Last update: November, 2022
This policy (the “Privacy Notice”) applies to any person anywhere in the world who accesses and uses www.gsequity.com (this “Website” and each such person, “you” and “your”). This Privacy Notice explains how Greenstone Placement Management FZ-LLC, together with its affiliates, subsidiaries and parent entities, (collectively, “Greenstone”, “we”, “us” or “our”) collects, uses, and shares your Personal Data (as hereinafter defined, and each person in respect of whom Personal Data is collected, a “Data Subject”) that is collected or via this Website or submitted to Greenstone by you using information contained on this Website. This Privacy Notice also informs you about your rights in respect of your Personal Data and what to do if you have any questions or complaints about our use of your Personal Data. We take your privacy very seriously and are committed to abiding by the applicable data protection laws.
If you are not willing to be bound by the terms of this Privacy Notice, or if any representation made herein by you is not true, you must cease using this Website, should not submit any Personal Data to Greenstone and must contact Greenstone using the contact details herein to request the return or deletion of any of your Personal Data that Greenstone has collected.
Greenstone reserves the right to change, modify, add or remove all or part of this Privacy Notice at any time; thus, we suggest that you review this Privacy Notice periodically. The most up-to-date version of this Privacy Notice will be published on this Website.
Personal Data Collected by Greenstone
Greenstone collects information voluntarily submitted by you, either through this Website, via forms accessed from this Website or via the contact details listed on this Website. Such voluntarily submitted information may include data that can identify you, either directly (such as your name or passport details) or indirectly (through combining different sets of data, such as your data of birth, e-mail address, the name of the company that you work for, etc.) (collectively, “Personal Data”). Additionally, this Website automatically collects information from you which may also be Personal Data, such as the Internet protocol (IP) address used to connect your device to the Internet.
By accessing or using this Website, and by voluntarily sharing any Personal Data with Greenstone, you hereby represent and warrant that you understand that your Personal Data may be used by Greenstone for the purpose(s) for which it was collected and you consent to such use of your Personal Data. You have the right to withdraw such consent in respect of any or all of your Personal Data at any time for any reason or for no reason.
This Website is not targeted at, or intended to be used by, minors under 16 years of age. Greenstone does not knowingly collect or use the Personal Data of minors under 16 years of age. If you are under 16 years old, please do not provide any Personal Data, even if prompted to do so, and if you believe that you have inadvertently provided Personal Data, please ask your parent(s) or legal guardian(s) to notify us and we will delete your Personal Data.
For the purpose of applicable data protection laws, Greenstone is deemed to be a ‘Controller’ in respect of any Personal Data that you provide to us or that we otherwise obtain about you.
Mechanism and Purpose for Collecting Personal Data
The following table explains the mechanism through which Personal Data is collected by Greenstone via this Website, or using information contained on this Website, and the purpose for such collection and subsequent processing of the Personal Data. Your Personal Data is collected and processed for specific, lawful purposes only. We do not collect any Personal Data from you that we do not need.
|Mechanism for collecting Personal Data||Personal Data collected||Purpose for collection|
|Data Subject submits an enquiry about Greenstone, our services, the Data Subject’s Personal Data stored by Greenstone or the enforcement of a right related thereto||Name, contact information (generally, e-mail address and/or phone number) and any other Personal Data provided in such enquiry||Necessary to protect the interests of the Data Subject: it is necessary for us to read, store your message and be able to respond to you.|
|Data Subject submits a complaint about Greenstone||Name, contact information (generally, e-mail address and/or phone number) and any other Personal Data provided in such complaint||Necessary to protect the interests of the Data Subject and necessary to carry out the obligations, and exercise specific rights, of Greenstone: it is necessary for us to read, your complaint and be able to respond to you, as well as taking any further action required.|
|Data Subject applies for a position with Greenstone||Name, date of birth, contact information (generally, e-mail address and/or phone number), education history, employment information||Necessary to protect the interests of the Data Subject, necessary for Greenstone’s legitimate interest of operating our business efficiently, necessary for Greenstone to comply with our legal obligations: it is necessary for us to read and store your information so that we can evaluate you for the position you have applied for or any future positions that may become available.|
|Website automatically collects the Personal Data||IP address||Legitimate interest, continually improving this Website and the services that Greenstone provides: it is necessary for us to store a small amount of information about how and where this Website is accessed and how it is used to conduct data analysis and research and to monitor and analyse usage and activity trends.|
Use of Personal Data
Your Personal Data will be used within Greenstone by staff who need to know and use such Personal Data in accordance with their responsibilities for Greenstone and the purpose for which the Personal Data was collected.
