GBS Inc. and each of their related companies (GBS Inc. together we, us, our and other similar expressions and each a GBS Inc. Member) are committed to protecting your personal privacy.
This policy tells you how GBS Inc. collects, stores, uses, manages and discloses your personal information, which includes information about you as an identified or identifiable individual (Personal Information). Please read this policy so that you understand how GBS Inc. deals with your Personal Information.
Information GBS Inc. collects
GBS Inc. may collect and use Personal Information about you in order to provide you with products and services. If you do not provide a GBS Inc. Member with all the Personal Information, it requests:
(a) that GBS Inc. Member may not be able to supply its products and services to you; and
(b) you or your organisation may not be able to participate in future offers of products or services which that GBS Inc. Member or each other GBS Inc. Member supplies.
The type of information GBS Inc. collects includes your name, address, email address, phone numbers, social security number, date of birth, annual income, net worth, bank account details and other contact and identification confirmation details. GBS Inc. may also collect details of your age, sex, occupation and other Personal Information about you.
GBS Inc. does not normally collect or store sensitive information, which includes information about ethnic origin, religious beliefs, political associations or opinions, criminal records or health and genetics. If GBS Inc. is required and able to collect sensitive information, the relevant GBS Inc. Member will ask for your consent before collecting that information and let you know the purpose.
How GBS Inc. collects Personal Information
GBS Inc. will generally collect your Personal Information directly from you, such as when you provide a GBS Inc. Member with information, whether in person, by telephone, online or in writing. If you submit an application (including by telephone or online), GBS Inc. will collect information necessary to fulfil that application. Other instances where GBS Inc. may collect Personal Information includes:
(a) information provided either directly to GBS Inc. or through a third-party engaged by GBS Inc. for the purposes of investing in financial products offered by GBS Inc.; and
(b) information from members of the general public, in the course of responding to, and using, GBS Inc.’s product information services.
In addition, GBS Inc. may also collect Personal Information about you form someone other than you, for example, from its software program providers or share registry providers.
How GBS Inc. stores Personal Information
GBS Inc. takes all reasonable steps to keep secure any Personal Information which it holds about you and to protect your Personal Information from loss, misuse or unauthorised alteration. Any Personal Information you provide to GBS Inc. is stored securely. Access to Personal Information is limited to our employees who specifically need it to carry out their business responsibilities. We also maintain security procedures to manage and protect the use and storage of records containing Personal Information.
GBS Inc.’s employees are obliged and trained to respect the confidentiality of any Personal Information held by the relevant GBS Inc. Member.
GBS Inc. is not responsible or liable for the security of data (including Personal Information in that data) sent on or through the internet.
Purpose of collection
GBS Inc. collects, holds, uses and discloses Personal Information so that each GBS Inc. Member can:
(a) meet its legal obligations;
(b) identify its customers, potential customers and their representatives;
(c) provide its products and services or other benefits to you;
(d) communicate with you;
(e) inform you of any initiatives it thinks may be of interest to you;
(f) inform you about its products and services and the benefits of using its products and services;
(g) provide you with information about offers or other benefits that may become available or be provided by it or other GBS Inc. Members;
(h) seek your opinion or comments about its products and services;
(i) carry out billing and debt recovery activities;
(j) carry out its management, administrative, quality assurance and complaint handling activities;
(k) develop and implement initiatives to improve GBS Inc.’s products and services;
(l) contact you to enable it to manage your account and Personal Information and fulfil each of its obligations to you or your organisation;
(m) recover money owing to it; and
(n) for other secondary purposes.
Children and Privacy
GBS Inc. acknowledges the importance of protecting children’s privacy online. In accordance with the Children’s Online Privacy Protection Act, GBS Inc. does not intend, nor does it knowingly collect, hold or use Personal Information from children under the age of 13. If you become aware or have reason to believe that GBS Inc. has collected Personal Information from someone under the age of 13, please immediately contact GBS Inc. at the contact details listed below.
Each GBS Inc. Member usually discloses the Personal Information it collects to its related entities, service providers and contractors that help it supply its products and services. For example, a GBS Inc. Member may disclose the Personal Information it collects to its information technology providers, promotional services providers, third-party contractors including software service providers, share registry providers, professional advisers (such as legal practitioners and accountants), debt collectors and insurers.
