Privacy Policy

Thank you for visiting our website at www.guotaiglobal.com (the "Site"), operated by Guotai Global LLC (the "Company"). Guotai Global is committed to treating the personal and corporate information of our Site users, customers, and vendors with respect and care.

We have updated our Privacy Policy and improved our privacy practices to better safeguard your data. This Site also uses cookies to personalize your experience. By continuing to use our Site, you accept the terms of this Privacy Policy, our Terms of Use, and our cookies policy.

This Privacy Policy (together with our Terms of Use and any other policies referenced) sets out how we collect and process any personally identifiable information — such as your name, email, address, and financial account information — that we collect from you, or that you provide to us. If you are a resident of the European Economic Area ("EEA"), this Privacy Policy also outlines additional rights and protections that apply to our collection and processing of your personal information.

As our services evolve, we may amend this Privacy Policy from time to time. The effective date appears at the top of this page. We encourage you to check our Site regularly to review the current Privacy Policy and any changes that may have been made.

By providing your Personal Data to us in any format (e.g., via email, telephone, fax, or in person) and/or by continuing to use any of our services or visiting our Site, you accept and consent to the practices described in this Privacy Policy.

1. What Personal Data We Collect

We collect personal information that you enter on our Site, or otherwise volunteer to us when you contact us — for example, to make purchases or request information. You can choose not to provide certain information, but doing so may limit the features or services we can provide.

For purposes of this Policy, "Personal Data" means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data, or from that data and other information in our possession. Personal Data can be:

• Factual — such as a name, address, email, phone, or date of birth
• Sensitive — such as financial account information, protected health or medical details, or information about racial or ethnic origin, political opinions, religious beliefs, physical or mental health, or sexual life
• Opinion — such as the results of a self-assessment

Guotai Global collects only the Personal Data that is relevant for the purposes for which it is requested. We do not use your Personal Data in any way that is incompatible with the purposes for which it was collected or to which you have consented.

You can visit our Site without telling us who you are or revealing any Personal Data. In some circumstances, however, we may ask you to submit Personal Data, which may include the following.

Information You Give Us

When you contact us through our Site or by corresponding with us by phone, email, or otherwise, or meet us at a Guotai Global event, we may collect Personal Data including:

• Contact information — name, address, email, and phone
• Financial information — credit card and account information collected when you purchase products or services
• Identification information — gender and date of birth
• For those considering careers with Guotai Global — professional information such as a resume or CV, salary history, education history, citizenship status, and position sought
• For current or prospective affiliates, suppliers, and subcontractors — information such as social security number, federal tax ID number, or other relevant data, as applicable

When considering an individual for employment, additional Personal Data may be collected as set forth in our Employee Privacy Policy.

Information We Collect About You

When you visit our Site, our web server automatically collects and stores the following:

• Technical information — IP address used to connect to the Internet, browser type and version, time zone setting, browser plug-ins, operating system, and platform
• Information about your visit — full URLs, clickstream to and through our Site (including date and time), pages viewed, page response times, download errors, duration of page visits, page interaction information (scrolling, clicks, mouse-overs), and methods used to browse away from the page

This information helps us improve our Site and your online experience.

Information We Receive from Other Sources

We receive information about you from third parties who operate other sites or services we use to provide our products and services. These include business partners, promoters, affiliates, and sub-contractors in technical, payment, and delivery services; advertising networks; marketing analytics providers; and search information providers. We will notify you when we receive information about you from third parties and explain the purposes for which we intend to use it.

Cookies

Our Site uses cookies to personalize your experience and support analytics. You can control cookies through your browser settings.

2. How We Use Your Personal Data

Information You Give Us

We will use this information to:

• Provide you with the information, products, and services that you request
• Carry out our obligations arising from any contracts entered into between you and us, or between you and our promoters, affiliates, or distributors
• Contact you to provide information about other goods and services we (or our affiliates and third-party vendors) offer
• Notify you about changes to our service
• Comply with applicable laws and regulations
• Train staff and assure quality, and to record details about the products and services you order
• Make inquiries about you for credit-reference purposes
• Perform data analyses (including anonymization and aggregation of Personal Data)
• For prospective employees — respond to your job application and process your CV

Information We Collect About You

We will use this information to:

• Administer our Site and run internal operations — troubleshooting, data analysis, testing, research, statistical, and survey purposes
• Improve our Site and ensure that content is presented in the most effective manner for you and your device
• Keep our Site safe and secure

Information We Receive from Other Sources

We will combine this information with information you give us and with information we collect about you. We will use this combined information for the purposes set out above.

3. How We Share Your Personal Data

We do not sell your Personal Data to any third parties. We partner with third parties to provide some of the services and products available on our Site and at our events. We sometimes disclose your Personal Data to those third parties, and they sometimes collect your Personal Data and provide it to us.

All such third parties use your Personal Data only on behalf of Guotai Global and under our instructions. Guotai Global takes reasonable steps to ensure these third parties use your Personal Data only for the purposes for which they have been engaged by us, and that they agree to protections no less protective than those set out in this Policy.

