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Privacy policy

This Privacy Policy was last updated on October 15, 2017.

Global Fund Exchange Holdings LLC and its subsidiaries and affiliates (collectively, “Global Fund Exchange”, “us” or “we”) understands that your privacy is important to you. We may process your personal data in our capacity as data controllers. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person, collected via all websites or apps that post a link to this Privacy Policy (collectively, “the Sites”). This Privacy Policy describes how we handle and protect your personal data in connection with the Site. Please see our terms of use for more information about our online terms and policies in general.

Information we collect

Global Fund Exchange collects personal data on certain areas of the Sites when you register for or apply for jobs through the Global Fund Exchange Recruitment, register for Global Fund Exchange newsletters and alerts, sign up for conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected may consist of information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and background information required to apply for a job.

By registering for Global Fund Exchange newsletters or alerts, you agree to receive the correspondence to which you have subscribed at the e-mail address that you provided at registration. Only Global Fund Exchange or its agents will contact you using this e-mail address. We will send e-mails to this address related to your registration.

We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal data you have provided.

Use of information

The personal data we collect may be used where Global Fund Exchange has a legitimate interest in or other legal basis for processing such information.  In some situations, the collection of personal data may be required for the operation of the Sites or to provide certain services or products. Global Fund Exchange uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, personalize content that you view or receive on the Sites, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyze the Sites’ performance and functioning, publish your letters to the editor or comments, prevent fraud, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Global Fund Exchange’s agreements, and accomplish other purposes you may initiate or request. We may keep any of your personal data on file and use it to contact you.

Global Fund Exchange may use first and third party cookies to manage our Sites and our services and collect analytics about how you use them. Please refer to our Cookie Policy for more details regarding our use of cookies.

Our Sites do not collect personal data about your online activities over time and across third party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.

Use of information collected via mobile devices

In connection with our mobile applications, Global Fund Exchange may use third party service providers to analyze non-personally identifiable user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, Global Fund Exchange receives reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. Global Fund Exchange also receives reports on certain errors occurring within mobile applications. None of these third party service providers gathers information in a manner intended to identify any particular user personally.

Data recipients and international data transfers

Personal data collected on the Sites may be transferred from time to time to Global Fund Exchange subsidiaries and affiliates and their personnel across our global organization, as well as to third party service providers located throughout the world. Additionally, the Sites may be viewed and hosted by Global Fund Exchange and its third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Global Fund Exchange subsidiaries, affiliates, and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

Global Fund Exchange shall not intentionally disclose or transfer (and shall take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent, whether for such third parties’ own marketing purposes or otherwise, except as follows. Global Fund Exchange may provide access to your personal data to third party service providers engaged by Global Fund Exchange to provide services related to the Sites; provided that such third party service providers will first agree to maintain the strict confidentiality of such information and provide the same level of data security as provided by Global Fund Exchange.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you; including, for example, processing recruitment materials, administering surveys or contests, or communicating with you. These third party service providers are not permitted to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal requirements.

In addition, we may disclose information about you:

• If we are required to do so by law or legal process;

• To law enforcement authorities or other government officials;

• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;

• If disclosure is necessary to protect the vital interests of a person;

• To enforce our terms of use;

• To protect our property, services and legal rights;

• To prevent fraud against Global Fund Exchange, our subsidiaries and affiliates and business partners;

• To support auditing, compliance, and corporate governance functions; or

• To comply with any and all applicable laws.

We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business, we may disclose or transfer your personal data.

User forums

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Global Fund Exchange is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.

Link to third-party sites

Global Fund Exchange may provide links to third-party websites or information as a service to our users. If you use these links, you will leave the Sites. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Global Fund Exchange of the third party, the third party website, or the information contained therein, and Global Fund Exchange shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Security

Global Fund Exchange has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Global Fund Exchange personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions, Global Fund Exchange, however, cannot guarantee that unauthorized persons will not obtain access to your personal data.

Data retention policy

Global Fund Exchange retains all personal data for the duration of the relevant business relationship or, where required, in accordance with our information management policies and schedules. If your request that we delete your personal data, Global Fund Exchange will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “YOUR RIGHTS” section of this Privacy Policy.

Children

The Sites are not designed for or directed at children 13 years of age or younger, and Global Fund Exchange does not intentionally collect or maintain personal data about anyone under this age.

Your rights

Where granted by local law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you. In certain circumstances, you may also request that we cease processing your personal data.

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at info [at] globalfundexchange.com

To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request; such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.

In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.

You may also unsubscribe from mailing lists or any registrations on the Site. To do so, please either follow instructions on the page of the Site on which you have provided such information, subscribed or registered or contact us at the address provide at the bottom of this Privacy Policy.

Your California privacy rights

Pursuant to California Civil Code Section 1798.83(c)(2), Global Fund Exchange does not share your personal data with third parties for those third parties’ direct marketing use.

If you are a California resident under the age of 18, and a registered user of any Site where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info [at] globalfundexchange.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Consent; changes to privacy policy

By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.

Contact our privacy department

If you have any questions about our Privacy Policy or if you require any assistance in navigating or reading the materials on this Site or any other Global Fund Exchange Sites, please contact us at:

Global Fund Exchange
Legal Department
212-570-7970
info [at] globalfundexchange.com