Who are We?
We are Two Harbors Investment Corp., 1601 Utica Avenue South, Suite 900, St. Louis Park, MN 55416, and its affiliates and subsidiaries (collectively, “Two Harbors,” “TWO,” “we,” “us,” or “our,” or the “company”).
What Personal Data do We Collect About You?
We and our third-party service providers collect information about you that you choose to provide us through our website or direct communication, which may include:
- Your name, email address, company, title, and telephone when you give it to us directly by signing up for our Investor Alerts, or by contacting us directly via email, telephone, or written letter.
As is true of most digital platforms, we and our third-party service providers also collect certain information automatically when you visit or interact with our website, which may include:
- Log data, including your internet protocol (IP) address, operating system, browser type, browser ID, device/Client ID, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our website; and
- Analytics data, including the electronic path you take visiting our website, as well as your usage and activity on our website, such as the links and objects you view, click or otherwise interact with (also known as “Clickstream Data”).
What is Our Legal Basis for the Processing of Your Personal Data?
We only process your personal data when we have a legal basis to do so.
We process certain personal data, namely, your email address, after you have granted free, specific, informed and unambiguous consent in this regard by signing up for our Investor Alerts. You are entitled at any time to unsubscribe from Investor Alerts, thereby withdrawing your permission for the processing of such personal data. This does not, however, affect the lawfulness of the processing on the basis of this consent prior to the withdrawal thereof.
We also process some personal data as is necessary for the purposes of legitimate interests, which may include:
- Fraud prevention and combating by the company (which are, in those specific cases, not overridden by your privacy interests); and
- Compliance with a legal obligation to which we are subject.
What do We do With The Information You Provide?
We and our third-party service providers acting our behalf may collect, store, and access your personal data for the following purposes:
- to administer and improve our website;
- to maintain any registered Investor Alerts account that you hold with us, including sending you informational update communications;
- to respond to our comments and questions and provide you support;
- to conduct research and analytics on visitor usage and activity relating to our website;
- to diagnose errors and problems with our website; and
- for fraud prevention, fraud combating and related anti-fraud measures, as well as to comply with legal duties imposed on TWO.
We will not disclose, sell, trade, or rent your personal data to any third party, save for any disclosures of your personal data detailed in this Privacy Policy. We may also disclose your personal data where necessary to comply with applicable law or an order of a governmental or law enforcement body.
Investor Alerts Registration
If you subscribe to our Investor Alerts, we will use the personal data provided by you to send you our Investor Alert emails and updates as agreed.
If you wish to unsubscribe from our Investor Alerts at any time, you can easily do this by clicking on the “Unsubscribe” link at the bottom of any email communication that we have sent to you, or via the Unsubscribe Page.
What do We do With Your IP Address and Cookies?
We use your IP address to help diagnose problems with our server and to administer our website. Your IP address is used to gather broad demographic information and is stored as a partial identifier.
We use essential, tracking cookies on the website, including Google Analytics. Certain cookies and technologies are essential in order for the website to operate, and some analyze traffic to optimize performance. These are necessary for us to provide the basic functionalities of the website. We will use these essential cookies and technologies also without obtaining your consent.
Most web browsers automatically accept cookies, but generally allow users to modify their browser settings to display a warning before accepting a cookie, to accept cookies only from certain websites, and/or to refuse all cookies. Please review your web browser settings if you want to use your web browser to control our cookies.
Is Your Personal Data Shared?
No, except as otherwise set forth under this Privacy Policy.
Only those employees of TWO and our third-party service providers whose access to the personal data is necessary will have access to it. Our employees, as well as the third-party service providers to whom personal data is made available, are obligated to respect the confidentiality of your personal data. We also impose this obligation on processors through a data processing agreement that we use when executing our services.
We do not in principle provide your personal data to third parties, unless this is necessary for the aforementioned purposes. In that context, we will provide your personal data to third party service providers who facilitate website hosting, information technology support, fraud prevention and browser session monitoring. In addition, we will make personal data available to third parties if a legal obligation or a court order requires us to do so, or with your express consent.
What are Your Rights?
You have the following rights:
- the right to ask what personal data we hold about you at any time and to obtain information in that regard;
- the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge;
- the right to erasure of your personal data (under circumstances listed in the applicable law);
- the right to restrict the processing of your personal data (under circumstances listed in the applicable law);
- the right to object against the processing of your personal data;
- the right to data portability (you can ask us to provide you or a third party with your personal data in a readable and accessible form; and
- the right to opt-out from communications.
For security purposes we may occasionally request proof of identity before we are able to disclose personal information to you. If you wish to exercise any of the above rights, please contact us at 1-800-680-2109 or privacyrequests@twoinv.com.
Pursuant to applicable California law, including the California Consumer Privacy Act (CCPA), TWO makes the following disclosures regarding the personal information it collects and discloses for a business purpose:
| Category of Personal Information | Category of Source from Which Data is Collected | Purpose of Collection | Category of Third Parties to Whom Data is Disclosed |
|---|---|---|---|
| Contact information such as name, mailing address, phone number, company position, and e-mail address | Directly from user | To enable you to take part in our Investor Alerts, for fraud prevention, fraud combating and related anti-fraud measures, as well as to comply with legal duties imposed on TWO or legal duty to use or disclose your information; to contact you (including by email) information which we think may interest you | Service Providers |
| Internet or other electronic network activity information, including, but not limited to, IP address, browsing history, search history, and information regarding a consumer’s interaction with an internet web site | Cookies and other tracking technologies | For monitoring, risk management, and administrative purposes; to make the website available to you | Service Providers |
| Where you have registered with us | Directly from user | To contact you (including by email) about TWO company updates | Service Providers |
| Your communication preferences | Directly from user | To contact you (including by email) about TWO Company updates we think would be of interest to you | Service Providers |
We have not sold your personal information in the last twelve (12) months.
Third Party Websites
This website contains links to other websites operated by third parties. Please note that this Privacy Policy applies only to the personal data that we collect through this website and we are not responsible for personal data that third parties may collect, store, and use through their websites. We recommend that you check the privacy policies of such other websites.
We do not exercise control over the websites that may be linked to the website. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you.
Collection of Information from Children
Our website is not directed to or intended to be used by children under 16 years of age. No one under the age of 16 is authorized to provide any personal information to or on the website, and we do not knowingly request or collect personal information from any individual under 16 years of age. If you are under 16 years of age, do not use this website, sign up for our newsletter, or provide any information about yourself to us, including without limitation your name, email address, postal address or location. If you are a parent or guardian and believe that your child under the age of 16 has submitted personal information to us in connection with the website or otherwise, please email privacyrequests@twoinv.com so that we can take steps to delete the personal information as required in accordance with applicable law.
Data Retention
We will not retain the personal data for longer than is necessary for the purposes for which it is collected or processed. We will in any case comply with legal data retention obligations.
Privacy Policy Changes
We may update this Privacy Policy from time to time and you should review this page periodically for such updates. When we change this Privacy Policy in any material way, we will update the “last modified” date within this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
This Privacy Policy was last updated in October 2021.
Contacting the Web Site
If you have any questions about this privacy statement, the practices of this site, or use of our trademarks and copyrighted material, or for any other concerns please feel free to contact us at privacyrequests@twoinv.com.