By visiting our Site or attending our events and sharing your Personal Data, you agree that we have the right to share your information with selected third parties, including:

• Sales — business partners, promoters, affiliates, distributors, suppliers, and sub-contractors, for the purpose of fulfilling your requests to purchase goods and services
• Marketing — business partners, promoters, affiliates, distributors, suppliers, and sub-contractors, for the direct marketing of goods and services that may be of interest to you
• Cloud services — providers of cloud storage services
• Contractual performance — partners and sub-contractors involved in the performance of any contract we enter into with you, or that they enter into with you on behalf of Guotai Global
• Web analytics — analytics and search engine providers that assist us in improving and optimizing our Site

Other Circumstances of Disclosure

We may also disclose your Personal Information to third parties in the following circumstances:

• If we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer as part of the transaction
• If we sell all or substantially all of our assets to a third party, in which case Personal Data about our customers will be one of the transferred assets
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, to enforce our terms of use and other agreements, or to protect the rights, property, or safety of us, our customers, or others

Whenever we share information with third parties, we take steps to ensure they have adequate measures in place to safeguard your Personal Data and that they are required to use it only for the intended purpose.

4. Storage of Your Personal Data

Guotai Global uses reasonable and appropriate measures to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction — taking into account the risks involved in the processing and the nature of the Personal Data we collect.

We will keep your Personal Data for as long as we need it, or as otherwise required by law, for the purposes set out above. The retention period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example, if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim.

You may unsubscribe from our online email updates and marketing by following the unsubscribe instructions in the body of any email we send you. We will take commercially reasonable steps to implement your unsubscribe requests promptly, but you may still receive promotional information from us by mail for up to 60 days, and up to 10 days for email. You may also continue to receive information from third parties to whom we have previously disclosed your Personal Data. When you unsubscribe from marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in the future.

5. Access to Other Websites

Our Site may include links to and from websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that they are not covered by this Privacy Policy. We are not responsible for the privacy practices of any third party or the content of linked sites, although we encourage you to read their privacy policies and terms before submitting any Personal Data.

6. Protecting Children's Privacy

We are strongly committed to protecting the safety and privacy of children. Our Site is not designed or intended for use by children under 13. We do not knowingly collect personal information online from children under 13 and have adopted measures to comply with the Children's Online Privacy Protection Act of 1998 ("COPPA"). Our Site may contain content that we believe is unsuitable for children under 13, and we encourage all parents to talk to their children about online safety and to monitor their children's use of the Internet.

7. Additional Policies in Compliance with EEA Privacy Laws

In addition to the policies described above, residents of the European Union or the EEA are afforded the following additional rights and protections under the General Data Protection Regulation ("GDPR"). The additional rights and protections in this section apply only to residents of the EU or EEA.

7.1 GDPR Definitions

• "Controller" means the Company, which determines the purposes for which, and the manner in which, any Personal Data is processed and used in its business
• "Processor" means any Person processing Personal Data
• "Person" means a natural person, corporation, association, organization, partnership, or other legal entity
• "Processing" is any activity that involves use of the Personal Data — including, without limitation, obtaining, recording, holding, organizing, amending, retrieving, using, disclosing, erasing, or destroying Personal Data, or transferring it to third parties

7.2 The Legal Basis for Processing Your Personal Data

To comply with the GDPR, we set out the legal basis for processing your Personal Data. Depending on the purpose, the legal basis will typically be one of:

• Our own legitimate business interests, or those of our third-party partners — such as direct marketing, allowing prospective employees to apply for jobs, handling inquiries from affiliates and customers, or other interests we have assessed and established
• The performance of a contract that we have in place with you
• Your consent, where appropriate
• Compliance with our legal obligations, including national security and law enforcement requirements

7.3 Where We Store Your Personal Data

The data we collect is stored on our servers or on servers provided by cloud-service providers, such as Amazon Web Services. If you are a resident of the EEA, your Personal Data may be transferred within or outside the EEA to areas where privacy laws may be less strict than in the EEA. By submitting your Personal Data, you agree to this transfer, storage, and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

The transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

7.4 Retention of Your Personal Data

In some cases, there is a legal requirement to keep Personal Data for a minimum period of time. Except in those circumstances, we do not keep your Personal Data for any longer than is necessary for the purposes for which it was collected or for which it is to be further processed.

7.5 Your Rights with Respect to Your Personal Data

Subject to certain exceptions, you have the following rights with respect to your Personal Data:

• To receive a copy of the Personal Data that we hold about you
• To request that any inaccurate or incomplete Personal Data be corrected or supplemented
• To have your Personal Data erased, unless we have a legitimate reason to retain it (for example, if we are required to retain it for legal reasons)
• To ask us not to process your Personal Data for a particular purpose, including for marketing

All of these rights are subject to certain conditions and exemptions. For example, Guotai Global will not be obligated to erase your Personal Data if we need to retain it to protect ourselves in the event of a legal claim. To exercise any of these rights, please submit a written request using the contact information below. The Company reserves the right to charge a fee in dealing with such requests as permitted by applicable law. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.

8. Conditions of Use and Changes to This Policy

If you visit our Site or attend our events, your visit and any dispute over privacy is subject to this Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the laws of the State of California.

If you have any concerns about our privacy practices, please contact us with a thorough description, and we will try to resolve them. As our business changes, our Privacy Policy and Terms of Use may change as well. We may email periodic reminders of our notices and conditions, but you should also check our Site regularly for recent changes. Unless stated otherwise, our current Privacy Policy applies to all information we hold about you and your account.

9. Contacting Us

This Site is owned and operated by Guotai Global LLC. If you have any questions or suggestions regarding this Privacy Policy or our privacy practices, please email us or contact us by mail.