Global Shares

Privacy Statement

Introduction

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

This Privacy Statement applies to all websites on which this Privacy Statement is shown. If a Global Shares website links to a different privacy statement, then that privacy statement will apply to your use of that site.

Ways Global Shares Collects and Uses Personal Information

"Personal Information" is information that, either alone or in combination with other information collected, identifies an individual. When we combine other information (i.e., information that does not, on its own, identify an individual) with Personal Information, we treat the combined information as Personal Information.

When you Create a Global Shares Account

When you create an account on a Global Shares website, we ask you to provide Personal Information, which may include information such as your name, email address, bank details, residency etc. You will use your email address or username and your password to login to your account. Your Global Shares account will be password-protected. We use your name to help verify your account when you call customer support.

When you Communicate with Global Shares

When you interact with our us via email, telephone or in person, we may collect Personal Information, such as your name, mailing address, phone number, email address and contact preferences; and information about the Global Shares services you receive. We use this information 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 improve customer service, subject to applicable laws, we may also record and review conversations with us.

We may use Personal Information to communicate with you, including communicating with you about your account or transactions with us, giving you important information about our services, sending you notice about material changes to this Privacy Statement or other legally binding information.

Other Uses of Personal Information by Global Shares

Global Shares may use Personal Information 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 Information

-        With Other Global Shares Companies

Global Shares is a global business. To offer our services, we may need to transfer your Personal Information 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 Information 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 General Data Protection Regulation (Regulation EU 2016/679) (“GDPR”).

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 Personal Information about you 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 GDPR.

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

  • Email Providers: Cloud services from Microsoft are 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 customers availing of our employee share plan services.
  • Banks. Global Shares uses third-party banks to hold and transfer funds to customers availing of our employee share plan services.
  • Data Hosting: All Personal Information, and back is hosted in Rackspace Inc.’s data centres in EU or US. The location for hosting your data will depend on the location of your employer company, and their instruction to us.

Other Disclosures

We may disclose Personal Information about you to others if we have your consent to do so in such form of consent as may be required under applicable law.

Subject to applicable laws in your jurisdiction, we may also disclose Personal Information 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; or

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

We may also transfer Personal Information 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, 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, web beacons, clear GIF’s or other similar tools on our site or in our email messages to assist us in collecting and analyzing 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.

We may use locally stored objects, also known as Flash cookies, in certain situations where we use the Adobe Flash Player to provide special content such as videos or video clips. Flash uses this technology to remember settings, preferences and usage similar to browser cookies but Flash cookies are not managed through your web browser. 

We track and collect data from users about their usage of Global Shares’ websites. The types of analytical information that we may collect include the date and time the device accesses our servers, software version, the geographic location of the device, language, what information and files have been downloaded to the device, user behavior (e.g. what features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the device functions. Global Shares uses this data to improve the quality and functionality of its websites and services; to develop and market products and features that best serve you and other users; and to help identify and fix usability problems as quickly as possible.

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 behavior 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 Information 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 Information 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 Information.

Security

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

Your Choices regarding Marketing Correspondence

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

Policy with Respect to Children

Our websites are not directed to individuals under the age of 16, and we request that individuals under 16 not provide Personal Information to Global Shares through any Global Shares website. If we learn that we have collected the Personal Information from a child under 16, we will take steps to delete the information as soon as possible. If you are aware of a user under the age of 16 using a Global Shares website, please contact us at info@globalshares.com.

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. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on our affected websites, consistent with applicable laws.

Retention of Personal Information

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

How You Can Review, Correct, Update and Delete Your Personal Information

Global Shares takes reasonable steps to help ensure that the Personal Information we collect from you is accurate, complete and current. You may request access to your Personal Information and request that erroneous or inaccurate Personal Information be updated. You may also request that your Personal Information and Global Shares account be deleted. Global Shares will respond promptly to your requests in accordance with applicable law. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and 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 Information for a longer period of time for recordkeeping purposes, such as retaining records relating to your purchases for warranty or accounting purposes.

Access, correction or deletion requests can be made as follows:

Email: info@globalshares.com Mail: Global Shares Ireland Limited, Building D, West Cork Technology Park, Clonakilty, Co. Cork, Ireland

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 information 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 (“FTC”). 

Complaints

In compliance with the Privacy Shield Principles, Global Shares commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Global Shares at:  Global Shares (Complaints), 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 (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.

Contact Us

If you have any queries about Global Shares data protection policy or practices, please write to: Global Shares, Building D, West Cork Technology Park, Clonakilty, Co. Cork, Ireland or email info@globalshares.com.

Date: 24th April 2018

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