First Share Global Privacy Policy

Effective date:

June 30, 2024

Last revised: June 29, 2024

First Share LLC, a New Jersey financial services provider headquartered at 51 Joysan Terrace, Freehold Township, NJ 07728, United States of America, with its representative offices at E24/3, One Canada Street, Canary Wharf, London E14 5AB, United Kingdom; Grenzacherstrasse 124, 4058 Basel, Switzerland; Units 355/1 & 356/2, One Central, Dubai World Trade Centre, Dubai, United Arab Emirates; Suite 1401/3, 12 Marina Blvd, Tower 3, Marina Bay Financial Center, Singapore; Suite 2439/L, 63/F, Two International Finance Center, 8 Finance Street, Hong Kong, China, hereinafter referred to, and known as, (“First Share LLC”, First Share”, “First Share Group”, “Daash”us”, “we”, or “our”) operates the www.firstsharellc.com website (the “Site”) and provides Wealth/Investment Management, Business Funding, Escrow (Direct Supplier and Third-party Supplier Payment Processing), International Payroll and Related Services (the “Services”), which are available through the Site.

First Share LLC has developed a global privacy program under which we offer the same high standards of privacy protection regardless of where you are in the world. When we refer to First Share, we mean the First Share LLC entity with which you have an agreement, if applicable.

This Privacy Policy informs you of how information about you is collected, used, and disclosed by us.

This Privacy Policy forms part of our First Share Platform(s) Terms of Service. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Scope of Application

This Privacy Policy applies to the following individuals :

Visitors of the Site with whom First Share and partners does not have a contractual relationship
Clients who use our Services, including client UBOs or representatives
Independent Contractors who use our Services
First Share community platform users
Suppliers who provide products or services to First Share Portfolio Hiring Customers’ Candidates
Prospects
Participants of webinars, conferences, trade events, surveys, etc.

By using our Site and/or our Services as well as engaging with First Share in any way, you agree to the collection and use of your information in accordance with this Privacy Policy.

Information Collection

First Share collects and stores certain information about you. This information can be used on its own or in combination with other information to identify you (“Personal Information”). Below is a list of types of Personal Information that we may collect and use about you:

A. Categories of Personal Information & Description:
1. Contact — Information we use to contact you including physical addresses, e-mail addresses, and phone numbers.

2. Identification — Information we use to identify you including full name, government-issued ID, passport, DoB, and selfie, where applicable.

3. Financial — Information about an individual’s financial account including bank account details, payment card details.

4. Transactional — Information about the transactions you carry out and the payments to and from your accounts with us including amounts and dates, when using the Site and/or the Services.

5. Contractual — Information about the products or services we provide to you.

6. Locational — Information we get about where you are, including country and IP address. This may come from your mobile phone or the place where you connect a computer to the internet. It may also include locations where you used your card.

7. Platform Usage — Information about the usage of our Services and Site including metadata.

8. Technical — Information on the devices and technology you use including IP address, login data, browser type and version, timezone, operating system, browser type.

9. Communications — Information from communications between us including any personal data you may share with us in your messages, communication metadata.

10. Professional — Information about professional career and educational background including current and old job positions, degrees, qualifications.

11. Public and Third-party Records — Information about you that is in public records and information about you that is publicly available on the internet. We also collect information about you which we receive from other companies, such as (without limitation) credit reference or fraud protection agencies (see below for more information).

12. Consents — Any permissions, consents or preferences that you give us.

13. First Share Community Platform Content — The First Share Community allows you to post or transmit comments, computer files, messages, and other materials. This content may include personal data.

14. Biometric data — To automatically verify your identity and prevent fraud, we may use your biometric data. Specifically, we may collect a photo of you (a selfie) along with government-issued identification. Using facial recognition technology, the information from your photo is matched against the information on your identification document.

15. Other Information — Any other information you choose to provide to us through all available channels, participating in user/customer surveys or otherwise visiting and interacting with our Site and/or Services.

For the avoidance of doubt, Personal Information shall not include any personal information which is anonymised, after which the identifiable data is destroyed. First Share may also collect and use non-Personal Information to analyze the effectiveness of our Services and to improve our Services. We may collect non-Personal Information through the Services, the Site and through cookies.

