Data Controller and Privacy Officer
This policy applies to Royal Gold, Inc. and its subsidiaries globally (together, “Royal Gold,” “we,” “our,” or “us”), which may be the data controllers for your personal information. These are the organizations that determine how and why your personal information is processed. In addition, while we are responsible for our website, we have outsourced its management to a third-party website administrator, which is the data controller of all personal information that is processed through our website.
We have a privacy officer to oversee compliance with this policy who may be reached at CorporateSecretary@royalgold.com. If you have general questions or would like to review, delete, deactivate, or update any information that you previously provided to us, you may contact us at InvestorRelations@royalgold.com.
Our privacy officer will use reasonable efforts to respond promptly to requests, questions, or concerns you may have regarding our use of your personal information.
Personal Information that We May Collect and Use
We may collect, use, store, and transfer different kinds of personal information about you, such as:
- Identity Data, including your first name, last name, title, company name, username or similar identifier, age, gender, and professional or work history
- Contact Data, including your address, email address, and telephone numbers
- Transaction Data, including details of inquiries you have made about us and our business
- Technical Data, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website
- Profile Data, including your username and password, your interests, preferences, feedback, or survey responses, the industry or market you work in, and your attendance at industry or market events
- Usage Data, including information about how you use our website and information provided on our website
- Marketing and Communications Data, including your preferences for when and how you receive marketing and other communications from us
How We Collect Personal Information about You
- Direct Interactions. We receive most of your personal information directly from you, such as when you contact us through our “Subscribe” form on our website or by post, phone, email, or otherwise, when you subscribe to our publications or request investor communications, receive proxy materials as a stockholder, or you give us feedback.
- Third Parties or Publicly Available Sources. We may receive personal information about you from third parties and public sources, including (a) Technical Data from analytics providers, advertising networks, and search information providers, and (b) Identity Data and Contact Data from publicly available sources, such as trade association or trade show registries, professional social media platforms (for example, LinkedIn), investor relations groups, and government or national authority registries (for example, the U.S. Office of Foreign Assets Control Sanctions List).
Purposes of Processing Personal Information
We may collect, use, process, transfer, and store your personal information for the following purposes:
- Maintaining our relationship with you
- Responding to your questions
- Fulfilling our legal or similar obligations
- Monitoring our contractual relationships
- Maintaining and improving our website
- Informing you about Royal Gold
- Inviting you to upcoming events, conferences, or meetings
The basis for processing personal information for the purposes identified above include complying with legal obligations and processing that is necessary for our legitimate business interests, including, but not limited to, developing and maintaining relationships with potential and existing investors and counterparties as well as maintaining and developing our website.
Access to and Transfer of Personal Data
Your personal information may be transferred outside of the country where you work or reside when necessary to accomplish the purposes described in this policy. This may include the transfer of your personal information among Royal Gold and its subsidiaries or third-party service providers located outside of the country in which you reside or work. For example, because our website is hosted on servers located in the United States, if you are visiting our website from a different country and providing personal information to us as a result, your personal information will be transferred to the United States.
Securing Personal Data
We maintain appropriate organizational and technical safeguards to protect your personal information from unauthorized or unlawful processing and from accidental loss, destruction, or damage. We have implemented procedures to deal with any suspected data breach affecting your personal information and will notify you and any applicable regulator of a breach if we are legally required to do so.
Length of Retention of Personal Information
To determine the appropriate retention period for personal information, we consider the purposes for which we process such personal information and applicable legal requirements.
Your Rights with Respect to Personal Information Held by Us
Depending on your circumstances and the privacy laws that apply to you, you may enjoy the following rights with respect to personal information held by us:
- Right of access. You may obtain access to the personal information that we hold about you. If you make this request, we will ask for specific information from you to verify your identity and to search for and provide you with your personal information. Your access may be limited if providing the access would be a violation of applicable law, excessive, or unreasonable, such as compromising the privacy of another person or exposing sensitive company information.
- Right to rectification. You may obtain rectification of your personal information without undue delay to the extent that personal information is inaccurate, outdated, or incomplete.
- Right to erasure. Under certain circumstances, you may ask us to delete or remove personal information, such as when we no longer have a legitimate interest to continuing to process it. If we are not able to comply with your request of erasure for specific reasons, we will notify to you.
- Right to restriction. Under certain circumstances, you may ask us to suspend the processing of your personal information, such as during the time while we are considering your request to rectify the accuracy of your personal information.
- Right to object. You may object to the processing of your personal information if we are processing your personal information for direct marketing purposes, including profiling.
- Right to request transfer. Under certain circumstances, you may request your personal information be transferred to you or to a third party in a structured, commonly used, machine-readable format.
- Right to make a complaint. You may have the right to lodge a complaint with the relevant data protection authority, where applicable, in your country.
If you want to exercise any of these rights in relation to your personal information (excluding your right to make a complaint), please contract our privacy officer in writing at CorporateSecretary@royalgold.com.
Updated July 2020