Last Updated on February 10, 2022
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect information from you when you provide it to us directly and through your use of the Platform.
INFORMATION YOU PROVIDE TO US DIRECTLY
Personally Identifiable InformationInformation you provide to us directly includes certain data that may personally identify you (“Personally Identifiable Information”) and may include, among other things:
- Information you provide to us when you use our Platform (e.g., your username, password, name, birthdate, gender, marital status, social security numbers, other data provided on government-issued identification documents, email address, home address, IP address, employer information and employment status, phone number, financial data (including credit reports and information about your income and net worth, investment objectives, risk tolerance, investment experience, educational and/or professional history, investor questionnaire results);
- Transaction and billing information, if you make any transactions on our Platform (e.g., credit/debit card details and delivery information);
- Records of your interactions with us (e.g., if you contact our customer service team via email or phone, or interact with us on social media), as well as records of your interactions with others on our public discussions forums; and
- Information you provide us when you enter a competition or participate in a survey.
USAGE INFORMATION WE AUTOMATICALLY COLLECT
The usage information we automatically collect as you navigate through the Platform includes certain data that is about you but does not, by itself, personally identify you and may include, among other things:
- Platform pages, articles, presentation and videos viewed, usage of certain features on the Platform (including clicks on links in our email updates), data relating to server locations, cookies existing on your device used to access the Platform, search criteria used and results, date and time, IP address;
- Information about the devices, operating systems and web browsers you use to access our Platform; and
- Other information necessary to provide the Platform, for example we may access your approximate location.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Platform may use local objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings, see ‘Choices About How We Use and Disclose Your Information’.
- Web Beacons. Pages of our Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect Personally Identifiable Information automatically, but we may tie this information to Personally Identifiable Information about you that we collect from other sources or you provide to us.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
HOW WE USE YOUR INFORMATION
Depending on how you use our Platform, your interactions with us, and the permissions you give us, we use information that we collect about you or that you provide to us, including any Personally Identifiable Information:
- To present our Platform and its content to you;
- To provide you with information or services that you request from us;
- To fulfill any other purpose for which you provide it;
- To provide you with notices about your account;
- For ‘Know Your Customer’ compliance (KYC);
- For anti-money laundering background checks;
- For accreditation verification purposes and suitability requirements;
- To disburse funds;
- To manage and respond to any queries or complaints to our customer service team;
- To improve and maintain the Platform, monitor its usage, and analyze our business or operations;
- For marketing purposes, see ‘Marketing’ below;
- For market research, e.g., we may contact you for feedback;
- To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so;
- For security purposes, to investigate fraud and where necessary to protect ourselves and third parties;
- To comply with our legal and regulatory obligations or to protect against legal liability;
- In any other way we may describe when you provide the information; and
- For any other purpose with your consent.
Depending upon your marketing preferences, we may use information to send you marketing messages by email, phone, or post. Some of these messages may be tailored to you, based on your previous browsing or purchase activity, and other information we hold about you.
If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us (details below), clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with messages relating to services provided by Netshares from time to time (e.g., order and delivery confirmations, and information about your legal rights).
You may also see ads for our Platform on third-party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, enabling us to serve ads to customers who have visited our Platform). Where you see an ad on social media, this may be because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third-party websites.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates;
- To other companies as necessary to operate the Platform, e.g., escrow agents, transfer agents, and custodians;
- To businesses that you invest in through the Platform;
- To contractors, service providers, and other third parties we use to support our business, including, but not limited to, marketing providers, external IT teams, legal advisors, etc.;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Netshares Financial’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Netshares Financial about our Platform users is among the assets transferred;
- To enforce or apply our Terms of Service;
- To fulfill the purpose for which you provide it;
- To third parties engaged in fraud prevention and detection;
- To law enforcement or other governmental authorities, e.g., to report a fraud or to comply with a lawful request;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others.
- For any other purpose disclosed by us when you provide the information; and
- With your consent.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personally Identifiable Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information of Third-Party Advertising. If you do not want us to share your Personally Identifiable Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to firstname.lastname@example.org.
- Promotional Offers from the Company. If you do not wish to have your email address/contact information used by Netshares to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you can change your preferences at any time by contacting us at firstname.lastname@example.org, clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. See ‘Marketing’ above, for more details of how to opt-out of marketing.
- Target Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can send us an email stating your request to email@example.com.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Our Platform is not intended for children under the age of 18, and we do not knowingly collect Personally Identifiable Information from children under the age of 18. If we learn that we have collected Personally Identifiable Information from a Platform user under the age of 18, we will take steps to delete the Personally Identifiable Information. If you are aware that a Platform user under 18 has provided us with Personally Identifiable Information, please contact us using the details below.
THIRD-PARTY SITES INTEGRATION
This Platform ensures that data is encrypted when leaving the Platform. This process involves converting the information or data into a code to prevent unauthorized access. This Platform follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods, such as SSL, are utilized to protect customer data when in transit to and from this Platform over a secure communications channel.
Whilst we do everything within our power to ensure that the information is protected at all times from our Platform, we cannot guarantee the security and integrity of the information that has been transmitted to our Platform.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personally Identifiable Information, we cannot guarantee the security of your Personally Identifiable transmitted to our Platform. Any transmission of Personally Identifiable Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.
ACCESSING AND CORRECTING YOUR INFORMATION
You have certain rights in respect of your Personally Identifiable Information, including the right to access, portability, correct, and request the erasure of your Personally Identifiable Information.
We will comply with any requests to exercise your rights except where Nethares is required by law or regulation to keep your Personally Identifiable Information or where such request would cause the Personally identifiable Information to be incorrect. In such circumstances, Netshares Financial will advise you as to this legal or regulatory obligation. To make any requests regarding your Personally Identifiable Information, or if you have any questions or concerns regarding your Personally Identifiable Information, you should contact us using the details below.