Except as provided in this policy, GBS Inc. will not disclose your Personal Information to a third-party unless:
(a) you have consented to the disclosure;
(b) the third-party is the service provider or contractor of a GBS Inc. Member, in which case that GBS Inc. Member will require them to use and disclose the Personal Information only for the purpose for which it was provided to them;
(c) the third-party is a person involved in a dealing or proposed dealing (including a sale) of all or part of GBS Inc.’s assets and business or securities in a GBS Inc. Member;
(d) the third-party is a credit reporting agency, your creditor, banker, financier, credit provider, mortgage insurer or trade insurer; or
(e) the disclosure is permitted, required or authorised by or under law.
GBS Inc. may use Personal Information to advise you of new products and marketing initiatives that may be of interest to you. This may include product or service offerings, newsletters and general information about any one or more GBS Inc. Member.
If you prefer not to receive information about GBS Inc.’s products and services, you can ask to be removed from the relevant circulation list by contacting GBS Inc. at the contact details listed below.
GBS Inc. never discloses Personal Information to a third-party for the purpose of allowing them to direct market their products or services to you, unless you have expressly consented to that disclosure.
If at any time you want to know what Personal Information GBS Inc. or any one or more GBS Inc. Members holds about you, you are welcome to request access to that information by contacting GBS Inc. at the contact details listed below.
You should note that where:
(a) the access impacts on the privacy of others;
(b) the request for access is frivolous or vexatious;
(c) there are existing or anticipated legal proceedings; or
(d) the access can be denied under law or by a law enforcement agency,
GBS Inc. may deny your request for access.
If GBS Inc. denies your request for access, GBS Inc.’s privacy officer will let you know why.
GBS Inc. may also charge a fee to cover the reasonable costs any one or more of the GBS Inc. Members incurs in processing your request.
Quality and correction
GBS Inc. always tries to make sure that the Personal Information that a GBS Inc. Member holds about you is accurate, complete and up-to-date. If at any time you believe the Personal Information that a GBS Inc. Member holds about you is incomplete or inaccurate, please let us know and GBS Inc.’s privacy officer will use reasonable efforts to correct that information.
Website and cookies
To ensure each GBS Inc. Member is meeting the needs and wants of its website users, and to develop its online services, GBS Inc. may collect aggregated information by using cookies or similar electronic tools.
If you wish to ‘disable’ cookies, check with your internet browser provider to find out how this can be done. Disabling cookies may limit or disrupt your ability to use all or part of our website.
Links to Third-Party Websites
GBS Inc.’s website may include links to third-party websites. This policy applies only to information collected by GBS Inc. on or through its website either directly or through a third-party and its website. If you click any third-party links on our website, this policy no longer applies unless we are collecting your Personal Information from that third-party website provider. GBS Inc. encourages you to read the privacy policies of those third-party websites as GBS Inc. is not responsible for the collection, use, management or disclosure of your information by such third parties.
Changes to this policy
GBS Inc. may change this policy at any time. GBS Inc.’s privacy officer will notify you of any change to this policy by posting an updated version of the policy on the relevant GBS Inc. Members’ website. It is your responsibility to check the relevant GBS Inc. Member’s website and make sure you keep up-to-date with any changes to this policy.
GBS Inc. is committed to constantly improving its procedures so that your Personal Information is treated appropriately. If you feel that GBS Inc. has failed to deal with your Personal Information in accordance with this policy, please contact GBS Inc. at the contact details listed below so we have an opportunity to resolve the issue to your satisfaction.
The GBS Inc.’s privacy officer will:
(a) listen to your concerns and grievances;
(b) discuss with you the ways in which GBS Inc. can remedy the situation; and
(c) put in place an action plan to resolve your complaint and improve our information handling procedures if appropriate.
Disclosure to overseas recipients
GBS Inc. is likely to disclose Personal Information to recipients located outside of the United States for various purposes, including the use of services from third-party contractors, which is necessary for the purposes for which that information was collected. By using our website, you consent to the disclosure of Personal Information to overseas recipients who may be governed by different privacy and protection laws. GBS Inc. cannot guarantee the adequacy of overseas privacy laws and you waive any claims against GBS Inc. for any loss that may arise as a consequence of disclosure to overseas recipients.
If you require more detailed information about how GBS Inc. deals with Personal Information or if you have any concerns about how a GBS Inc. Member has dealt with your Personal Information, please let us know by contacting us at:
GBS Inc. will aim to respond to your concerns as quickly as possible.