Privacy Notice

Last updated April 1, 2022

Introduction

This privacy notice for Teton Research Group, LLC ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you: (1) Visit our website at www.tetonresearch.com, or any website of ours that links to this privacy notice (2) Engage with us in other related ways, including any sales, marketing, or events. Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us.

1. What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you use our Services or when you contact us. The personal information that we collect depends on the context of your interactions with us and may include the following: names, phone numbers, email addresses, mailing/physical addresses, job titles, contact preferences, and other personally identifying information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information during the scope of our engagement.

Information collected from other sources

In order to enhance our ability to provide relevant marketing and services to you, and update our records, we may obtain information about you from other sources, such as public databases, data providers, and other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, Internet Protocol (IP) addresses, social media profiles, and social media URLs.

2. How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. Your personal information may be processed in order to: (1) Facilitate account creation and authentication and otherwise manage user accounts; (2) Deliver and facilitate delivery of our services; (3) Respond to user inquiries/offer support to users; (4) Evaluate and improve our Services, products, marketing, and your experience; (5) Identify usage trends; (6) Comply with our legal obligations.

3. When and with whom do we share your personal information?

We may need to share your personal information in the following situations:

To recover your unclaimed property: In order for us to provide our Services to you, and aid in recovering your unclaimed property, we may need to provide your information to the third party entities we believe are holding your unclaimed property. These entities are almost exclusively government agencies.

Third party service providers: We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We contract with these service providers in order to provide an enhanced experience to our users. These service providers most notably include the contractors that we have partnered with to facilitate electronic document signature and electronic document notarization. Should you decide to utilize the electronic document signature or electronic document notarization capabilities we may offer, you consent to the distribution of your information to these third party partners.

Business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. How long do we keep your information?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. When we have no ongoing legitimate business need to possess your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. How do we keep your information safe?

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. Your data is encrypted both in transit and at rest. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only interact with our Services from a secure environment.

6. Do we collect information from minors?

We do not knowingly collect data from, solicit, or market to children under 18 years of age.

By using our Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at claims@tetonresearch.com.

7. What are your privacy rights?

You may review, change, or terminate your relationship with us at any time, within the context of our Master Agreement to Locate Property. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details by clicking here. If you are located in Switzerland, the contact details for the data protection authorities are available by clicking here.

8. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. Do we make updates to this notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

10. How can you contact us about this notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at claims@tetonresearch.com, by phone at 1-888-231-9889, or by post to:

Teton Research Group, LLC, 299 S. Main St, Suite 1300, Salt Lake City, UT 84111

11. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request by emailing us at claims@tetonresearch.com.

12. Do California residents have specific privacy rights?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and; (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, Internet Protocol address, email address, and account name YES
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information YES
C. Protected classification characteristics under California or federal law Gender and date of birth NO
D. Commercial information Transaction information, purchase history, financial details, and payment information NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements YES
G. Geolocation data Device location NO
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities YES
I. Professional or employment-related information Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us YES
J. Education Information Student records and directory information NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics YES

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at claims@tetonresearch.com, by calling toll-free at 888-231-9889, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. Teton Research Group, LLC has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Teton Research Group, LLC will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know: (1) whether we collect and use your personal information; (2) the categories of personal information that we collect; (3) the purposes for which the collected personal information is used; (4) whether we sell your personal information to third parties; (5) the categories of personal information that we sold or disclosed for a business purpose; (6) the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and (7) the business or commercial purpose for collecting or selling personal information. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

(1) You may object to the processing of your personal information; (2) You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information; (3) You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. (4) You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at claims@tetonresearch.com, by calling toll-free at 888-231-9889, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.