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
Fort Privacy
European Union
Data Protection 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