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Last update:  April 28, 2021

This policy (the “Privacy Policy”) 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 Policy 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 Information (as hereinafter defined).  This Privacy Policy also informs you about your rights in respect of your Personal Information and what to do if you have any questions or complaints about our use of your Personal Information.  We take your privacy very seriously and are committed to abiding by the applicable data protection laws.

By accessing and using this Website, or by submitting any information to Greenstone either via this Website or using information contained on this Website, you acknowledge that you have read, understood and agreed to this Privacy Policy.   If you are not willing to be bound by the terms of this Privacy Policy, or if any representation made herein by you is not true, you may not use, and must cease using, this Website and must contact Greenstone directly to request the return or deletion (subject to the terms of this Privacy Policy) of any Personal Information.

Greenstone reserves the right to change, modify, add or remove all or part of this Privacy Policy at any time; thus, we suggest that you review this Privacy Policy periodically.  The most up-to-date version of this Privacy Policy will be published on this Website.

Personal Information Collected by Greenstone

Greenstone collects any 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 collected information includes personal identification information, including, but not limited to: your name, address, telephone number, e-mail address, the name of the company (if any) that you work for, own, partially own or represent, your resume and other information regarding your employment history preferences (collectively, the “Personal Information”).

This Website automatically collects information from you which may also be ‘Personal Information’.  Such information includes:

  1. Technical information, for example, the type of device (and its unique device identifier) you use to access this Website, the Internet protocol (IP) address used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform, and similar data; and
  2. Information about your visit to this Website site, including Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

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 Information of minors under 16 years of age. If you are under 16 years old, please do not provide any Personal Information, even if prompted to do so, and if you believe that you have inadvertently provided Personal Information, please ask your parent(s) or legal guardian(s) to notify us and we will delete your Personal Information.

Purpose and Basis for Collecting Personal Information

The following table explains the purpose for which Personal Information is collected and the basis on which Personal Information is processed.  Your Personal Information is collected and processed for specific, lawful purposes only.

PurposePersonal Information (key elements)Basis
Enquiring about Greenstone and our servicesPersonal identification information; messageLegitimate interests and consent: it is necessary for us to read and store your message so that we can respond in the way that you would expect.
Submitting a complaint about GreenstonePersonal identification information; complaintLegitimate interests and consent: it is necessary for us to read and store your complaint so that we can respond in the way that you would expect and take any further action required.
Applying for a position with GreenstonePersonal identification information; employment information Legitimate interests and consent: it is necessary for us to read and store your information so we can evaluate you for the position you have applied for.
Automatically collected information about Website useWebsite activity collected through cookiesLegitimate interests: 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 Information

The entities comprising Greenstone are the ‘joint controllers’ of Personal Information that we collect from you, which means that such entities decide how to use such Personal Information and are responsible for looking after such Personal Information in accordance with GDPR and similar applicable data protection laws.  Your Personal Information will be used within Greenstone by staff who need to know and use such Personal Information in accordance with their responsibilities for Greenstone.  By accessing or using this Website, and by voluntarily sharing any Personal Information with Greenstone, you hereby represent and warrant that you understand that your Personal Information may be used by Greenstone in accordance with applicable laws and its policies and you consent to such use of your Personal Information.

Sharing Personal Information with Third Parties

Greenstone may share your Personal Information with a third-party:

  1. Where such third-party provides services for, or on behalf of, Greenstone. Such third parties are only permitted to use your Personal Information for specific purposes and in accordance with Greenstone’s instructions.
  2. If we are under a duty to disclose or share your Personal Information with such third-party to comply with the law, a judicial proceeding, court order or other legal obligation, or a regulatory or government inquiry.
  3. If we believe that disclosure to such third-party is appropriate to protect and defend Greenstone’s rights, property or safety.
  4. If we notify you and you consent to the sharing of your Personal Information with such third-party.

Where your Personal Information is shared with a third-party, Greenstone shall seek to share the minimum amount necessary.

Transfer of Personal Information

The entities comprising Greenstone operate in a number of countries; accordingly, your Personal Information shall be transferred to and stored outside the country in which you are located.  This includes countries outside the European Economic Area (EEA) and countries with laws that have not necessarily been determined to provide an adequate level of protection for the processing of such Personal Information under the laws of other jurisdictions.

Security of Personal Information

The security of your Personal Information is important to Greenstone, and we strive to implement and maintain reasonable and commercially acceptable security procedures and practices appropriate to the nature of the Personal Information 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.  However, you should be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure and we are unable to guarantee the absolute security of the Personal Information that we have collected from you.

Retention of Personal Information

We will only retain your Personal Information for as long as necessary to fulfil the purpose(s) we collected it for and for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purpose(s) for which we process your Personal Information 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 Information upon your request, unless we are required to retain it in accordance with applicable laws.

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 Information to these third-party websites and/or resources.

Cookies

A cookie is a text file unique to the web browser on the device you use to access this Website, which is used for various purposes, including making this Website better for you, collecting information about your visit to this Website, the content you viewed, the links you followed and information about your browser, device and IP address.  Greenstone does not use cookies to ‘see’ other data and information on your device or to obtain your contact information.

Your Rights

You have the following rights in relation to your Personal Information:

  1. To access your Personal Information held by Greenstone.
  2. To have your Personal Information corrected if it is incomplete or incorrect.
  3. To restrict or object to the processing of your Personal Information or request the erasure of your Personal Information (in certain circumstances and subject to applicable law).
  4. To receive a copy of the Personal Information you have provided to Greenstone (in certain circumstances and subject to applicable law).
  5. Where you have submitted your Personal Information voluntarily, or otherwise consented to its use, the right to withdraw such consent.
  6. The right to complain to an applicable data protection authority regarding Greenstone’s collection or use of your Personal Information.

If you would like to exercise any of these rights, please contact us.

Contact Us

If you have any questions about, or would like to exercise any rights under, this Privacy Policy, please contact us: lc@gsequity.com.

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