Global Shares Participants Privacy Statement

Your privacy is important to Global Shares. We developed this Privacy Statement, so you know how we collect, use, share and store your personal data.

Personal Data means any information relating to an identified or identifiable natural person. In practice, this means any data about a living person who can be identified from the data available will count as personal data.

Through our continued commitment to protect your privacy we at all times seek to comply with the EU General Data Protection Regulation, the Maltese Data Protection Acts and the Irish Data Protection Acts (the Data Protection Law).  Global Shares is committed to providing the highest levels of protection to your personal data in compliance with the Data Protection Law.

This Privacy Statement supplements your general terms and conditions.

What Personal Data do we process?

In the context of providing share plan administration services to you Global Shares will process the following Personal Data:

  • Personal details such as your full name, and address, nationality, date of birth, telephone numbers, e-mail addresses and Personal Public Service Number or other national identity number and global identification number.
  • Details of your employment status to include employment date, termination date and termination reason code
  • contribution details.
  • Bank account number
  • Town or City and Country of Birth
  • National identifier pursuant to Commission Delegated Regulation (EU) 2017/590
  • Share sales & purchases
  • Dividend payments
  • Online identifier
  • Primary and secondary tax residency
  • Tax ID
  • Customer Due Diligence documentation for AML/CFT compliance including:
    • Photographic identification document such as passport or driver’s licence
    • Non-photographic identification document such as a utility bill or bank statement
    • Electronic photographs

Where do we obtain your Personal Data from?

We will collect your Personal Data in a number of ways. Much of the Personal Data we collect will be provided directly by you when you join an equity plan, sign up for services or when you contact us by email, letter, phone, or submit Personal Data online. We also generate payment, holdings and transaction data as a function of providing a service to you.

We may also receive your Personal Data from the following third parties:

  • Your employer - if you are a participant in a company equity plan, your employer may provide us with your name, date of birth, contact details, identity information, share entitlement data, employment details, compensation and/or payroll information, and other Personal Data.

  • Private brokers - if you request that we liaise with a private broker in respect of your shares we may receive Personal Data from the broker. The private broker’s privacy policy should inform you what Personal Data they may send to us.

  • Government agencies.

When you visit our websites or open emails from us, we collect information about your website use and email viewing so we can improve our services. For more information about how we collect this information please see our Global Shares Website Privacy Statement. 

How we use your Personal Data and the legal basis for this use

We use your Personal Data for the following reasons:

  • To provide you with customer and service support.

  • We may access your Global Shares account in order to assist us in providing you the necessary assistance.

  • To carry out your instructions in relation to your account.

  • To communicate with you about your account or transactions with us.
  • To comply with our legal and regulatory obligations, for example, transaction reporting under rules imposed by the relevant financial authorities.

  • To detect, prevent and report financial crime.

  • To manage our business in an efficient and proper manner, including the management of our financial position, our resources, the risks to which we are exposed and the way in which we arrange our internal operations

We process your Personal Data for the purposes described above:

  • when necessary to enter into and fulfil a contract or arrangement with you;
  • when necessary for us to comply with a legal obligation;
  • when necessary for the pursuing our legitimate interests as a contracting party.

Other Uses of Personal Data by Global Shares

Global Shares may use Personal Data for internal statistical, marketing or operational purposes, including generating sales reports and measuring and understanding demographic, user interest and other trends among our customers.

Entities with Which Global Shares May Share Personal Data

-          With Other Global Shares Companies

Global Shares is a global business. To offer our services, we may need to transfer your Personal Data to other Global Shares companies in other countries, including our companies in the United States, where many of our servers are located. Those countries may not have the same data protection laws as the country in which you initially provided the information.

Any such transfers of Personal Data from Global Shares companies in the European Economic Area ("EEA") or Switzerland to Global Shares companies in the United States are done so in compliance with the Data Protection Law.

All Global Shares companies are required to follow the privacy practices set forth in this Privacy Statement.

