1. Who we are and our role
DEF 14 Inc., 99 Wall St. #4014, New York, NY 10005, United States, is responsible for personal information where we determine why and how it is processed, including website inquiries, account administration and our research database.
Where we process personal information on an institutional customer's behalf and under its instructions, the applicable customer agreement and data processing agreement govern that processing. The customer may be responsible for responding to requests concerning that information. Contractual terms do not remove privacy rights available under applicable law.
2. Information we collect
- Contact and account information: information you or your organization provide, such as your name, work email, company, role, account details and access entitlements.
- Trial, commercial and support records: trial requests, correspondence, customer agreements, billing administration, support requests, terms acceptance and privacy preferences.
- Website and platform information: device and browser details, IP addresses, session information and interactions with our website and platform, subject to applicable cookie choices.
- MCP request content: questions, search parameters and other information sent to our service by your connected assistant, together with the responses we return. The specific information depends on the tool invoked and what the assistant transmits. See Section 5.
- Operational metadata: technical records about access, request processing and service performance used to operate, secure and troubleshoot the MCP service. These records exclude question and response content.
- Research information: information about identifiable people obtained from public research sources, as described in Section 12.
We receive information from you, your organization, the assistant you connect, your interactions with our services and the research sources described below. Required form fields are identified when information is collected. Without information needed to assess a request or administer access, we may be unable to provide the requested service.
Please do not include passwords, access tokens or unnecessary personal or confidential information in queries or support messages. Our service is not intended for submitting sensitive personal information.
3. How we use information
We use personal information to assess trial requests; provide and administer services; authorize access; answer queries; provide support; maintain security; manage commercial relationships; comply with legal obligations; and exercise or defend legal claims. We also analyze service performance using operational information. Optional use of trial request content is described separately in Section 4.
Where European or UK data protection law applies, the following bases apply as appropriate to the activity:
- Contract: to take steps you request before entering a contract with you, or perform a contract to which you are a party.
- Legitimate interests: to administer business customer relationships, operate and secure our services, support users, maintain relevant research and protect legal rights, where those interests are not overridden by your rights and interests. This is generally the relevant basis for administering access for employees of an institutional customer.
- Consent: for optional trial-content improvement use and for marketing or non-essential cookies where consent is required. You can withdraw consent without affecting processing lawfully undertaken before withdrawal.
- Legal obligations: for processing required by applicable law.
4. Free trials
When you request a trial, we use your contact and company information to assess the request, communicate with you and administer access. Submitting a request does not automatically subscribe you to optional marketing.
During an MCP trial, questions and responses may be retained for up to 90 days from collection unless zero retention is enabled. Retained trial content is used to provide and troubleshoot the trial service. You can enable zero retention in the platform before your first MCP query. Enabling it applies to future requests. Do not assume that changing this setting deletes previously retained content; you may contact us to request deletion of that content.
Product-improvement use is optional. Only with your separate permission may authorized administrators review retained trial questions and responses to identify errors, evaluate response quality and improve search and retrieval. This permission does not authorize training AI models. Declining or withdrawing it does not remove trial access. Zero-retention requests are not retained for these activities.
You can withdraw this permission by contacting us using Section 14.
Ending a trial does not restart the retention period. On conversion to a paid account, zero retention applies automatically to new MCP requests. You may request deletion of retained trial content at any time, subject to applicable legal exceptions.
5. MCP and connected AI assistants
The MCP service enables compatible AI assistants to retrieve DEF 14 research and display results, including charts and dashboards. Read-only tools can still transmit personal or confidential information in their inputs.
DEF 14 receives the information the connected assistant sends when invoking a tool, processes the request and returns a response. Connecting an assistant does not by itself mean DEF 14 receives your entire conversation. However, questions or tool parameters can contain conversation context or other information selected by the assistant or user.
Paid accounts automatically receive zero retention for MCP questions and responses. Under zero retention, request content is processed to complete the request and is not retained afterward. Paid MCP questions and responses are not used for model training, product improvement, response evaluation or routine human review.
This zero-retention commitment concerns MCP request content. It does not require deletion of DEF 14's underlying research database, ordinary account and contract records, or content you separately choose to save in the platform or send to support.