Sharing Personal Data with Third Parties
Greenstone may share your Personal Data with a third-party:
- Where such third-party provides services for, or on behalf of, Greenstone, which includes IT providers, who have the capacity to access data held on our systems, and certain third party providers used for data storage services. Such third parties are only permitted to use your Personal Data for specific purposes and in accordance with Greenstone’s instructions and/or contractual obligations.
- If we are under a duty to disclose or share your Personal Data with such third-party to comply with the law, a judicial proceeding, court order or other legal obligation, or a regulatory or government inquiry.
- If we believe that disclosure to such third-party is appropriate to protect and defend Greenstone’s or the Data Subject’s rights, property or safety.
- If we notify you and you consent to the sharing of your Personal Data with such third-party.
Where your Personal Data is shared with a third-party, Greenstone shall seek to share the minimum amount necessary.
Transfer of Personal Data
The entities comprising Greenstone, and the third parties that Greenstone may transfer your Personal Data to, operate in a number of jurisdictions; accordingly, your Personal Data may be transferred to and stored outside the jurisdiction in which it was collected. This includes jurisdictions outside the European Economic Area (EEA) and jurisdictions with laws that have not necessarily been determined to provide an adequate level of protection for the processing of such Personal Data (an “Inadequate Jurisdiction”). Therefore, additional steps have been taken by Greenstone to ensure your Personal Data will be treated securely and in accordance with this Privacy Notice and applicable data protection laws when it transferred, stored or otherwise processed in an Inadequate Jurisdiction. Such additional steps include Greenstone having put appropriate safeguards in place, including enforceable Data Subject rights and effective legal remedies for the Data Subject, whether through a legally binding and enforceable agreement including standard data protection clauses or other mechanism, with the entity processing your Personal Data in an Inadequate Jurisdiction and/or obtaining your explicit consent for any such transfer of your Personal Data to an Inadequate Jurisdiction. By submitting your Personal Data to Greenstone, you acknowledge and consent to the transfer, storing or processing of your Personal Data to or in an Inadequate Jurisdiction. You have the right to withdraw such consent in respect of any or all of your Personal Data at any time for any reason or for no reason.
Storage and Security of Personal Data
The security of your Personal Data is important to Greenstone. We implement and maintain reasonable and commercially acceptable security procedures and practices appropriate to the nature of the Personal Data we store in order to protect it from unauthorized access, use, disclosure, modification or destruction. Greenstone has staff dedicated to maintaining our data protection and security policies, periodically reviewing such policies and making sure all other Greenstone staff are aware of and comply with our data protection and security policies.
Retention of Personal Data
We will only retain your Personal Data for as long as necessary to fulfil the purpose(s) we collected it for and for the purposes of satisfying any legal or similar requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purpose(s) for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. To the extent reasonably possible to do so, we will erase your Personal Data upon your request, unless we are required to retain it in accordance with applicable laws.
You have the following rights in relation to your Personal Data (which may be limited depending on certain circumstances and applicable law):
- To obtain information regarding your Personal Data held by Greenstone, including what Personal Data has been collected and processed, the purpose for the collection, the method of collection, how the collected Personal Data is stored, etc.
- To receive a copy of your Personal Data held by Greenstone.
- To request that Greenstone transfers your Personal Data to another person or entity.
- To have your Personal Data corrected if it is incomplete or incorrect.
- To restrict or object to the processing of your Personal Data or request the erasure of your Personal Data.
- To object to your Personal Data being used for automated decision-making.
- Where you have submitted your Personal Data voluntarily, or otherwise consented to its use, the right to withdraw such consent.
- The right to complain to an applicable data protection authority regarding Greenstone’s collection or use of your Personal Data.
If you would like to exercise any of these rights, please contact us using the details set out herein.
If you have any questions about this Privacy Notice or would like to exercise any rights in respect of your Personal Data collected by Greenstone, please contact Greenstone’s Data Protection Officer who will assist you: email@example.com / +9714 382 7600.
We do not envisage that any decisions will be taken about you using automated means; however, we will notify you in writing if this changes.
Use of Links
This Website may provide links to third-party websites and/or resources. If you follow any such links, you should be aware that these third-party websites have their own privacy policies and that Greenstone accepts no responsibility or liability in relation to such policies. Please review such policies before you submit any Personal Data to these third-party websites and/or resources.