-          With Service Providers

We use third party service providers to help us to provide services to you. We may share your Personal Data with such third party service providers to the extent necessary for the sole purpose of enabling them to perform services on our behalf and where there are written contract terms between Global Shares and the service provider which satisfy the requirements of the Data Protection Laws.

Here are examples of third-party service providers we use:

  • Email Providers: Microsoft Office 365 is used to assist Global Shares in sending emails, consistent with applicable laws and the choices available to you.
  • Custodians: Global Shares uses third-party custodians to hold securities for employees availing of our employee share plan.
  • Banks: Global Shares uses third-party banks to hold and transfer funds to employees.
  • Data Hosting: All Personal Data, is hosted in hosted database companies’ data centres. If you are employed in the EU/EEA, your information will primarily be held within the EU/EEA.
  • Other external contractors: Global Shares uses a number of other external contractors to process Personal Data. This allows Global Shares to perform its obligations under various contracts with relevant data subjects. 

Other Disclosures

Subject to applicable laws in your jurisdiction, we may also disclose Personal Data about you to others as we believe to be necessary or appropriate:

(a) under applicable law or regulation, including laws or regulations outside your country of residence;

(b) to comply with legal process;

(c) to respond to requests from public authorities and law enforcement officials, including officials outside your country of residence;

(d) to assist or support theft investigations involving Global Shares products or property;

(e) to enforce any of our terms and conditions or policies;

(f) to protect our operations or those of any of our affiliates and subsidiaries;

(g) to protect the rights, privacy, safety or property of Global Shares, its affiliates and subsidiaries, you or others;

(h) to permit us to pursue available remedies or limit the damages that we may sustain; or

(I) Global Shares may be required to disclose Privacy Shield Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may also transfer your Personal Data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Global Shares’ business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

Cookies and Similar Technology

To help analyse how you and other visitors navigate Global Shares websites, and compile aggregate statistics about site usage and response rates, we, with assistance from third-party analytics service providers, collect certain information when you visit our site. This information includes IP address, software version, what information and files have been downloaded to the device, device state information, device model, hardware and operating system information, information relating to how device functions, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), demographics, page views and page elements (e.g. links) that you click. We may use cookies, pixel tags or other similar tools on our site or in our email messages to assist us in collecting and analysing such information. We use this information to provide better, more relevant content on our site, to identify and fix problems, and to improve your overall experience on our site.

If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them. In addition, if you reside in a jurisdiction that requires us to obtain your consent to use cookies on our sites then you will have an opportunity to manage your cookie preferences on the sites; except that certain cookies are required to enable core site functionality and you cannot choose to disable those cookies.  If you do not wish to have any further data gathered by those cookies you should not browse the website any further if you have not provided consent.

Here are examples of third-party providers of analytics and similar services we currently use:

  • Google: Google Analytics is used to track site statistics and user demographics, interests and behaviour on websites. We also use Google Search Console to help understand how our website visitors find our website and to improve our search engine optimization. Learn more about how this analytics information may be used, and on how to control the use of your information.
  • Social Networks: Third-party social networks that provide interactive plug-ins or social networking features (for example, to allow you to connect to Facebook or Google to find friends to add as connections or to "Like" a page) on Global Shares websites, may use cookies or other methods (for example, web beacons) to gather information regarding your use of our websites. The use of such information by a third party depends on the privacy policy available on that social network’s website, which we encourage you to carefully review. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our site with any of your Personal Data that they may have. We may also obtain analytics information from social networks that help us measure the effectiveness of our content and advertisements on social networks (e.g., impressions and clicks).

Types of Cookies Used

Each of our websites may use different cookies for different purposes. The cookies used include:

ga, PHP SES SID

 Links, Third Party Apps, and Third Parties’ Privacy Practices

Our websites and products may contain links to other sites that are not operated by Global Shares, and our websites or product may contain apps that you can download from third parties. These linked sites and apps are not under our control and we are not responsible for the privacy practices or the content of any linked sites and apps. If you use any third-party sites or apps, any Personal Data collected by the third party’s site or app will be controlled by the privacy policy of that third party. We recommend that you carefully review the privacy statements of any third parties to which you provide Personal Data.

