Privacy Policy

Last Updated on March 4, 2021

Welcome to Netshares Financial Services, LLC (“Netshares”, “us,” “our,” “we”), a broker-dealer registered with the U.S. Securities and Exchange Commission (the “SEC”) and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investors Protection Corporation (“SIPC”). This privacy policy (the “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit our website at https://netshares.com/ and other online services (the “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. If you have any questions that this Privacy Policy does not address, please contact us at (800) 216-0360 or 3200 Wilcrest Drive, Suite 275, Houston, Texas 77042.

At Netshares, we respect the privacy of our Platform visitors (“you,” “your,” “User”) and are committed to protecting it through our compliance with this Privacy Policy (the “Privacy Policy”). This Privacy Policy is part of our Terms of Service, and all the terms and conditions set forth in the Terms of Service also apply to this Privacy Policy. Please carefully review this Privacy Policy to learn about how we use your information. By using the Platform in any way you agree to this Privacy Policy. We may also ask you to indicate your consent more formally by checking a box or by taking an affirmative action within the Platform. If you have any questions or concerns regarding this Privacy Policy, you should contact us using the details below.

IF YOU DO NOT UNDERSTAND OR DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT USE THE PLATFORM.     

What personal data do we collect about you?

We collect information from you when you provide it to us directly and through your use of the Platform.

INFORMATION YOU PROVIDE TO US DIRECTLY

Personally Identifiable Information

Information you provide to us directly includes certain data that may personally identify you (“Personally Identifiable Information”) and may include, among other things:

  • Information you provide to us when you use our Platform (e.g., your username, password, name, birthdate, gender, marital status, social security numbers, other data provided on government-issued identification documents, email address, home address, IP address, employer information and employment status, phone number, financial data (including credit reports and information about your income and net worth, investment objectives, risk tolerance, investment experience, educational and/or professional history, investor questionnaire results);
  • Transaction and billing information, if you make any transactions on our Platform (e.g., credit/debit card details and delivery information);
  • Records of your interactions with us (e.g., if you contact our customer service team via email or phone, or interact with us on social media), as well as records of your interactions with others on our public discussions forums; and
  • Information you provide us when you enter a competition or participate in a survey.

USAGE INFORMATION WE AUTOMATICALLY COLLECT

The usage information we automatically collect as you navigate through the Platform includes certain data that is about you but does not, by itself, personally identify you and may include, among other things:

  • Platform pages, articles, presentation and videos viewed, usage of certain features on the Platform (including clicks on links in our email updates), data relating to server locations, cookies existing on your device used to access the Platform, search criteria used and results, date and time, IP address;
  • Information about the devices, operating systems and web browsers you use to access our Platform; and
  • Other information necessary to provide the Platform, for example we may access your approximate location.

The   technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
  • Flash Cookies. Certain features of our Platform may use local objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings, see ‘Choices About How We Use and Disclose Your Information’.
  • Web Beacons. Pages of our Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect Personally Identifiable Information automatically, but we may tie this information to Personally Identifiable Information about you that we collect from other sources or you provide to us.

HOW WE USE YOUR INFORMATION

Depending on how you use our Platform, your interactions with us, and the permissions you give us, we use information that we collect about you or that you provide to us, including any Personally Identifiable Information:

  • To present our Platform and its content to you;
  • To provide you with information or services that you request from us;
  • To fulfill any other purpose for which you provide it;
  • To provide you with notices about your account;
  • For ‘Know Your Customer’ compliance (KYC);
  • For anti-money laundering background checks;
  • For accreditation verification purposes and suitability requirements;
  • To disburse funds;
  • To manage and respond to any queries or complaints to our customer service team;
  • To improve and maintain the Platform, monitor its usage, and analyze our business or operations;
  • For marketing purposes, see ‘Marketing’ below;
  • For market research, e.g., we may contact you for feedback;
  • To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so;
  • For security purposes, to investigate fraud and where necessary to protect ourselves and third parties;
  • To comply with our legal and regulatory obligations or to protect against legal liability;
  • In any other way we may describe when you provide the information; and
  • For any other purpose with your consent.

MARKETING

Depending upon your marketing preferences, we may use information to send you marketing messages by email, phone, or post. Some of these messages may be tailored to you, based on your previous browsing or purchase activity, and other information we hold about you.

If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us (details below), clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with messages relating to services provided by Netshares from time to time (e.g., order and delivery confirmations, and information about your legal rights).

You may also see ads for our Platform on third-party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, enabling us to serve ads to customers who have visited our Platform). Where you see an ad on social media, this may be because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third-party websites.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personally Identifiable Information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates;
  • To other companies as necessary to operate the Platform, e.g., escrow agents, transfer agents, and custodians;
  • To businesses that you invest in through the Platform;
  • To contractors, service providers, and other third parties we use to support our business, including, but not limited to, marketing providers, external IT teams, legal advisors, etc.;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Netshares’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Netshares about our Platform users is among the assets transferred;
  • To enforce or apply our Terms of Service;
  • To fulfill the purpose for which you provide it;
  • To third parties engaged in fraud prevention and detection;
  • To law enforcement or other governmental authorities, e.g., to report a fraud or to comply with a lawful request;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others.
  • For any other purpose disclosed by us when you provide the information; and
  • With your consent.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the Personally Identifiable Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our website may then be inaccessible or not function properly.
  • Disclosure of Your Information of Third-Party Advertising. If you do not want us to share your Personally Identifiable Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to info@netshares.com.
  • Promotional Offers from the Company. If you do not wish to have your email address/contact information used by Netshares to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to info@netshares.com. If we have sent you a promotional email, you can change your preferences at any time by contacting us at info@netshares.com, clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. See ‘Marketing’ above, for more details of how to opt-out of marketing.
  • Target Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can send us an email stating your request to info@netshares.com