Sources of Your Information Personal

We may collect Personal Information about you or your businesses from any of these sources:

Directly for you when you use our Services, complete a contact form, request marketing communications, participate in surveys or contact us.
First Share collects profile and usage data when you interact with our Site and/or Services, including, without limitation, your security details, app or your web browser settings, marketing choices and data from the devices you use to connect to our platform so we can provide you with our products or services.
We also collect information through the use of cookies and other internet tracking software while you are using our website or mobile apps as described in detail in our Cookie Policy.
From third parties:
Companies, business partners or individuals that introduce you to us
Business partners, service providers, sub-contractors, advertising networks, analytics providers, search information providers, fraud protection services, Payment Service Providers (PSPs) who help us authenticate your identity, improve the quality of our Services, promote our Services and protect our business. We may also receive Personal Information about you from providers that help prevent, detect and prosecute unlawful acts, money laundering, and fraudulent behavior.
Social networks and other technology providers (for instance, when you click on one of our Facebook or Google adverts)
Public information sources such as (without limitation) national company registries
Market researchers
Government, law enforcement agencies, authorities and regulatory bodies.

Cookie Use

Please refer to our Cookie Policy for more information.(Clickable link to the Cookie Policy Page)

Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Information Use

Below is a list of the ways that we may use your Personal Information together with the legal basis of processing, where applicable under data protection law.

B. Purposes for which we use your Personal Information, Legal basis , and Associated Users/Individuals.

1. Purpose

i. Management of the contractual relationship with you to provide you with our Services.

ii. Improving our business by (a) Improving our services and operations (b) Developing new ways to meet our customers’ needs and grow our business (c) Analyzing and studying how our customers use products and services from First Share.

iii. Secure access to our Services, including but not limited to performing the necessary identification and verification of our users prior to granting access to our Services.

iv. Marketing and events-related communications, including but not limited to inviting you to participate in events, surveys, providing personalized content through advertising campaigns or otherwise communicating with you for marketing purposes to promote our Services.

v. Interviews & Recruitment

vi. Protect the security or integrity of us, our Site and our Services.

vii. Communicate with you about our Site and Services, such as to notify of changes and updates and to provide you with customer support and troubleshooting.

viii. To manage our business operations including but not limited to delivering First Share’s products and services, making and managing payments, managing fees and charges due on user accounts and debt collection.

ix. Meet our legal, regulatory, and tax reporting obligations.

x. To provide and maintain the First Share Community Platform.

xi. Aggregating pseudonymised personal data and reporting anonymised salary data for the purpose of compensation benchmarking in various industries and geographies as well as for academic research purposes.

2. Legal Basis

i. (a) Performance of the contract
(b) Compliance with our legal obligations

ii. (a)Performance of a contract & (b) Legitimate interest:
Our legitimate interest is centered around enhancing the quality of our Services, optimizing operational efficiency, and maintaining a competitive edge in the market.

iii. (a) Performance of the contract, (b) Legitimate interest, & (c) Consent:
Our legitimate interest is to safeguard access to our Services to authorized only users who have gone through identification and verification processes

iv. (a) Consent & (b) Legitimate interest
Our legitimate interest is to tailor our marketing communications to the preferences and interests of our audience and provide a personalized and engaging experience for our customers.

v. (a) Performance of the contract & (b) Legitimate interest:
Our legitimate interest is to help our Portfolio Hiring Companies assess their prospective candidates’ qualifications and suitability for available and/or offered positions and to maintain a pool of potential candidates for future opportunities.

vi. (a) Legitimate interest:
Our legitimate interest is to maintain the reliability and availability of our services by detecting and preventing security threats, fraud, money laundering and other crime, unauthorized access, risk and other activities that could harm our business, Site, or Services.

vii. (a) Legal Obligation & (b) Performance of the contract

viii. (a) Performance of the contract & (b) Legitimate interest:
Our legitimate interest is grounded in our commitment to delivering a seamless and informative user experience and to provide assistance when needed.

ix. (a) Performance of the contract & (b) Legitimate interests:
Our legitimate interests to manage our business operations efficiently, deliver our products and services, and ensure the financial stability of our company.

x. All and Necessary Legal obligations

xi. (a) Performance of the contract & (b) Legitimate Interest:
Our legitimate interest to ensure that the online platform operates smoothly and effectively to provide the services or features it offers to users.

xii. (a) Consent, (b) Performance of a contract, & (c) Legitimate interest:
Our legitimate interest in making informed decisions about compensation strategies, remain competitive, and attract and retain talent as well as benefiting society by advancing the knowledge in fields related to compensation, labor markets, and HR practice, while meeting all our users numerous needs.

