September 02, 2020
Shareline publishes and operates the Platform to facilitate direct or indirect transactions in private companies (the “Transactions”). Transactions may be initiated through the Platform, or off-site by email, telephone, or other means.
Type of Personal Data
- Contact information (private or professional): full name, postal address, e-mail address, phone number
- Identification information: e.g. identity (identity card, passport information, etc.), place and date of birth, nationality, gender, photo
- Financial information with respect to your investment objectives and means, including information about your wealth and financial situation, declared investor profile including investment experience, investment activity, risk tolerance and transaction history
- Employment information: e.g. employer’s name, employment
- In connection with certain Transactions, we gather documents pertaining to your ownership if you are a shareholder, including any documents you choose to upload. The types of documents we ask for includes company-related documents that may be considered confidential. We also keep records of the Transactions and related documents. We may also have, or solicit, applicable documents from the issuer of the shares, or from third party reporting services.
- Service usage and Transactions history, as well as records of your communications with Shareline and customer service requests. When you list or indicate an interest in a Transaction, we provide information in anonymized form except as described below, unless you agree otherwise.
- Information requested or required by regulatory or governmental authorities or law enforcement bodies.
- Data from you about third parties that is not your own Personal Data, such as information about the company that issued shares you hold (if a shareholder) or about your investment entity (if an investor).
- Transaction data including full beneficiary names, address and details including communications on bank transfers of the underlying transaction
- Data about your preferences (data which relate to your use of our products and services)
- Activity and interaction on the Platform, our other apps and our social media pages, (connection and tracking data such as cookies, connection to online services, IP address, geolocation data), call, chat, email, interview, phone conversation and information about your device (IP address, technical specifications and uniquely identifying data)
- Login credentials used to connect to our Platform
- Behavioural and marketing information such as your interests, and your public social media presence.
- Accounts at other institutions such as private banks or family offices of whom you may be a client.
How and Why do we Collect Personal Data
We collect Personal Data from and about you to:
- Set up your user account, correspond with you, and otherwise enable and facilitate your usage of Shareline’s Service or as is necessary for your use of the Platform and the provision of the Service.
- Help you discover, indicate your interest, agree to, close, and otherwise participate in Transactions, as well as enter into and service the contracts that are issued as part of the Transactions.
- Assure us, and parties to the Transactions, of the valid ownership, vesting status, transferability, and other attributes of shares issued by third party private companies.
- Verify your identity, your status as a professional investor (or other qualifications), if applicable, process diligence checks, and establish your eligibility and suitability for being a member of the Shareline community.
- If you are using the Service on behalf of an entity, organization, or client, verify your affiliation and that you are authorized to do so.
- Setup and maintain accounts for sending and receiving funds and for depositing, holding and transferring securities.
- Facilitate your and our compliance with various laws, regulations, and industry oversight pertaining among other things to banking, financial information, securities transactions, money laundering, terrorism, and “know your customer” rules promulgated by, among others, applicable government and regulatory bodies.
- Create and maintain your account profile.
- Provide you with information about, and solicit your further participation in, the Service (which may include research and development purposes and direct marketing activities and/or the transfer of your Personal Data to third parties for their direct marketing purposes).
- Study, test, and improve the Service, and the overall user experience using the Service.
- Offer customer support, technical support, maintenance, and product development.
- Protect against fraud, Platform misuse, privacy and security breaches, securities and other legal and regulatory violations, and to fulfill and enforce agreements reached with you and others.
We ensure that all uses of your Personal Data have one of the foregoing legal bases: Personal Data (i) that is necessary to provide the Service, including customer support, personalised features, and safety and security protections, (ii) for which we have a legitimate interest not overridden by your data protection interest, such as research and development, marketing, and protecting our interests, (iii) to comply with our accounting, audit, legal and regulatory obligations, or (iv) where you have given prior consent to such collection and use, which you may withdraw with respect to further processing.
We collect information by asking you to enter information (including Personal Data) into forms, by observing your account activity and usage of the Service, by logging your access and activity on the Platform, by your uploading of documents, and via third party information providers that, among other things, provide background checks to verify your identity and your eligibility and suitability to participate in Transactions. Third party information providers include, among others: social media sites, our affiliated entities, fund administration partners, advertising platforms, data brokers and other data sources, and compliance service providers.
We may also collect Personal Data by direct communication with you and others by telephone, in person, and by online or electronic messaging means both on-Platform and through off-Platform services.