Your AI provider has separate practices. It receives the information you provide to it and the results returned through the MCP connection. Its retention, training and privacy settings are governed by its own policies and your arrangements with it. DEF 14's zero-retention setting does not delete or control copies held by that provider, your organization or you.
6. Retention and deletion
| Information | Retention approach |
|---|---|
| Paid MCP questions and responses | Processed to fulfill the request; not retained after completion under the zero-retention commitment in Section 5. |
| Trial MCP questions and responses | Up to 90 days from collection unless zero retention applies. Changes to earlier content are described in Section 4. |
| MCP operational metadata | 90 days from collection, excluding question and response content. |
| Account, trial-request and support records | For as long as needed to assess and follow up on a request, administer an active account or resolve a support matter. After the request or relationship ends, we retain only records needed for outstanding matters, applicable legal obligations or the establishment, exercise or defense of legal claims; otherwise we delete or anonymize them. |
| Contracts, billing and legal records | For the periods required by applicable recordkeeping obligations and relevant limitation periods, limited to the information needed for those purposes. |
| Consent, acceptance and preference records | For as long as needed to honor your choices and demonstrate the applicable permission or agreement, considering relevant legal requirements. Minimal suppression information may be retained to respect an unsubscribe request. |
| Cookies and website analytics | For the period needed for the relevant session, preference or analytics purpose, taking into account the technology used and applicable privacy choices. Contact us for information about the cookies and analytics records associated with your use. |
| Research information | While relevant to our research and historical coverage, subject to accuracy reviews and applicable privacy rights. |
Time limits are measured from collection unless stated otherwise.
Where preservation of existing records is required by law or necessary for a specific legal claim, we restrict further use to that purpose and delete them when preservation is no longer needed. This does not mean that request content is routinely retained under zero retention.
9. International processing
DEF 14 is based in the United States, and our MCP infrastructure is hosted on AWS in the United States. Information may therefore be processed outside the country where you are located.
Privacy laws in the United States may differ from those in your country. Where applicable law requires safeguards for an international transfer, the transfer must be covered by an appropriate legal mechanism. Contact us for information about the destinations and safeguards applicable to your information, or to request a copy of applicable contractual safeguards, subject to necessary redactions.
Using our service does not by itself constitute consent to a restricted international transfer or replace a required transfer safeguard.
10. Security
We use technical and organizational measures designed to protect personal information and restrict access according to responsibilities and the information needed for authorized tasks. No online service can guarantee absolute security. Keep your credentials confidential and contact us if you suspect unauthorized access.
11. Your rights and choices
Depending on your location and applicable law, you may have rights to access or obtain a copy of your information; correct it; request deletion; restrict or object to processing; receive a portable copy; and withdraw consent where processing relies on consent. These rights are subject to applicable conditions and exceptions. Where applicable, you may also appeal a decision about your request and complain to your local data protection authority.
Contact us using Section 14 to exercise a right or ask a privacy question. We may request proportionate information to verify your identity or authority. We respond within applicable legal deadlines and do not discriminate against you for exercising applicable privacy rights. Where we act on your organization's instructions, we may refer the request to it or assist it in responding.
Disconnecting, revoking access and deleting data are different actions. You can remove the MCP connection from your assistant. To revoke DEF 14 authorization or request deletion of retained information, use the available platform controls or contact us. Removing a connection does not itself delete existing records, and DEF 14 cannot delete copies controlled by your AI provider.
Our services are intended for adult business and institutional users, not children. If you believe a child has provided us with personal information, please contact us.
12. Personal information in research sources
Our shareholder activism research may include professional information about identifiable people, such as directors, officers, shareholders and activists, including their roles, affiliations, disclosed ownership and involvement in corporate events. Sources may include regulatory filings, company disclosures and other public research materials.
We organize and make this information available to customers for business research, including through the platform and MCP. Where applicable, we rely on our legitimate interests in providing relevant, accurate business research, balanced against individuals' rights and interests. Public availability does not remove applicable privacy protections. Contact us to raise an accuracy concern or exercise applicable rights concerning information about you.
13. Changes to this policy
We may update this policy as our services, practices or legal obligations change. We will post the revised policy with an updated effective date and provide additional notice of material changes where required. Where a new use requires consent, we will obtain it before that use begins.
14. Contact us
DEF 14 Inc.
99 Wall St. #4014
New York, NY 10005
United States
Privacy requests and questions: demo@def14.co.