Privacy Notice

Last update:  August, 2024

1. About

This notice (the “Privacy Notice”) applies to any information or data that Greenstone Placement Management FZ-LLC or its affiliates (collectively, “Greenstone”, “we”, “us” or “our”) collects or receives about its clients, investors and other third parties in connection with its business dealings, when such parties accessing our website www.greenstone.agency (the “Website”), or when such parties otherwise engage with us that, either alone or in conjunction with other information or data, identifies a natural person (collectively, the “Personal Data“; provided, that, such term does not include anonymized information or information and data that is not subject to a data protection law, rule or regulation).  Each person in respect of whom we process Personal Data is referred to as “you” or “your”.

We take your privacy very seriously and are committed to ensuring that the Personal Data that we collect is safe and secure.  This Privacy Notice informs you about how and why we process your Personal Data, your rights with respect to your Personal Data, and what to do if you have any questions or complaints about our use of your Personal Data.

This Privacy Notice applies to Personal Data that we process as a “Data Controller” during the course of conducting our business, which is where we determine the purpose and means of processing such personal information.  If a Greenstone entity has contractually agreed to act as a “Data Processor” on behalf of a Data Controller, such entity’s processing of any Personal Data under such arrangement will be governed by its contractual agreement with the Data Controller.

2. How We Collect Your Personal Data

(a) Personal Data that you provide to us.

We process Personal Data that we receive from you in the course of our business relationship with you.  Depending on the nature of the business relationship, we will collect some or all of the following types of Personal Data from you:

• contact information, which may include your name, e-mail address, telephone number, and postal address;
• verification data, which may include your date of birth, passport number, national ID number, tax identification number, information contained in a utility bill, lease, electoral register extract or other identifying document, signature, and other information required for verification purposes pursuant to our policies and/or applicable laws, rules and regulations;
• financial information, which may include your bank account details, tax identification number, sources of wealth, and investment preferences;
• professional information, which may include your occupation, job title, employment history, the name and address of the entity you own, work for or represent, and details of your shareholding;
• family information, with respect to whether a family member is a government or political official, or as otherwise required for visa, insurance or other purposes;
• transaction information, which may include information and data you provide in connection with investments;
• audio and visual recordings of calls you have with us;
• marketing data, which may include your subscriptions and your marketing preferences;
• such other Personal Data as you may provide to us when you contact us via the Website, our social media platform, a contact form, or email, and through any associated documentation that you complete or submit when contacting us; and
• such other Personal Data as we may be required to collect from you, which shall at all times be used in accordance with this Privacy Notice or as specified at the time of such collection.

(b) Personal Data that we automatically collect.

When you use or access the Website, we automatically collect the Personal Data that your browser transmits to our server, which is technically necessary for you to access the Billions Platform and for us to ensure its continued stability and security, or for us to improve the Billions Platform and your use of it.

We will generally automatically collect:

• access data, which includes information about your device and internet connection, including the device’s unique identifier (IP address), the location inferred from your IP address, the date and time of your access, and the referrer URL (previously visited page);
• traffic data, which includes usage logs and the resources that you access and use on or through the Website;
• diagnostic data related to your use of the Website, such as crash data and logs, performance data, and any other data collected for the purposes of measuring technical diagnostics; and
• such other Personal Data as may be automatically collected in the ordinary course of you accessing and using the Website.

Certain of such automatic collection of your Personal Data is obtained using “cookies”, which are small files that are sent to us and are stored in the hard drive of the device that you are using.  These cookies help us improve the Website and your use of it.  If you wish to remove cookies, you can deactivate cookies within your browser’s parameters; however, such deactivation may mean that certain parts of the Website are inaccessible to you or do not function properly.  Unless you deactivate cookies, the Website will send and receive cookies by default.

(c) Personal Data that we obtain from third parties.

We use third parties, which include publicly available databases, sanctions lists, third-party reference providers, social network providers, and our service providers and business partners, to obtain your Personal Data, which is generally obtained in order to complete know-your-customer and other verification procedures in accordance with our policies and applicable laws, rules and regulations.  In addition, due to the nature of our business, finance professionals and/or financial institutions may provide Personal Data to us in respect of their clients, investors or persons for whom they act as an agent, which may include your Personal Data, if applicable.

In addition, we may collect your Personal Data in respect of your use of the Website, in order to improve the Website and your use of it, from third-party services, such as Google Analytics, that collect, monitor and analyse information about demographics, such as gender, country of provenance and age, and navigational behaviour, such as pages viewed during a session, time spent on a given page and engagement with content, such as clicks and form submissions.

