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The California Privacy Act, also known as CCPA, created consumer rights relating to Personal Identifying Information (“PII”) that is collected by businesses for consumers with a residence status in the state of California (“CA”).

The CA Department of Justice (Attorney General) adopted sections §§ 999.300 through 999.341 of Title 11, Division 1, Chapter 20, of the California Code of Regulations (CCR) concerning the CCPA. It went into effect on August 14, 2020 and additional amendments went into effect on March 15, 2021.

Continental implemented a CCPA policy in October of 2020. We comply with the CCPA regulations and additional amendments, effective on March 15, 2021,
to the extent that those regulations do not conflict with our recordkeeping requirements under current S.E.C. regulations.

We do NOT buy or sell PII.

We furnished letters of instruction to all consumers with a CA resident status when the regulations became effective in August of 2020, and continue to furnish letters to new consumers via USPS to provide an off-line method to easily opt-out. The letter also provides information for consumers to opt-out electronically by utilizing a “do not sell my info” link on our website. The link provides instructions to assist shareholders who wish to opt-out electronically by completing a form and submitting.

Effective on March 15, 2021 the following sections of the CCPA were modified:

Section 999.306 was modified to provide examples of how businesses that sell personal information that they have collected in the course of interacting with consumers offline can provide the notice of right to opt-out of the sale of personal information through an offline method. It has also been modified to provide a uniform icon required by the CCPA for the purpose of promoting consumer awareness of the right to opt-out of the sale of personal information.

Section 999.315 was modified to provide guidance on how a business’s methods for submitting requests to opt-out should be easy and require minimal steps. The provision includes illustrative examples of prohibited methods because they are designed with the purpose or substantial effect of subverting or impairing a consumer’s choice to opt-out.

Section 999.326 was modified to clarify the proof that a business may require an authorized agent to provide, as well as what the business may require of a consumer to verify their request.

Section 999.332 was modified to clarify that businesses subject to either section 999.330, section 999.331, or both of these sections are required to include a description of the processes set forth in those sections in their privacy policies.

Except for the opt-out icon, our policy complied with the March 15, 2021 amendments. The opt-out icon on our website has recently been updated with the required opt-out icon.

Continental provides certifications to all of our issuers located within CA or other issuers with CA consumers of resident status to the extent such shareholders have provided PII to us. In addition, we require our vendor partners who assist us with lost shareholder searches, escheatment of abandoned property, OFAC screening, etc. to confirm on an annual basis, that they are in compliance with the CCPA regulations as to our records.

Because of the extensive system programming as well as the process required to effect this regulatory change, it has become necessary to charge all affected issuers an annual fee and transaction charges.

Please contact your Account Manager for more information.

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