Privacy Policy

Overview

This is the Privacy Policy of Global X Management Company LLC which is referred to as “Global X”, “us” or “we” throughout this Privacy Policy. This Privacy Policy provides details of the way in which we process personal data in line with our obligations under applicable data protection law, including Regulation 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR”), the UK GDPR, the California Consumer Privacy Act of 2018, and any other applicable law.

Information We Obtain

Global X may obtain personal information from you through the site globalxetfs.com or globalxetfs.eu as applicable, including but not limited to information you provide when you:

• Download marketing or research collateral;
• Contact us with questions or requests for information
• Register for our Model Portfolio content; or
• Register for any Continuing Education credits

We may also obtain information through third parties, including but not limited to, third party investor relations managers with whom you have shared your information for receiving investment opportunities.

For purposes of this privacy policy, “personal data” includes information that can be used to identify you, such as your name, address, company affiliation, e-mail address, phone number, or investor type. The types of personal data we collect, use, store and transfer include:

• Identity Data: including your first and last name, title and gender.
• Contact Data: including your email address, telephone number and business contact information.
• Technical Data: including your internet protocol (IP) address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Usage Data: including information about how you use our website and services.
• Marketing and Communications Data: including your preferences in receiving marketing communications from us and our third party partners.

We do not collect or process any special categories of personal data about you as defined in Article 9 GDPR, nor do we collect any information about criminal convictions and offences.

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;
• Information about your mobile device;
• Geo-location data; and
• The state or country from which you accessed the site

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

• A cookie is a small text file placed on your computer. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of the site, such as certain pages for which you need to log in, will not function properly.

To monitor website performance, Global X also utilizes Pirsch Analytics, which is a cookie-free web analytics software.

How We Use Your Information

Global X will only use your personal data when permitted by law, and generally in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to perform a contract we have entered into with you; or
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (see Contact Us).

Personal data is processed by us for the following purposes:

Where we use your personal data for marketing and advertising purposes, you may opt-out of receiving such communications at any time. We will get your express opt-in consent before we share your personal data with any company outside Global X and its affiliates for marketing purposes. You can unsubscribe or choose not to receive promotional materials from Global X by following the specific instructions in the e-mail or other communication you receive or by e-mailing us at info@globalxetfs.com. Please note that it may take some time to process your request, consistent with applicable law.

How We Share Your Information

Global X may share your personal information with our affiliates and subsidiaries under narrow circumstances, including but not limited to:

• With our service providers that help us to operate our business (e.g., to deliver the information or services requested by you; to perform other activities related to such information or services; and to provide you with promotions from Global X);
• In connection with any proposed or actual sale or other transfer of some or all assets of Global X, and/or any proposed or actual sale or merger of Global X (including in the event of a reorganization, dissolution or liquidation);
• With our affiliate entities to allow us to deliver our services to you, including marketing information about investment opportunities;
• As otherwise required or permitted by law; and/or
• Any other sharing to which you consent.

We may also disclose personal data to our professional advisors, regulatory bodies, auditors, technology providers and any of the respective related, associated or affiliated companies of the foregoing for the same or related purpose(s).

Global X and Data Processors

Global X will engage certain service providers to perform certain services on its behalf which may involve the processing of personal data. To the extent that such processing is undertaken based on the instructions of Global X and gives rise to a data controller and data processor relationship, Global X will ensure that such relationship is governed by a contract which includes the data protection provisions as required by applicable data protection law.

Your Legal Rights:

If you are based in the EEA or the UK you have certain rights under GDPR and UK GDPR (as appropriate), including the following:

• the right to receive detailed information on how we process your personal data;
• the right of access to your personal data;
• the right to amend and rectify any inaccuracies in your personal data;
• the right to request your personal data be erased (right to be forgotten);
• the right of data portability;
• the right to restrict processing;
• the right to object to processing;
• the right to object to automated decision making, including profiling;
• the right to withdraw your consent at any time where we are relying on consent to process your personal data; and
• the right to make a complaint to the appropriate data protection regulatory authority.

These rights will be exercisable subject to limitations as provided for under the applicable data protection law. You may make a request to Global X to exercise any of these rights by contacting us (see Contact Us). Requests shall be dealt with in accordance with applicable data protection law.

Data Retention

We will only retain your personal data for so long as is necessary to fulfil the purposes we collected or obtained it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate period for retention of your personal data, we will consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, and the purposes for which we process your personal data. Details of retention periods for your personal data are available by contacting us (see Contact Us).

