PRIVACY POLICY


This Privacy Policy describes how Globacap Limited collects and processes personal information about you (as a user of our Website), how we use and protect this information, and your rights in relation to that information. Throughout this Privacy Policy we will refer to you as “you”, and we will refer to Globacap Limited as “we”, “us” or “Globacap”.


References throughout this Privacy Policy to the “Website” are references to the website that you are currently using (www.globacap.com) and any sub-domains of this site unless they contain their own privacy policy. References to the “Globacap Platform” are to the platform operated by Globacap for the tokenisation of debt and equity securities and related corporate activities and which is available through the Website.

1. Application

This Privacy Policy sets out the principles governing our use of your personal information. “Personal information” is information, or a combination of pieces of information, that could reasonably allow you to be identified. This Privacy Policy applies to you as soon as you first use the Website, and you are deemed to have agreed to be bound by it upon your first use of the Website.

2. Collecting Your Personal Data

The categories of information that we might collect directly from you are:

  • your personal details and contact details (including your name, date of birth, address and email address);
  • your banking details (including your account number and sort code);
  • your tax information (including your tax code);
  • your demographic information; and
  • your employment and educational history (including your current and past employers, school and university records).

In the case of companies seeking to raise capital through the Globacap Platform, we may seek additional information about your directors, shareholders, executive team and other key persons in connection with your business. We may supplement the personal information you provide us with personal information about you that we receive from third parties.

3. Processing Your Personal Information

The principal purposes for which we process and store your personal information are:

  • to confirm your identity to create your account and ensure that you are eligible to use the services provided on the Website;
  • to conduct required anti-money laundering checks on you in connection with certain transactions you may conduct via the Website;
  • in the case of investors looking to deploy capital, to confirm that you are eligible to make investments through the Website in accordance with relevant legislation;
  • to provide you with information about your account;
  • to monitor, improve and administer the Website and the services provided on the Website;
  • to enable us to conduct surveys and analysis, and other marketing efforts;
  • to provide you with information about our business, and on other selected products and services that we think may be of interest to you (unless you have asked us not to do so);
  • to measure, understand, or improve the effectiveness of advertising we provide to you and others;
  • to enable us to comply with our legal and regulatory obligations, including reporting to regulators and governmental authorities; and/or
  • to contact you to ensure customer satisfaction in respect of our role as a website provider and assist you in getting the best value from our service.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

  • to fulfil our contractual obligations to you, for example to provide our services on the Globacap Platform. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations;
  • to comply with our legal obligations to a third party, for example obligations we owe to taxation authorities;
  • to comply with our legal obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations; or
  • to meet our legitimate interests, for example to understand how you use our services and to facilitate the smooth functioning of the Globacap Platform. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

We may obtain your consent to collect and use certain types of information when we are required to do so by law (for example, in relation to any direct marketing activities, Cookies or when we process sensitive personal information). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy.

4. Information Security & Storage

We implement technical and organisation measures to ensure a level of security appropriate to the risk of the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of your personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your personal information for as long as we have a relationship with you. Once our relationship has come to an end, we will retain your personal information for a period of time that enables us to:

  • maintain business records for analysis and/or audit purposes;
  • comply with record retention requirements under the law;
  • defend or bring any existing or potential legal claims; and/or
  • deal with complaints regarding the services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

5. Personal Information Sharing

Any of your personal information that is collected by Globacap or its affiliates will be kept confidential by Globacap and its affiliates, and we will not disclose it to any third parties. The only exceptions to this are:

  • we may disclose certain portions of your personal information to third-party service-providers solely in the course of their provision of services to Globacap. Where this is the case, your personal information may be transferred to, stored or processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law. We will put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on any appropriate safeguards we have in place, please contact us using the details below;
  • we may disclose certain portions of your personal information if we are required to do so by law, regulation or the order of court or other legitimate government body or arbitration panel. This includes, among other things, any personal information that may be requested by HM Revenue & Customs and the Financial Conduct Authority; and/or
  • in the event that we intend to enter into a major corporate transaction, such as a sale of control of our or another business on a stock exchange, we may disclose certain portions of your personal information to potential buyers, underwriters or advisors. If we do this, we will take reasonable precautions to ensure that the recipients of your personal information are obligated to keep it confidential.

6. Changes On Business Ownership And Control

We may, from time to time, expand, reduce or sell our business, and this may involve the transfer of certain divisions or the whole business to other parties. Your personal information will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use your personal information for the purposes for which it was supplied by you.

7. Use of Cookies

“Cookies” are small files that reside on your computer’s hard drive, generally contain an anonymous unique identifier and are accessible only by the website that placed them there and not any other sites.

Globacap may set and access Cookies on your computer. In addition, we may gather certain information about you, including details of your operating system, browser version, domain name and IP address, and the details of any website you linked from to the Website. We do this in order to enable us to provide the services available on the Website and to monitor and improve the Website.

To the extent that we have third-party advertisements on the Website, those third parties may also place, set and access Cookies on your computer. They do this to track how many unique users have seen a particular ad and to provide advertisements that are more relevant to a given user’s interests. We do not have access to these cookies, and other than allowing them to be served, we play no role in these Cookies at all.

You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies; however, this can be altered. In addition, you may delete Cookies that have already been placed on your hard drive. For further details, please consult the help menu in your browser. Disabling or deleting Cookies may prevent you from using the full range of services available on the Website.

8. Communications Between You And Globacap

We may intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and us. We may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities.

In the case of communications by email you should note that, as emails are not encrypted (and may, therefore, be intercepted by third parties) and as the identity of the sender cannot be confirmed, you must NOT provide your security details by email and should avoid providing any personal information to us by email.

9. Your Rights Over Your Personal Information

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

  • access your personal information;
  • rectify the information we hold about you;
  • erase your personal information;
  • restrict our use of your personal information;
  • object to our use of your personal information;
  • receive your personal information in a usable electronic format and transmit it to a third party (the right to data portability);
  • lodge a complaint with your local data protection authority.

If you would like to exercise such rights, please contact us using the details below. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. We will contact you if we need additional information from you in order to honour your requests.

10. No Waiver

In the event that either you or we fail to exercise any right or remedy contained in this Privacy Policy, that does not mean you or we (as applicable) have waived that right or remedy and so shall not be construed as a waiver.

11. Revisions

We may modify or update this Privacy Policy from time to time. If we change this Privacy Policy, we will notify you of the changes. Where changes to this Privacy Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).

12. Contact Us

Globacap is the controller responsible for the personal information we collect and process.

If you have questions or concerns regarding the way in which your personal information has been used, please contact our Data Protection Officer using the following contact details:

The Globacap Limited Data Protection Officer
Globacap Limited
5 Cheapside
London, EC2V 6AA
United Kingdom

We are committed to working with you to obtain a fair resolution to any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office using its website: https://ico.org.uk/make-a-complaint/