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

STORAGE AND RETENTION

We will keep information for as long as we need it for the purposes set out above. As such, this period will vary depending on your interactions with us. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax, and warranty purposes. We may also keep a record of correspondence with you for as long as is necessary to protect us from a legal claim. When we no longer have a need to keep your information, we will delete it. Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

CHILDREN POLICY

Our Platform is not intended for children under the age of 18, and we do not knowingly collect Personally Identifiable Information from children under the age of 18. If we learn that we have collected Personally Identifiable Information from a Platform user under the age of 18, we will take steps to delete the Personally Identifiable Information. If you are aware that a Platform user under 18 has provided us with Personally Identifiable Information, please contact us using the details below.

DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF FACEBOOK

On this Platform, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Platform, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/.  During the course of this technical procedure, Facebook is made aware of what specific sub-site of our Platform was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our Platform by the data subject—and for the entire duration of their stay on our Platform—which specific sub-site of our Platform was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our Platform, e.g., the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our Platform by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our Platform. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our Platform is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g., the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by the data subject to eliminate a data transmission to Facebook.

DATA PROTECTION PROVISIONS FACEBOOK (VISITOR ACTION PIXEL)

We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our Platform. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads. Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF GOOGLE ANALYTICS (WITH ANONYMISATION FUNCTION)

On this Platform, the controller has integrated the component of Google Analytics (with the anonymiser function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our Platform from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our Platform. Google uses the collected data and information, among other things, to evaluate the use of our Platform and to provide online reports, which show the activities on our Platform, and to provide other services concerning the use of our Platform for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our Platform. With each call-up to one of the individual pages of this Platform, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Platform by the data subject. With each visit to our Platform, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our Platform at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this Platform, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript that any data and information about the visits of Platform may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF MAILCHIMP.

On this Platform, the controller has integrated MailChimp. MailChimp is an online service provider which allows the advertising growth of business. The purpose of MailChimp’s integration is to promote the services of the website to existing users as well as to potential new users. MailChimp’s data privacy policy is further explained under the following links:

Privacy Policy

Data Processing Addendum

PAYMENT METHOD: DATA PROTECTION PROVISIONS ABOUT THE USE OF PAYPAL AND STRIPE AS A PAYMENT PROCESSOR

On this Platform, the controller has integrated components of PayPal and Stripe. PayPal and Stripe are online payment service providers. Payments are processed via so-called PayPal and Stripe accounts, which represent virtual private or business accounts. PayPal and Stripe are also able to process virtual payments through credit cards when a user does not have a PayPal or Stripe account. A PayPal or Stripe account is managed via an e-mail address, which is why there are no classic account numbers. PayPal and Stripe make it possible to trigger online payments to third parties or to receive payments. PayPal and Stripe also accept trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

Stripe’s services in Europe are provided by a Stripe affiliate—Stripe Payments Europe Limited (“Stripe Payments Europe”)—an entity located in Ireland. In providing Stripe Services, Stripe Payments Europe transfers personal data to Stripe, Inc.

If the data subject chooses “PayPal” or “Stripe” as the payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to PayPal or Stripe accordingly. By selecting these payment options, the data subject agrees to the transfer of personal data required for payment processing.

The personal data transmitted to PayPal or Stripe is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.

The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal or Stripe, in particular, if a legitimate interest in the transmission is given. The personal data exchanged between PayPal or Stripe and the controller for the processing of the data will be transmitted by PayPal or Stripe to economic credit agencies. This transmission is intended for identity and creditworthiness checks.

PayPal or Stripe will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfil contractual obligations or for data to be processed in the order.

The data subject has the possibility to revoke consent for the handling of personal data at any time from PayPal or Stripe. A revocation shall not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.

The applicable data protection provisions of PayPal and Stripe may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full. And, https://stripe.com/en-in/privacy respectively.

SECURITY

This Platform ensures that data is encrypted when leaving the Platform. This process involves converting the information or data into a code to prevent unauthorized access. This Platform follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods, such as SSL, are utilized to protect customer data when in transit to and from this Platform over a secure communications channel.

Whilst we do everything within our power to ensure that the information is protected at all times from our Platform, we cannot guarantee the security and integrity of the information that has been transmitted to our Platform.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personally Identifiable Information, we cannot guarantee the security of your Personally Identifiable transmitted to our Platform. Any transmission of Personally Identifiable Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

ACCESSING AND CORRECTING YOUR INFORMATION

You have certain rights in respect of your Personally Identifiable Information, including the right to access, portability, correct, and request the erasure of your Personally Identifiable Information.

We will comply with any requests to exercise your rights except where Netshares is required by law or regulation to keep your Personally Identifiable Information or where such request would cause the Personally identifiable Information to be incorrect. In such circumstances, Netshares will advise you as to this legal or regulatory obligation. To make any requests regarding your Personally Identifiable Information, or if you have any questions or concerns regarding your Personally Identifiable Information, you should contact us using the details below.

CHANGES TO PRIVACY POLICY

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the effective date at the top of this Privacy Policy. Your continued use of the Platform following the posting of any changes to this Privacy Policy means you consent to such changes.

CONTACT US

If you have any queries on any aspect of our Privacy Policy, please contact us at info@netshares.com or 3200 Wilcrest Drive, Suite 275, Houston, Texas 77042.