Global X BIGGEST WINNER CONTEST

PRIVACY POLICY

Global X Investments Canada Inc. (referred to in this Policy as “we”, “us” and “our”) is committed to protecting the privacy of personal information that we collect, use and maintain in the Global X Biggest Winner Contest (the “Contest”). We have a Chief Compliance Officer who is responsible for the overall governance of privacy. This Policy describes how we may collect, hold, use, and disclose your personal information. This Policy may be amended from time to time without notice to you. Please read this Policy and contact us should you have any questions.

What is Personal Information?
Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal email address and telephone number.

We may collect personal information directly from you or indirectly through someone you authorize or from third parties in accordance with applicable law. The information we may collect or receive from you depends on your relationship with us.

Privacy Principles
The Policy is outlined by standard privacy principles that guide us in the collection, use and disclosure of personal information.

Accountability
We are accountable for the personal information under our control by establishing, training our staff in, and enforcing our privacy policies and procedures to promote compliance with these privacy principles. We have a Chief Compliance Officer accountable for personal information under our control and responsible for compliance with this Privacy Policy.

Our policies and procedures govern how we may deal with your personal information. Every employee is responsible for respecting and protecting the personal information to which the employee may have access.

Identifying Purpose
We will inform you about the purposes for which we may collect, use, and disclose your personal information and we only collect, use, and disclose your personal information for those purposes.

Consent and Choice
We will obtain your consent to collect, use, or disclose your personal information and you may at any time revoke that consent, subject to legal and regulatory requirements. In some stances, we may not be able to provide certain services and products to you if you do not consent or withdraw consent to our collection, use or disclosure of the required information.

Limiting Collection
We limit the collection of your personal information only to what we determine is necessary for the purposes we identify for you and only collect the personal information we need for those identified purposes.

Limited Use and Disclosure
We do not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as required by law. In addition, we will only use or disclose your personal information for the purpose(s) it was collected.

Retention
Your personal information will be kept only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements. These requirements also apply to third parties who work with us.

To determine the appropriate retention period, we consider different criteria, including the purposes for which we process your personal information, the need to maintain your personal information to provide you with products and services, and all applicable legal and regulatory requirements. We may retain personal information beyond our designated retention periods due to regulatory requirements or in response to a legal matter.

Accuracy
We maintain your personal information in an accurate, complete, and up-to-date form as is needed for its use. We are committed to maintaining the accuracy of your personal information and may make reasonable efforts to keep your information complete and up-to-date.

Protection
We have established safeguards to protect against unauthorized access, disclosure, copying, use or modification, theft, misuse, or loss of your personal information that may be in our custody or control. These safeguards are appropriate to the sensitivity of the information.

Openness
We have policies and procedures in place which educate our employees on their responsibilities when collecting, using, disclosing and managing the personal information that we may collect.  We provide our employees with annual training on our privacy policy.

Individual Access and Rights
You may request access to the Personal Information we hold about you or request a correction/update of that personal information.

You can make that request directly to privacyofficer@globalx.ca or by mail below. We will need specific information from you to process your request. Depending on the nature of your request, we may charge you a fee and we will advise you of any fee prior to proceeding with your request. If we are unable to provide some of the personal information we hold about you, we will give you an explanation.

Contact Us
If you have any questions about this Policy please contact us at privacyofficer@globalx.ca or by mail here:

Chief Compliance Officer
Global X Investments Canada Inc.
55 University Avenue, Suite 800
Toronto, Ontario
M5J 2H7