This is the Privacy Policy of Global X Brasil Gestora de Investimentos LTDA., which is referred to as “Global X Brasil” throughout this Privacy Policy. This Privacy Policy provides details on how personal data is to be processed, in accordance with our obligations under the applicable data protection legislation, including the Brazilian “Lei Geral de Proteção de Dados” (Law No. 13,709/18) (“LGPD”), and any other applicable law.

Global X is committed to privacy measures, the protection of personal data and its use in an ethical, legal, transparent, secure and responsible manner.

LGPD Concepts

  • Holder: Natural person to whom the personal data that will be processed are referred.
  • Personal Data: Information related to the identified or identifiable natural person. 
  • Sensitive Personal Data: Personal data related to racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political character; data referring to health or sexual life; genetic or biometric data, when linked to a natural person.
  • Anonymized Data: Information related to the holder that can not be identified. It is that data that, originally, was relative to a person and went through stages that ensured his disconnection from that person.
  • Controller: Natural or legal person, of public or private law, who is responsible for decisions regarding the processing of personal data.
  • Operator: Natural or legal person, governed by public or private law, who carries out the processing of personal data on behalf of the controller.
  • Person in charge: Individual, indicated by the controller, to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).
  • Treatment: Any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
  • Database: Structured set of personal data, established in one or several locations, in electronic or physical support.

Your legal rights:

  • Confirmation of the existence of treatment;
  • Access of the collected data;
  • Correction of incomplete, inaccurate or outdated data;
  • Anonymization, blocking or deletion of unnecessary, excessive or treated data in non-compliance with the provisions of the LGPD;
  • Portability of the data to another service or product provider, upon express request, in accordance with the regulations of the National Authority, observing the commercial and industrial secrets;
  • Elimination of personal data processed with the consent of the holder, except in the cases provided for in article 16 of LGPD;
  • Information of the public and private entities with which the Controller has made shared use of data;
  • Information on the possibility of not providing consent and on the consequences of the denial;
  • Revocation of consent.

These rights are subject to limitations provided for in applicable data protection law. You may make a request to Global X to exercise any of these rights by contacting us at [email protected]. Requests will be handled in accordance with applicable data protection law.

Information obtained by Global X:

Global X may obtain personal information through the website globalxetfs.com.br or related as applicable, including, but not limited to, the information provided when you:

  • Download marketing or research materials;
  • Contact with questions or requests for information;
  • Apply for any Continuing Education credits.

Global X may also obtain information through third parties, including, but not limited to, investor relations managers with whom you shared information to receive investment opportunities.

For the purposes of this privacy policy, “personal data” includes information that can be used to identify you, such as name, address, company affiliation, email address, telephone number or type of investor. The types of personal data processed by Global X include:

  • Identity Data: includes first and last name, title and gender;
  • Contact Data: includes e-mail address, telephone number and business contact information;
  • Technical Data: includes IP (internet protocol) address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technologies on the devices that the Owner uses to access the  Global X website.
  • Usage Data: includes information about on how you use the Global X website and services.
  • Marketing and Communications Data: includes preferences in receiving marketing communications from Global X and third party partners.

Global X does not collect or process special categories of personal data, nor does it process information about criminal convictions and felonies.

Collection of information using cookies and other tools

Global X may use “cookies” or other electronic tools to collect information such as:

  • IP address;
  • Browser type;
  • Operating system;
  • Computer platform;
  • Mobile device information;
  • Geolocation data; and
  • The state or country from which the Owner accessed the Website.

Global X  may also use cookies or other electronic tools to collect and compile statistical and other non-personal information about the use of the website and the services provided on the website, as explained below:

  • Necessary cookies: these are those used for the website to perform basic functions and operate correctly. Therefore, the collection of information is essential to ensure the functioning of the website or for the proper provision of the service. In this way, the activities covered as strictly necessary include those related to the specific functionality of the service, that is, without them the user would not be able to carry out the main activities of the website or application. This category is restricted to the essential to provide the service requested by you, not contemplating non-essential purposes, which meet other interests of the Controller.
  • Analytical or performance cookies: they make it possible to collect data and information about how users use the website, which pages they visit most often on that website, the occurrence of errors or information about the performance of the website or application itself.
  • Advertising cookies: are used to collect information for the purpose of displaying advertisements. More specifically, from the collection of information relating to the user’s browsing habits, advertising cookies allow their identification, the construction of profiles and the display of personalized advertisements according to their interests.

Cookies are files installed on a user’s device that allow the collection of certain information, including, in some situations, personal data, in order to meet various purposes.

Most browsers are set to accept cookies by default. If you prefer, the Owner can configure your browser to disable cookies or alert you when cookies are being sent. Similarly, most mobile devices allow the Holder to  disableand the ability to retain geolocation information to be collected from their mobile device. However, if you choose  to disable  cookies or refusesand accepts a request to place a cookie, it is possible that some parts of the website, such as certain pages to which it is necessary to login, will not function properly.

Global X may use its own or third-party cookies on its website.  The collection of personal data through the use of cookies is limited to the minimum necessary to carry out legitimate, explicit and specific purposes, and further processing in a manner incompatible with these purposes is prohibited.

We will always seek your consent in the use of cookies, and this consent can be withdrawn at any time. You can change your cookie preferences at any time by changing your preferences here on our website.

How we use personal information

 Global X will only use personal data permitted by law, on the following occasions:

  • When necessary for legitimate interests (or those of third parties), observing your fundamental rights;
  • When entering a contract signed with the Holder; or
  • To fulfil legal or regulatory obligations. 

For the day-to-day activities of Global X, the processing of personal data does not require consent for simple processing, except in relation to the sending of direct marketing communications to the Data Officer via email or text message.   In these cases, you have the right to withdraw consent to marketing at any time by contacting us via email [email protected].

For marketing purposes and public materials, Global X will obtain express opt-in consent from the Data Officer before sharing their personal data with any company outside the Global X economic group.  You may unsubscribe or opt out of receiving promotional materials from Global X by following the specific instructions in the email or other communication received, or by sending an email to [email protected].

Data Retention

Global X will keep the personal data  it obtains only  for as long as necessary to fulfill the purposes for which it was collected, and to comply with any legal and regulatory requirements.  To determine the appropriate period  for the retention of personal data, Global X will consider the  amount, nature, sensitivity of the data, the  potential risk of harm arising from the unauthorized use or disclosure of personal data, and the purposes for which the personal data was collected. 

Personal data may also be deleted at the request by you, unless there is any legal hypothesis that requires the storage of the data. In this case, you will be informed of the reason for the impediment of elimination.  The request for deletion of personal data can be made through the e-mail [email protected]

Data Officer

The Data Officer is responsible for ensuring compliance with the Brazilian “Lei Geral de Proteção de Dados”.

If you understand that your personal data is not being treated in accordance with the law, or has any questions about how their data is being treated, please send an e-mail to: [email protected]

Privacy Policy Update

Whenever Global X understands as necessary, the Privacy Policy may undergo changes that will be published in its website. These changes will be valid, effective and binding after the new version is disclosed on its website or is communicated in any other way.

In charge: Vitor BatistaForeman’s E-mail: [email protected]