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:
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:
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:
We process your Personal Data for the purposes described above:
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:
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
Here are examples of third-party providers of analytics and similar services we currently use:
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
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 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.
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
Postal Address:Information and Data Protection Commissioner, Floor 2, Airways House, High Street, Sliema, SLM 1549, Malta.
8 Nov 2019
Data Protection Officer
30 Oct 2020