Who do we Share Personal Data With?
Like any company, we may share Personal Data that we have collected with our affiliates and third parties (whether located within or outside your jurisdiction) for the purposes described above. This includes:
- The other party or parties to a prospective or actual Transaction through the Service.
- Intermediate entities such as funds and “special purpose vehicles” that handle securities pools on behalf of Shareline or on their own account, as well as the organizers, managers, and fund advisers of these entities or other parties in order to complete, service and enforce the terms of a Transaction or contemplated Transaction.
- If we are under a court order, investigation, audit, reporting requirement or other legal or regulatory obligation, we may be required to disclose Personal Data as a matter of legal or regulatory process to any local or foreign regulatory, governmental, tax, law enforcement or other agencies or authorities for the purposes of complying with any law, rule, regulation or guideline.
- Any affiliate, adviser, contractor, agent or third party service provider (including but not limited to financial institutions and payment providers) who provide us with services relating to administration, telecommunications, payment, clearing, audit, accounting, risk management, credit, legal, compliance, operations, sales and brokerage, marketing, relationship management, securities management, information technology, records and data storage, performance measurement and compilation and analysis in connection with our provision of the Platform and Service and our operations.
- Our service providers who provide us with security, fraud prevention, marketing technology, information technology, site analytics, site maintenance, software development, electronic signatures, identity verification and other Platform and service features, provided that all such parties will be under confidentiality duties to protect and not share any Personal Data we give them.
- To third parties you agree or ask us to disclose Personal Data to.
- Any other person under a duty of confidentiality to Shareline or its affiliated entities that have undertaken to keep such Personal Data confidential.
Further, per the terms of the Transactions and other agreements you may enter into, Shareline may setup or contract with third parties to service, pool, and otherwise manage the securities that are the subject of the Transactions.
Under certain circumstances, you have the right to do the following:
- Request to access your Personal Data and obtain information regarding the processing of your Personal Data, subject to applicable laws and regulations, including transferring to you or to a third party you choose, a copy of any automated Personal Data you provided consent for us to use, in a structured, commonly used, machine-readable format, in accordance with applicable legal and regulatory requirements.
- Correct your Personal Data, including any incomplete or inaccurate information, subject to applicable laws and regulations.
- Erase your Personal Data in certain circumstances.
- Object to or request that we restrict our processing of your Personal Data, including deleting or removing it, even in cases where we have a good reason to use it, based on something particular to your situation, subject to our legal and regulatory obligations as described above.
- Withdraw any consent you have previously given to us with respect to the Personal Data.
- Opt out from direct marketing at any time and without charge on any marketing message sent to you, via your account settings if a Member, or by contacting us directly.
- Require us, at any time and without charge, to cease to provide your Personal Data to any other person for use by that other person for direct marketing and to notify any person to whom your Personal Data has been so provided to cease to use such Personal Data for direct marketing.
- Ascertain our policies and practices in relation to Personal Data and be informed of the kind of Personal Data held by us as well as the main purposes for which Personal Data held by us is or is to be used.
- Depending on your jurisdiction, you may have the right to lodge a complaint with applicable regulatory bodies if you think that any of your rights relating to your Personal Data has been infringed by us.
Cookies and Similar Technologies
When you access the Platform or Service, we and certain information providers may place cookies, pixel tags, web beacons, page tags, or other data-gathering and transmitting tools or files on your device. These help us recognize you as a user, customize and personalize the Service, study and improve our offerings, collect information about your device and software in order to improve Platform performance or prevent fraud. Most Internet browsers and our consent management tool are able to disable or remove these cookies, and will contain instructions on how to do so, but doing so could affect your ability to use the Platform and Service.
We may retain or delete your Personal Data according to our internal data retention policies as permitted by applicable laws and regulations, even after you no longer use the Platform and Service or terminate or deactivate your account or your relationship with Shareline, among other things for backup, archival, contract enforcement and dispute resolution, auditing, and regulatory compliance purposes. Note, also, that securities law and regulations, among other things, may require that we keep an archival / recordkeeping copy of some or all of your Personal Data, that we provide such information to regulatory authorities, and that removing, deleting, erasing, suspending processing of, or withdrawing consent with respect to your Personal Data may result in our no longer being able to provide you the Service.
Transfer of Personal Data Between Jurisdictions
Other sites and services
If you believe we have not adequately responded to any request or resolved any complaint, you may have the right to contact your local governmental or regulatory body to file a complaint.