Legal

Privacy Policy

This Privacy Policy explains how DEF 14 Inc. ("DEF 14," "we," "us" or "our") collects, uses, discloses and retains personal information through our website, trial request forms, research platform, APIs and Model Context Protocol (MCP) service, and when you contact us. Our services are intended for business and institutional users.

Personal information can include professional contact details, account identifiers, IP addresses and information about identifiable people in public research sources. Information does not cease to be personal information because it is business-related or publicly available.

This policy explains our data practices. It does not replace our Terms and Conditions or constitute consent to optional processing. Where we request your consent, we do so separately.

Effective date: September 15, 2026

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

InformationRetention approach
Paid MCP questions and responsesProcessed to fulfill the request; not retained after completion under the zero-retention commitment in Section 5.
Trial MCP questions and responsesUp to 90 days from collection unless zero retention applies. Changes to earlier content are described in Section 4.
MCP operational metadata90 days from collection, excluding question and response content.
Account, trial-request and support recordsFor 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 recordsFor the periods required by applicable recordkeeping obligations and relevant limitation periods, limited to the information needed for those purposes.
Consent, acceptance and preference recordsFor 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 analyticsFor 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 informationWhile 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.

7. Who receives information

We disclose information only as needed for the purposes described in this policy, including to:

  • Service providers supporting hosting, infrastructure, account administration, communications, support and security. AWS supports our MCP infrastructure. Providers acting on our behalf are subject to applicable contractual confidentiality and data-processing requirements.
  • Your connected AI provider, which receives MCP results through the connection you use.
  • Your organization, where needed to administer its accounts and entitlements. This does not grant it access to content that DEF 14 does not retain under zero retention.
  • Professional advisers, authorities or other parties where reasonably necessary to comply with law, protect rights or address fraud, security incidents or legal proceedings.
  • Parties to a corporate transaction, where necessary for a proposed or completed merger, financing, reorganization or business transfer, subject to appropriate confidentiality protections.

We do not sell or rent user personal information or disclose it to external advertisers for their own marketing.

Access to retained MCP trial content is limited to administrators with the highest authorized permission level who need access for the purposes disclosed in this policy. Permission to use trial content for improvement does not authorize a third party to train its own models on that content.

8. Cookies and marketing

We use cookies and similar technologies to support functions such as authentication and session management. Where we use non-essential analytics or other tracking technologies, we provide information about them and obtain consent before activation where required by law. You may also manage cookies in your browser; disabling essential cookies may affect service functionality.

Where you choose to receive marketing emails, we use your professional contact details to send DEF 14 news and offers. You can unsubscribe through the email link or contact us. We do not use MCP questions or responses to select or personalize marketing. Necessary account, security and service messages are separate from optional marketing.

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.