3. Purpose of, and Legal Basis for, Processing Your Personal Data

We process your Personal Data where there is a purpose and, in accordance with applicable data protection legislation, a legal basis for doing so.

Generally, we use the Personal Data we collect about you for the purposes of:

• operating, maintaining and improving the Website and your use of it, which includes, but is not limited to, ensuring the continuing stability and security for all users, analysing its usage, and understanding its users;
• conducting our business operations, which includes, but is not limited to, sourcing and maintaining relationships with clients and investors, providing our corporate services, managing administrative and operational matters, recruiting and hiring employees, establishing and maintaining relationships with service providers, contractors and vendors, managing risk, and auditing;
• complying with applicable laws and regulations of our regulators or otherwise pertaining to our corporate services and business operations, which includes, but is not limited to, preventing and detecting money laundering and the financing of terrorism, conducting know-your-customer processes and procedures in accordance with applicable securities laws, including screening against sanctions lists, conducting FATCA/CRS reporting or equivalent requirements, verifying your identity, and responding to requests from our regulators or other supervisory authorities;
• performing our obligations under a contract, which includes, but is not limited to, providing services to you, and making payments to you or receiving payments from you;
• marketing, providing information in respect of, and promoting Greenstone and our corporate services, which may include, but is not limited to, sending you information about transactions that we believe may be of interest to you; provided, that, we ensure at all times that any marketing or offering of a transaction is conducted in compliance with applicable laws, rules and regulations;
• communicating with you and providing ongoing customer service, which includes, but is not limited to, responding to your inquiries, comments and requests;
• asserting legal claims and conducting our defence in the event of a legal dispute; and
• for other purposes when we have obtained your consent.

We rely on one or more of the following processing conditions with respect to our processing of your Personal Data:

• we have received your specific consent for the processing of your Personal Data;
• we need to process your Personal Data in order to perform our obligations to you under a contract;
• we need to process your Personal Data in order to comply with applicable laws, rules or regulations; or
• our processing of your Personal Data is necessary for the legitimate interests pursued by us or a third party, and we have determined that such legitimate interests are warranted and do not prejudice your rights and freedoms or your own legitimate interests.

Notwithstanding the foregoing, where we process your Personal Data solely based on the consent that we have obtained from you to do so, you may withdraw your consent at any time, for any reason or for no reason, by contacting us using the contact details listed herein.  Any such withdrawal of your consent is effective from the date on which we receive the withdrawal request and does not affect or apply to any processing of your Personal Data that occurred prior to such withdrawal of consent.

4. Sharing Your Personal Data

We may share your Personal Data:

• with our affiliates in order to support and enhance our business operations and perform our corporate services;
• with our third-party service providers, including those used to process payments and provide bookkeeping services, or track and respond to questions, requests, and other communications, as well as our IT service providers, our data hosting providers, and our background, reference, and credit check providers. When we use third-party service providers, we ensure that we take appropriate precautions, which may include entering into contractual agreements, to ensure that such providers have the appropriate technical, security and organizational measures to protect your Personal Data in accordance with applicable laws;
• to our business partners, including the fund managers, investment advisors and general partners of relevant funds, as well as their other service providers and representatives, our shariah-compliance service providers, and our professional partners, such as law firms, auditors, liquidators, finance professionals, private banks, and family offices;
• if we are under a duty to disclose or share your Personal Data in order to comply with applicable laws, rules or regulations, judicial proceedings, court orders or other legal obligations, or in response to a regulatory, tax or government request, inquiry or order, or as part of an audit;
• if we believe that disclosure to a third party is appropriate to protect and defend our legal, regulatory, or business interests or to protect your or another person’s rights, property or safety; or
• if you consent or direct us to share or disclose your Personal Data with a third party, which we shall do so in accordance with your directions.

When we share your Personal Data with a third party, we seek to share the minimum amount necessary.

5. Transferring Your 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 that may have different data protection laws than those of your country of residence.  If such jurisdictions do not offer a level of protection that is on a broad level the same as the jurisdiction in which your Personal Data was collected, we ensure that adequate safeguards are in place to protect your Personal Data. These safeguards include putting steps in place, which may include contractual obligations, to ensure that all such transferees keep your Personal Data confidential and secure and only use your Personal Data for the purposes that we have specified.

