Greenman OPEN (“OPEN”, “us” or “we”) fully respects your right to privacy in relation to your interactions with our Website, Mobile Application, and other online products and services that link to this Statement (collectively, the “Services”).

Whenever you use our Services, information may be collected through the use of cookies and other technologies. By using our Services, you agree to our use of cookies as described in the Cookie Notice.

Collection and Use of Information.

We collect information you provide directly to us. For example, we collect information when you fill out a form, make an investment, create a Mobile App Account, participate in any interactive features of the Services, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us.

We will not collect any personal information about you via our Services without your prior consent.  We will let you know what we intend doing with your information before collecting it, so that you can decide whether or not to furnish that information to us.
If you choose to register with OPEN, we may need you to provide personal information to allow us to provide that particular service.  For example, you may need to provide the following information:

• Name;
• Email address;
• Telephone number; and
• The nature of the services required.

Any information which is provided by you will be treated respectively, securely and confidentially.
In addition to providing this information at the initial point of contact, and if you choose to correspond further with us through email or by phone, we may retain the content of your communications together with phone numbers, email addresses and our responses, as required by the Data Protection Acts.  We retain this information solely for the purpose of providing you with the relevant required services.

Once you invest or create a Mobile App Account, we might ask you to provide additional information such as a copy of an identification document (passport, residency permit, visa or national identity card), a utility bill and such other documents as may be required by us to comply with our regulatory obligations and to verify your identity.

Please note that if you choose to provide additional information about yourself to complete your “Profile“, then the information we ask for may include your gender, date of birth, place of birth, addresses, nationality, national insurance number, social security number (or other government-issued identification number), citizenship and residency status, Tax ID, and information about your experience trading, education, source of income, investment aims and appetite, occupation, employer and employment position, annual income, investment portfolio, total cash and liquid assets and other details or questions as may be required in the Profile creation and the process may be amended by us from time to time.

It is optional for you to do so but for legal and regulatory reasons you will be unable to proceed to use certain features unless you provide further information.

OPEN does not intentionally collect any sensitive information via our Services unless legally required to do so.  Sensitive personal information includes race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual life or criminal records and in some cases social security numbers or financial information.  OPEN works to protect the confidentiality and security of such information it obtains in the course of business.  Access to such information is limited and policies and procedures are in place designed to safeguard the information from loss, misuse and improper disclosure.

Your personal data will only be retained to allow us to provide you with a better service in the future.
In accordance with the GDPR, you have the right to obtain a copy of any personal data we hold on you.  If at any time after giving us personal information you decide that you no longer wish us to hold or use this information, or in the case that the information becomes out of date, you are free to notify us, and we will remove or rectify the information within a reasonable time and in accordance with legislative requirements.

You acknowledge and agree that in certain circumstances we may be obliged to disclose personal information relating to you to third parties, for example, in order to conform to any requirements of law or to comply with any legal process.

How do we use the information that you provide to us?

We will retain and process any personal data you supply to us only for the reasons listed below:

• To verify your identity and carry out checks that we are required to conduct by applicable laws and regulations, including without limitation, “know your customer” (KYC), anti-money laundering, fraud, sanctions and politically exposed person (PEP) checks;
• In relation to a service that is relevant and related to your query;
• To respond to any questions or queries that you send to us;
• To obtain feedback on your dealings with our company;
• To provide you with fund updates such as distribution notices; or
• To provide you with notices related to your investment or Mobile App Account, general updates, market updates and other marketing materials, including about the Services offered by members of the Greenman Group;
• To maintain administrative records relating to our business;
• To set up security measures to secure your account, including without limitation, to carry out two-factor authentication (“2FA”); and
• To provide the Services.

Contacting You

We may contact you for administration reasons related to the service or offer to which you have signed up to.  This includes:

• If you have requested us to via a contact form;
• By signing up to an event or competition;
• To request us to provide you with information about our services, activities or online content;
• To invite you to participate in surveys about our services (participation is always voluntary); or
• Where you have signed up for an online newsletter or ‘ezine’.

Promotional Communications

You may opt out of receiving promotional emails from OPEN by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as regulatory announcements or investment-related communications.

If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.

When a Mobile App User Invites You to Use the Application

Users of OPEN’s Mobile Application can invite their contacts to sign up for an account with us. We only collect the email addresses of individuals that users choose to invite to join the App and we only use the email addresses for sending an invitation to the individual at the request of the existing App user.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Cookies

Cookies are files which are transferred to your computer by website.  Cookies can store information about your preferences and other information which you need when you visit a website.  They are commonly used on websites.

How we use cookies

We use cookies to monitor our Website traffic, to ensure better service levels and in order to provide you with certain features such as the customised delivery of certain information.  To prevent the use of cookies you should activate the facility which is available in most web browsers that enables a user to deny or accept cookies.

Google Analytics Cookies

These are cookies that are set by this website directly. They are used to collect information about how visitors use our Website.  We use the information to compile reports and to help us improve the Website.  The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.  You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.ie/policies/privacy/ or to opt out please follow this link https://tools.google.com/dlpage/gaoptout

Server analytics

We also collect statistical and analytical information collected through the standard operation of our web servers, providing us with general and not individually specific information.  We will make no attempt to identify individual users, or to associate any technical information collected with any individual user.

Disclaimer

Greenman OPEN, its employees, servants and agents, affiliates or other representatives and their respective parent and subsidiary companies, shall not be liable in respect of any claims, emergencies, demands, causes of action, damages, losses, expenses, including without limitation, reasonable legal fees and costs of proceedings arising out of or in connection with the use and/or dissemination of personal information relating to you in accordance with this privacy policy and your consents.

Third Party Sites

You should be aware that where you link to another website from OPEN’s Website, that we have no control over that other website.  We have no responsibility for the privacy practices of other websites.

• Your rights as a Data Subject
• You may request a copy of any personal data we hold on you;
• You may request that we make changes to your data, to ensure that it is accurate and up to date;
• You may get in touch with us at any time to request removal of your data;
• You may, under certain circumstances, object or request restriction of our processing of your data; and
• You may withdraw your consent to our processing of your data at any time.

Exercising your rights, or getting in touch

To exercise your rights, or to get in touch in relation to your data, simply send an email to [email protected] or contact us at +353 1 6471121 outlining the nature of your request.  We must supply the information to you within one month of receiving the request.  However, this one month period may be extended by two further months where requests are complex or numerous.  We will notify you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Amendments to this policy

We reserve the right in its sole discretion to amend this privacy policy at any time, and you should regularly check this privacy policy for any amendments.