CAP Table Sub-Processor List Policy

A Sub-Processor is a third-party data processor engaged by Global Shares, who has or potentially will have access to or process data of Global Shares Cap Table Management Platform users (which may contain personal data).

The below list identifies the Sub-Processors authorised to access user data (including personal data contained therein) in the Global Shares CAP Table Management Platform.  

Any such Sub-Processors will be permitted to process user data only to deliver the services Global Shares has retained them to provide, and they are prohibited from using user data for any other purpose. These Sub-Processors may provide services to one or more of the Global Shares products.

Global Shares undertakes to use commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed Sub-Processors that will have access to or otherwise process user data (which may contain personal data).

Updates to Sub-Processor List Procedure (“Onboarding procedure”)

At least thirty (30) days (“Notice Period”) before Global Shares engages any new Sub-Processor to carry out processing activities, Global Shares will make updates to the Sub-Processor lists via this website. These updates will be notified to the Customer via email. If no objection is received as per the process outlined below during the Notice Period, the Customer will be deemed to have authorised the new Sub-Processor.

Objecting to a new Sub-Processor

Unless otherwise provided for in your service agreement with Global Shares, you may object to a Sub-Processor by submitting your objection by email to [email protected] with subject line “Sub-Processor Objection”, along with your name, your company’s name, name of Global shares Service, name of Sub-Processor and grounds for the objection.

Infrastructure Sub-Processors – Service Data Storage and Processing

The Global Shares services relies upon certain infrastructure suppliers to support the delivery of the Global Shares CAP Table Management Platform. The following is a list of the name(s), location(s) and activities of the infrastructure Sub-Processors:

Name	Location of Data	Purpose of Sub-processing	Transfer Mechanism (if applicable)
Microsoft Azure	European Union	Cloud Storage Services	N/A

Sub-Processors who provide ancillary services to support Global Shares Services

The following Sub-Processors provide ancillary services to help support, operate and maintain the Global Shares CAP Table Management Platform. In such cases, the Sub-Processor(s) identified may process, store, or otherwise access limited customer data or personal data in the course of providing their ancillary services. The following list of name(s), location(s) and activities of the ancillary services Sub-Processors:

Name	Location of Data	Purpose of Sub-processing	Transfer Mechanism (if applicable)
Smartsheet Inc	United States	Workflow and collaboration Platform	Standard Contractual Clauses
Five 9 Inc	United States	Call Centre Management	Standard Contractual Clauses
Airbrake	United States	Error Management and Application Performance Management	Standard Contractual Clauses
Transperfect Translations Ltd	European Union	Translation Services	N/A
Tax Computer Systems Limited	European Union	Tax Management Software	N/A
Iron Mountain, Inc.	European Union	Self-hosted JIRA customer support services	European Union. If not, Standard Contractual Clauses.
DocuSign	European Union	Electronic Signatures	European Union. If not, Binding Corporate Rules
Atlassin PTY Ltd	European Union	Work management software	European Union. If not, Standard Contractual Clauses
MailGun	United States	Email Delivery Services	Standard Contractual Clauses

ID Verification-specific services Sub-Processors

Global Shares uses certain ID verification Sub-Processors to provide ID verification services in connection with Global Shares Equity Admin.

The following is a list of name(s), location(s) and activities of the ID verification-specific services:

Name	Location of Data	Purpose of Sub-processing	Transfer Mechanism (if applicable)
ID-Pal	European Union	AML Screening and ID Verification	N/A
KYC Global Technologies Limited	European Union. If not, then Jersey Island (Equivalency)	AML Screening and ID Verification	N/A
Trulioo Information Services	Canada (Equivalency)	AML Screening and ID Verification	N/A

Sub-Processors who provide contract staff

The following Sub-Processors provide contract staff that work in close coordination with Global Shares employees to help support, operate, and maintain the Global Shares Equity Admin product and in the course of doing so may be exposed to customer or participant data (including personal data contained therein).
In all such cases, customer and participant data resides only in Global Shares facilities, on Global Shares systems, and subject to Global Shares policies and supervision. For example, a Sub-Processor may perform IT troubleshooting on a Global Shares product and in the course of doing so may be exposed to snippets of customer data in the Global Shares work management portal.
The following list of name(s), location(s) and activities of the Sub-Processors who provide contract staff:

Name	Location of Data	Purpose of Sub-processing	Transfer Mechanism (if applicable)
GS Consultancy Agreement	European Union	Dev Ops / IT	N/A
Bliss Applications	European Union	Dev Ops / IT	N/A
iCommit BVBA GS Consultancy Agreement	European Union	Dev Ops / IT	N/A
KCS SIT, SA	European Union	Dev ops / IT	N/A
Yauheni Liohenki	European Union	Dev ops / IT	N/A
Aubay Portugal, SA	European Union	Dev Ops/IT	N/A
KWAN Lda	European Union	Dev Ops/IT	N/A
Sensatus Limited – GS Consultancy Agreement	European Union	Dev Ops / IT	N/A
Zartis Spain SLU	European Union	Dev Ops / IT	N/A