6. Ensuring The Safety And Security Of Your Personal Data

Ensuring the safety and security of your Personal Data is very important to us.  We implement and maintain appropriate technical, security and organizational measures and procedures designed to safeguard and secure your Personal Data and protect it from unauthorized access, use, disclosure, modification or destruction.

 7. Retention Of Your Personal Data

As far as necessary, we process and store your Personal Data for the duration of our business relationship with you; however, we are subject to various storage and documentation legal and regulatory obligations that generally extend beyond the end of your business relationship with us and may use other factors to determine an appropriate retention period for the storage of your Personal Data beyond the end of your business relationship.

We also assess retention periods according to applicable statutory limitation periods for any disputes or liabilities that may arise as a consequence of our processing of your Personal Data.  This will also apply if you exercise your rights as a data subject; once potential actions are time-barred, we will proceed to delete the Personal Data.

 8. Using Your Personal Data For Marketing Purposes

We may use your Personal Data for marketing purposes, including sending you promotional and informative communications about our services, new products, features or opportunities.  Such communications may contain tracking technologies in order to build profiles and track subscriber activity relating to engagement, demographics and other data.

We may use your Personal Data for the purpose of marketing, providing information in respect of, transactions or opportunities that we believe may be of interest to you; provided, that, we ensure at all times that any marketing or offering of any transaction or opportunity is conducted in compliance with applicable laws, rules and regulations.

If you wish to stop receiving these communications, please follow the opt-out instructions by clicking “unsubscribe” (or similar opt-out language) in these communications.  Alternatively, you may opt out of the use of your Personal Data for these purposes by contacting us at dataprotection@gsequity.com.

9. Your Rights In Respect Of Your Personal Data

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;
• to receive a copy of your Personal Data held by Greenstone;
• to request that we transfer 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, to withdraw such consent; and
• to lodge a complaint with an applicable data protection authority regarding our collection or use of your Personal Data.

If you would like to exercise any of these rights, please contact us using the contact details set out below.

We will need to verify your identity before processing your request, for which we will generally be required to match sufficient information you provide to us with the information we maintain about you.  Although we try to limit the Personal Data collected in connection with such requests, certain requests may require us to obtain additional Personal Data from you.  In certain circumstances, we may decline a request if we are unable to verify your identity, unable to locate your Personal Data in our systems, or as permitted by law.

10. How To Contact Us

If you have any questions regarding this Privacy Notice or would like to exercise any rights in respect of your Personal Data, please contact us at dataprotection@gsequity.com.

11. Personal Data Of Minors

We do not knowingly collect or process the Personal Data of minors under the age of 18 without the consent of the relevant parent or guardian.  If we become aware that we have inadvertently collected the Personal Data of a minor under the age of 18 without the consent of the relevant parent or guardian, we will take reasonable steps to delete such Personal Data as soon as possible.

12. No Automated Processing

We do not engage in any activity that subjects you to a decision based solely on automated processing, including profiling, that would produce legal effects, or similarly significant results, impacting you.

13. Social Media And Other Third-Party Websites

In conducting our business, we may use various social media platforms. If you contact us on a social media platform using a direct message tool therein, we may respond to you in the same manner.  Any use of a social media platform is subject to the policies and terms of the relevant social media platform, which we have no control over.  Accordingly, we have no control over how any such social media platform uses any Personal Data that you may submit to it.  Certain social media platforms may also automatically provide us with your Personal Data, and the information we receive will depend on the terms that govern your use of the social media platform and any applicable privacy settings.

Additionally, the Website contains links to other websites provided by third parties that are not under our control. When following any such link and providing information to a third-party website, please be aware that we are not responsible for and have no control over any Personal Data that you may provide to such third party.

14. Recordings

We hereby notify you that we may record and/or transcribe all telephone and video calls (including those conducted using Microsoft Teams or equivalent providers) that we or our employees, agents or representatives conduct with you if required to do so in accordance with applicable laws, rules or regulations.  You hereby consent to the recording and/or transcription of any such telephone and video conversations and agree that any such recordings may be submitted in evidence in relation to any claims, proceedings or requests from regulators or other supervisory authorities.

15. Changes To This Privacy Notice

Any Personal Data that we collect is subject to the Privacy Notice in effect at the time such Personal Data is collected.  We may, however, revise this Privacy Notice from time to time to reflect changes in the law, our data collection and use practices, or advances in technology.  The current version of this Privacy Notice will always be posted to our Privacy Notice page, which you should review periodically.uture success and growth.