3. Associated Users/Individuals
i. (a) Clients (b) Independent Contractors (c) Suppliers.

ii. (a)Visitors of the Site (b) Clients (c) Independent Contractors
(d) First Share community platform users (e) Suppliers (f) Prospects.

iii. (a) Clients (b) Independent Contractors.

iv. (a) Visitors of the Site (b) Clients and customers (c) Independent Contractors (d)First Share community platform users (e) Prospects
(f)Participants of webinars, conferences, trade events, surveys etc.

v. Candidates.

vi. (a) Visitors of the Site (b) Clients and Customers (c) Independent Contractors (d)First Share community platform users (e) Prospects
(f)Participants of webinars, conferences, trade events, surveys etc.

vii. (a) Visitors of the Site (b) Clients and Customers
(c)Independent Contractors (d) First Share community platform users (e) Prospects

viii. (a)Clients (b)Independent Contractors (c) Suppliers

ix. (a)Clients (b)Independent Contractors (c) Suppliers

x. (a)Clients (b)Independent Contractors (c) Suppliers

xi. First Share community platform users

xii. Workers.

In cases where we need to process personal data for the performance of the contract with you or as required by law and you refuse to provide your information, we may not be able to perform the contract with you and consequently, we may not be able to provide certain services to you.

Contract Type & Nature

All contracts are Smart Contract, and are signed by a simple click or a button. No contract may require a traditional signature, and all contracts are valid upon signing, and represents and replaces all traditional signature types, unless otherwise communicated by the Service and Service Provider Partners.

Communications

We may contact you with newsletters and other marketing information that may be of interest to you. You may opt out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. Please note that we may still send you transactional or administrative messages related to the Service even after you have opted out of receiving marketing communications.

Information Sharing With Third Parties

We will only share your information with the third parties listed below for the purposes described above in the “Information Use” Section unless otherwise noted at the point of collection. We want to assure you that we do not sell or trade any personal information to third parties under any circumstances:

Our clients to whom you provide your services

Trusted third-party agents, partners, suppliers, and service providers who assist us in providing the Services to you and are only permitted to use your information according to the purposes specified in their agreement with us. These third parties include website hosts, data hosts, cloud software providers, IT providers, identification verification providers, customer support providers, payment processors, financial institutions, financial advisors, legal advisors, auditors, and insurance companies. These partners are required under law and contract to keep your Personal Information confidential.

Government or public agencies, law enforcement authorities, regulators or any other entity having appropriate legal authority for receipt of you Personal Information, if required or permitted by law or legal process or if we believe that such action is necessary to comply with the law, to protect the security or integrity of our business, our Site and/or Services and to protect the safety of the users of our Services or the public.

We may disclose your Personal Information to a third party who acquires any part of our business, whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our assets.

We may share de-identified Personal Information with academic institutions to perform research, under controls that are designed to protect your privacy—including requiring such institutions to operate under confidentiality agreements and mandating that published findings contain only de-identified and aggregated data.

From time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics, and

We may share Personal Information with our current and future First Share affiliates. Our affiliates may use your Personal Information in a manner consistent with this Privacy Policy.

We may share Personal Information with third-party advertising partners such as social networks to perform marketing activities and to deliver targeted advertisements based on your interests.

When you provide your consent to us to share your information.

Retention of Your Personal Information

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, consistent with applicable law. This retention period allows us to comply with our legal obligations, resolve disputes, enforce our agreements and study customer data as part of our own research. We will not retain your data for longer than is necessary to fulfill the purpose for which it is being processed.

