Last Updated: January 2022
1. About Us
We are GLOBAL SHARES PUBLIC LIMITED COMPANY and its related companies which include:
The following trust companies:
Our headquarters is at West Cork Technology Park, Clonakilty, Cork, Ireland
Email: [email protected]
Website is www.globalshares.com
References to “We”, “Us” and “Global Shares” shall apply to the company in the group that is processing your Personal Data.
We are a company that:
The Global Shares group has its headquarters in Ireland which means that we must comply with the EU General Data Protection Regulation (“EU GDPR”) when processing the Personal Data of all our Users. This means we must provide information to you about how we process Personal Data and set out the basis on which any Personal Data we collect from You, or that You provide to Us, will be used by Us where We are controllers of that Personal Data for the purposes of the GDPR.
In this Privacy Notice, we provide further information about what Personal Data we collect, what we use it for, why we collect it and what our legal basis is, who we share it with and how long we retain it. We also provide detailed information about your rights in relation to your Personal Data. If you have further questions, please get in touch with us using the contact details below.
For Users who are not based in the EU, we have provided additional supplementary information, where relevant to local data protection and privacy laws.
2. Contact details
We have appointed a Data Protection Officer (“DPO”). If you have any questions about this Privacy Notice or the way in which your Personal Data is being used by us, please contact:
The Data Protection Officer
West Cork Technology Park,
Clonakilty, Cork,
Ireland
3. The purpose of this privacy notice
This Privacy Notice applies to Personal Data and applies specifically to Users of the Equity Gateway platform who have a share dealing account with Global Shares (“Share Account”).
The definition of Personal Data is as follows:
“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
This Privacy Notice describes our approach to data protection and sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us where we are controllers of that Personal Data for the purposes of the GDPR. Please read this Privacy Notice carefully to understand our views and practices regarding the Personal Data we collect, as controllers under the GDPR, and how we will treat it.
4. Who this privacy notice applies to
This Privacy Notice provides specific information relating to Users who have Share Accounts whose Personal Data we process.
Global Shares has split our Privacy Notice into four separate notices as follows:
5. Sources of personal data
USERS CONTACT PERSONAL DATA
We collect Contact Personal Data from our Users who have a Share Account.
We source Personal Data in order to manage the Share Accounts. We will only ever source Personal Data that is necessary and in a way that would be generally expected.
We receive Personal Data about you from a variety of sources, as follows:
6. Categories of personal data
We process the following categories of Personal Data. For each category we have included an example of the type of Personal Data that may be part of that category:
7. Our legal basis for processing personal data
We process all Personal Data lawfully and in accordance with the requirements of the law. The GDPR sets out the legal grounds for processing Personal Data.
When we process Personal Data, it is generally on one of the following legal basis:
CONTRACT
We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract. When you activate a Share Account, you enter into a contract with us when you complete the account opening task and accept the Share Account terms and conditions.
CONSENT
For certain processing activities we may rely on your consent.
Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so.
You can withdraw consent provided by you at any time by contacting us at [email protected]
LEGITIMATE INTEREST
At times we will need to process your Personal Data to pursue our legitimate business interests, for example for administrative purposes, to provide information to you, to operate, evaluate, maintain, develop and improve our platform, mobile app and services or to maintain their security and protect intellectual property rights.
We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweighs our legitimate interests.
You may object to any processing we undertake on this basis.
If you do not want us to process your Personal Data on the basis of our legitimate interests, contact us at [email protected] and we will review our processing activities.
LEGAL OBLIGATION
If we have a legal obligation to process Personal Data, such as anti-money laundering, anti-terrorist legislation or financial markets regulations we will process Personal Data on this legal ground.
8. Out processing activities
We use your Personal Data to provide you with our services and to assist us in the operation of our Employee Share Accounts. Under data protection law, we must ensure that the purpose of processing is clear.
We have set out below the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing for the Share Accounts.
USERS WITH SHARE ACCOUNTS
9. Disclosure of personal data
In certain circumstances, we may disclose Personal Data to third parties as follows:
10. Security measures
We will take all steps reasonably necessary to ensure that all Personal Data is treated securely in accordance with this Privacy Notice and the relevant law, including the GDPR.
In particular, we have put in place appropriate technical and organisational procedures to safeguard and secure the Personal Data we process.
We monitor for and do everything we can to prevent security breaches of the Personal Data that we process.
Once we have received your Personal Data, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your Personal Data can access it.
We also use secure connections to protect Personal Data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential. Please do not share your password with anyone.
If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately.
11. Transfers outside the EEA
In order to provide our products and services we may need to transfer Personal Data outside the European Economic Area (EEA). We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR.
If we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission. We may also rely on some of the other legally compliant transfer mechanisms provided under the GDPR.
12. Retention
In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required by law or for the purposes of legal claims.
Further information about our retention practices are set out below:
13. Your Rights
EU Users
You have various rights relating to how your Personal Data is used.
Right of access to the Personal Data we hold on you
You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to everything we’ve recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.
We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.
We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.
Right of rectification of Personal Data
You should let us know if there is something inaccurate in your Personal Data.
We may not always be able to change or remove that Personal Data, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
Right of erasure of Personal Data (right to be forgotten)
In some circumstances you can ask for your Personal Data to be deleted, for example, where:
Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.
Please note that we can’t delete your Personal Data where:
Right to restrict what we use your Personal Data for
You have the right to ask us to restrict what we use your Personal Data for where:
When Personal Data is restricted, it can’t be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.
Right to have your Personal Data moved to another provider (data portability)
You have the right to ask for your Personal Data to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
This right only applies if we’re using your Personal Data with consent and if decisions were made by a computer and not a human being. It does not apply where it would adversely affect the rights and freedoms of others.
Right to object
You have the right to object to processing of your Personal Data which is based on public interest or legitimate interest processing. We will no longer process the Personal Data unless we can demonstrate a compelling ground for the processing.
Right not to be subject to automated decision-making
You have the right not to be subject to a decision based solely on automated processing. This right shall not apply where the processing is necessary for a contract with you, or the processing is undertaken with your explicit consent, or the processing is authorised by law.
You can make a complaint
You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.
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