Security

We take precautions to protect your personal data against unauthorized loss, access, use, alteration or destruction. Only employees who need the information to perform a specific job are granted access to personal data. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Data Transfers outside the EEA

Global X may transfer your personal data to countries outside the EEA or the UK which may not have the same or equivalent data protection laws. If such transfer occurs, Global X will ensure that such processing of personal data is in compliance with applicable data protection law including GDPR and UK GDPR, and, in particular, that appropriate measures are in place such as entering into Model Contractual Clauses (as published by the European Commission).

Social Media

Global X and select employees maintain profiles and/or pages on various social media sites, including X, Facebook, YouTube, and LinkedIn. If you choose to “Follow” Global X on X, Facebook, YouTube or LinkedIn or take any similar action on another social media site, you are providing your consent to receive informational updates, including solicitations, from Global X. To stop receiving this information from Global X on a social media site, you must follow the procedure established by the site. For example, on X, you must click “Unfollow” on Global X’s profile page.

The information contained in Global X’s social media profiles and pages is current as of the date of publication (or such earlier date as referenced) and is subject to change without notice. Global X has no obligation to update any or all of such information. Additionally, Global X personnel other than the author(s) may provide oral or written market commentary or investment ideas to Global X’s clients or prospects that differ from the views expressed.

All amounts, market value information, and estimates have been obtained from outside sources where indicated or represent the good faith judgment of Global X. Where such information has been obtained from outside sources, Global X cannot guarantee its accuracy or completeness. Past performance is not a guarantee or reliable indicator of future results. Global X’s social media profiles and pages are not intended to be an offer or solicitation with respect to the purchase or sale of any security or other financial instrument or any investment management services. They are provided for information purposes only, do not constitute investment advice, and should not be used as the basis for any investment decision. They also do not purport to provide any legal, tax, or accounting advice.

X, Facebook, YouTube, and LinkedIn are owned by third parties unaffiliated with Global X. Global X is not responsible for the terms of use or policies of any of the social media sites on which it maintains a profile or page or any third-party sites to which they are linked, and you use these sites at your own risk. Global X is not responsible for and does not endorse any content, advertising, products, advice, opinions, recommendations, terms of use or privacy policies, or other materials on or available from third parties.

While Global X may monitor postings by third parties on its profiles and pages, Global X is not able to review them before they are displayed, and any such postings are the views and responsibilities of the posters. Global X does reserve the right to edit or remove any post for any reason and to block followers to the extent permitted by the sites. If Global X does not remove a third-party post, it is not an endorsement of the content.

Global X does not provide customer service, conduct financial transactions, or accept customer complaints through its social media profiles and/or pages. Never disclose account or other personal financial information on any of our social media profiles or pages.

Links to Third-party Websites

The site may include links to third-party websites. Since we do not control third-party websites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

California Residents

The California Consumer Privacy Act of 2018 (CCPA) provides California Residents with specific privacy rights. These rights are further discussed in this Notice and should be read in conjunction with our general privacy policy.

Questions Regarding this Online Privacy Policy

If you have questions regarding this privacy policy, please contact us at info@globalxetfs.com.

How to contact our EU / EEA and UK representatives:

We have appointed Grant Thornton as our EU/EEA/UK privacy representatives in compliance with both EU GDPR Article 27 and UK GDPR Article 27.

If you are based in the EU/EEA or UK, Grant Thornton gives you an easy way to exercise your GDPR Privacy related rights such as:

• Your right to be informed of what we do with your data
• Your right of access to your data
• Your right to rectify your data
• Your right to erasure (right to be forgotten)
• Your right to restrict processing
• Your right to data portability
• Your right to object to processing
• To exercise your rights in relation to automated decision making and profiling

If you would like to contact us via our representative, please email

• EU/EEA GDPR Data Subjects: Email EU/EEA GDPR Dataeurepresentative.globalx@ie.gt.com.
• UK GDPR Data Subjects: Email UK GDPR Dataukrepresentative.globalx@ie.gt.com.

You also have the right to lodge a complaint with the relevant supervisory data protection authority. We hope we can deal with any complaint in advance of you taking this action. Should you wish to lodge a complaint directly with the supervisory authority in your region please find contact details https://edpb.europa.eu/about-edpb/about-edpb/members_en

Updates

Our privacy policy may change from time to time and all updates will be posted on this page. If you have questions about this privacy policy, you should contact us via telephone at 1-888-493-8631 or info@globalxetfs.com.

Carefully consider the funds’ investment objectives, risk factors, charges, and expenses before investing. This and additional information can be found in the funds’ summary or full prospectus, which may be obtained by calling 1-888-493-8631 or by visiting globalxetfs.com. Please read the prospectus carefully before investing.