To determine the appropriate retention period, we take into consideration the amount, nature, and sensitivity of the personal data, as well as the purposes for which we process it. We also assess whether we can achieve those purposes through other means. For the data retention period related to the Services provided to you, please refer to the Data Processing Addendum

Security

The security of your Personal Information is important to us. We implement suitable measures to safeguard the information you entrust to us, preventing its loss, misuse, unauthorized access or disclosure, alteration, and destruction, addressing threats from both external and internal sources. Furthermore, we restrict access to your personal data to individuals such as employees, agents, contractors, and other third parties, but only those who require such access for legitimate business purposes. These authorized individuals will process your personal data solely based on our explicit instructions and are bound by a confidentiality obligation.

If you have selected a password or other login credentials that grants you access to the First Share platform, it is your responsibility to take all reasonable measures to maintain the confidentiality of this information. You should not share your password or login credentials with any other individual.

Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you. Therefore, you are also a key stakeholder in making sure that your Personal Information is protected. If you become aware of any breach of security or privacy, please contact us immediately at [email protected].

International Transfer

Information collected while you use the Site and/or Service, including your Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States, United Kingdom, Switzerland, Singapore, Hong Kong, and the UAE; and choose to provide information to us, please note that we will transfer the information, including your Personal Information, to the United States and process it there. In order to provide adequate protection for the data transfer, we have in place contractual arrangements with our subsidiaries, affiliates and business partners in respect of such transfers. By utilizing our Sites and/or services, you authorize the international transfer of your data, to the United States, where we are based, and to other locations where we and/or our service providers operate. Note that the First Share Platform is maintained and owned by First Share LLC, a United States entity, however First Share stores all First Share Platform data in Ireland (EU) and United Kingdom only.

Children’s Privacy

We do not knowingly collect Personal Information from children under the age of 18. Our Site and Services are not addressed to minors, and we have a strong security measure that checks this. If you are a parent or guardian and you learn that your children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under the age of 18 without verifiable parental consent, we will take steps to remove that information from our servers.

Your Rights

Under applicable privacy regulation, you may have some or all of the following rights in respect of your Personal Information:

to obtain a copy of your Personal Information together with information about how your Personal Information is processed;
to rectify inaccurate Personal Information;
to erase your Personal Information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
to restrict processing of your Personal Information
to object to the processing of your Personal Information where we’re relying on a legitimate interest;
to object to decisions that are based solely on automated processing or profiling;
to obtain a portable copy of your Personal Information, or to have a copy transferred to a third party controller; or
to withdraw your consent, at any time, where you may have provided it for the collection, processing and transfer of your Personal Information for a specific purpose;

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.

To exercise these rights you may contact us either by emailing [email protected] or addressing it to the Head of Data Privacy Manager Service, Bouazizas & Partners, 46/e Quai de la Seine, 75019, Paris, France.

We may ask you for additional data to confirm your identity and for security purposes, before disclosing the information requested to you. If you would like to submit a request on behalf of another individual, you may do so by providing proof of authorization by the individual to submit such a request on their behalf. We reserve the right to charge a fee where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are excessive, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain Personal Information for a limited period of time for record-keeping, accounting and fraud prevention purposes. Please note also that you may be able to exercise some of these rights without our intervention. For example, if you are a registered First Share platform user, you can access and update your personal data.

Changes to This Privacy Policy

This Privacy Policy is effective as of the “LAST REVISED” date specified at the top of this Privacy Policy and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

Questions or Concerns Regarding This Privacy Policy

If you have questions or concerns regarding privacy using our Service, please contact us at: [email protected].

Region-Specific Privacy Terms

First Share LLC is a global company and as such, our approach to privacy compliance is a global one. No matter where you are located, whether in the United States, the European Economic Area (EEA), the United Kingdom (UK), Latin America, the Middle East or the Asia-Pacific region, we remain committed to abiding by all applicable data protection laws. Below you’ll find region-specific privacy terms that might apply to you in addition to the general terms of this Privacy Policy, depending on the country where you’re based:

1. Legal Basis

If you are a resident in the EEA, UK and Switzerland, we collect and process information about you only where we have a legal basis for doing so under applicable laws. For information about the legal bases we rely on when processing your Personal Information under GDPR, please refer to the section “Information Use” of our Privacy Policy.