Security

Global Shares takes reasonable security measures to help protect against loss, misuse, unauthorized access and unauthorized disclosure or alteration of the Personal Data under its control.

Your Choices regarding Marketing Correspondence

We and other members of the Global Shares group of companies may use your Personal Data to send you marketing-related correspondence (including emails) related to Global Shares products in accordance with your email preferences. We do not share your Personal Data with third parties for the third parties’ marketing purposes.

To opt out of receiving marketing-related correspondence from Global Shares, please click "Unsubscribe" from any marketing email you receive from Global Shares.

Privacy Statement Updates

We may change this Privacy Statement from time to time as we add new products, as we improve our current offerings, and as technologies and laws change. You can determine when this Privacy Statement was last revised by referring to the date of this Privacy Statement at the bottom of this page. Any changes will become effective upon our posting of the revised Privacy Statement on our affected websites.

Retention of Personal Data

We will retain your Personal Data for the period necessary to fulfill the purposes for which your Personal Data has been collected as outlined in this Privacy Statement unless a longer retention period is required by law.

How You Can Request Access to, Review, Correct, Update, Transfer and Delete Your Personal Data

Global Shares takes reasonable steps to help ensure that the Personal Data we collect from you is accurate, complete and current. You may request access to your Personal Data and request that erroneous or inaccurate Personal Data be updated. You may request that your Personal Data and Global Shares account be deleted. You may also request that Global Shares no longer process your Personal Data for particular purposes. You may request that your Personal Data is transferred to another organisation, or to you, in certain circumstances. Global Shares will respond promptly to your requests in accordance with applicable law. For your protection, we may need to verify your identity before implementing your request. We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain Personal Data for a longer period of time for recordkeeping purposes, such as retaining records relating to your purchases for warranty or accounting purposes.

All Data Subject Access Requests and other requests can be made in writing to the postal address below:

Postal address: Data Protection Officer, Global Shares, Building D, West Cork Technology Park, Clonakilty, Co. Cork P85 EY90, Ireland.

Withdrawal of Consent

Where the legal basis for us using your Personal Data is that you have given your consent, you may withdraw your consent at any time. If you do so we will stop using your Personal Data promptly.

EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework

Global Shares complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States.  Global Shares has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Global Shares is also subject to the investigatory and enforcement powers of the Federal Trade Commission. 

Complaints Regarding Our Privacy Shield Policy

In compliance with the Privacy Shield Principles, Global Shares commits to resolve complaints about our collection or use of your Personal Data.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Global Shares in writing at the following postal address:

Postal address:Data Protection Officer, Global Shares, Building D, West Cork Technology Park, Clonakilty, Co. Cork P85 EY90, Ireland.

Global Shares has further committed to cooperate with the panel established by the EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.

Queries and complaints

If you have any queries about this Privacy Statement please contact our designated Data Protection Officer in writing at the postal address below:

Postal address: Data Protection Officer, Global Shares, Building D, West Cork Technology Park, Clonakilty, County Cork.

Complaints

If you are not satisfied with the outcome of the response you receive or believe we are not processing your Personal Data in accordance with the law, then you are entitled to make a complaint to the data protection authority in your country.  For ease of reference please see contact details for the Irish and Maltese data protection authorities:

Data Protection Commission Ireland

Global Shares Ireland Limited is registered with the Irish Data Protection Commission.  Their website is www.dataprotection.ieor you can contact their office at:

Lo Call Number:1890 252 231

Email: [email protected]

Postal Address:Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23.

Data Protection Commission Malta

Global Shares Execution Services Limited is registered with the Maltese Office of the Information and Data Protection Commissioner’s website is https://idpc.org.mt/en/Pages/Home.aspxor you can contact their office at:

Telephone Number:(+356) 2328 7100

Email:[email protected]

Postal Address:Information and Data Protection Commissioner, Floor 2, Airways House, High Street, Sliema, SLM 1549, Malta.

Version Control

Date:

8 Nov 2019

Owner:

Data Protection Officer

Version

V1.2

Review Date:

30 Oct 2020

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