2. Data Transfer

This section applies to residents of the EEA, Switzerland and the UK, using our Site and/or Services and addresses the specific requirements under the General Data Protection Regulation (GDPR), the UK GDPR and the Swiss Federal Data Protection Act (FADP).
When transferring data from the European Union, the European Economic Area, the UK, and Switzerland, First Share relies upon the Standard Contractual Clauses as included in our Data Processing Addendum. First Share also complies with the EU-U.S. Data Privacy Framework (the “EU-U.S. DPS”), the UK Extension to the EU-U.S. DPF (the “UK Extension”), and the Swiss-U.S. Data Privacy Framework (the “Swiss-U.S. DPS”), as set forth by the U.S. Department of Commerce.

First Share has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. First Share has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, email Privacy Protection Department at [email protected]

First Share is responsible for the processing of personal data it receives, under each DPF, and subsequently transfers to a third party acting as an agent on its behalf. First Share complies with the DPF Principles for all onward transfers of personal data we receive from the European Union, the UK and Switzerland in reliance on the EU-U.S. DPF Principles, the UK Extension and/or the Swiss-U.S. DPF Principles, including the onward transfer liability provisions. In particular, where we have received your personal information in the United States in reliance upon the EU-U.S. DPF Principles, the UK Extension and/or the Swiss-U.S. DPF Principles and we subsequently transfer that information to a third party acting as an agent, and such third party agent processes your personal information in a manner inconsistent with those Principles, we will remain responsible unless we can prove we are not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Deel commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact First Share at [email protected].

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, First Share commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

With respect to personal data processed pursuant to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), First Share is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, First Share may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions that are fully described on the Data Privacy Framework website here, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

3. Your GDPR Rights

If you are a resident of EEA, UK and Switzerland, you have the rights set forth in the “Your Rights” section of our Privacy Policy.

China and Chinese Territories

1. Legal Basis

If you are a resident of the Republic of China, we collect and process information about you only where we have legal bases for doing so under applicable laws. For information about the legal bases we rely on when processing your Personal Information under PIPL, please refer to the section “Information Use” of our Privacy Policy.

2. Transfer of Information Outside China

First Share will transfer your personal information to the United States as mentioned in the “International Transfer” section of our Privacy Policy. First Share may also transfer your Personal Information to third parties located outside of the territory of China if this is necessary to fulfill our purposes as outlined in the “Information Use” section. Before we transfer your Personal Information outside the territory of China, we will make sure that all requirements under the laws and regulations of China on cross-border transfer of Personal Information are met and will require overseas recipients to protect your Personal Information at the levels not lower than those required by applicable laws and regulations of China.

3. Your PIPL Rights

If you are a resident of the People’s Republic of China (“PRC”), you have, in addition to the rights set forth in the “Your Rights” section of our Privacy Policy, the right to access, correct, and delete the Personal Information of the deceased close relative of yours under the Personal Information Protection Law (“PIPL”).

Brazil

1. Legal Basis

If you are a resident of Brazil, we collect and process information about you only where we have legal bases for doing so under applicable laws. For information about the legal bases we rely on when processing your Personal Information under LGPD, please refer to the section “Information Use” of our Privacy Policy.

2. Your Brazilian Privacy Rights

This section applies to individuals who are located in Brazil, according to the “Lei Geral de Proteção de Dados” (LGPD).

We assure you that you will never be discriminated against by exercising your rights. If you are a resident of Brazil, you have, in addition to the rights set forth in the “Your Rights” section of our Privacy Policy, the right to anonymization, and to access information from public and private entities with whom we have shared your Personal Information.

Other Regions

If you reside in a location outside of the EEA, the UK, Switzerland, the United States, Hong Kong, China, or Brazil, Singapore, and the UAE, please be aware that we prioritize your privacy. Certain regions have distinct privacy requirements that necessitate specific provisions in our Privacy Notice. We are committed to staying compliant with applicable data protection laws and will update this Privacy Policy as necessary to incorporate any required provisions.