Globality Privacy Notice

We at Globality know you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Notice will explain how our organization uses the personal data we collect from you when you use our website and Platform.

By using or accessing any Globality Services, you acknowledge that you accept the practices and policies outlined in this Privacy Notice and hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of Globality’s Services is at all times subject to the Terms of Use, which incorporates this Privacy Notice. Any terms we use in this Privacy Notice without defining them have their definitions provided in the Terms of Use.

What does this Privacy Notice cover?

This Privacy Notice covers our treatment of personally identifiable information (“Personal Information”) that we gather when you access or use our Services, but this Privacy Notice does not cover the practices of companies we don’t own or control or people we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services to personalize, provide, and improve our Services; to allow you to set up a user account and profile; to contact you and allow other users to contact you; to fulfill your requests for certain products and services; and to analyze how you use the Services. In certain cases, we may share some Personal Information with third parties, but only as described below.

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of eighteen. If you are under eighteen years of age, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from anyone under age eighteen, we will delete that information as quickly as possible. If you believe that anyone under eighteen years of age may have provided us personal information, please contact Globality InfoSec through our contact page.

What data do we collect?

Globality collects two types of data from all users: Personal Information (which includes personally identifiable information) and anonymous Platform and website usage metrics.

The following personally identifiable information is collected from all users: first and last name; email address; IP address, cookies, and/or device identifiers; geolocation data; company name and role. Phone number, physical address, and images and pictures are only collected if provided by the user. We also collect learning and employment records for Globality employees only.

How do we collect data?

Information provided by users

Globality receives and stores any information you knowingly provide to us. For example, through the registration process, account settings, and/or employee onboarding, we may collect Personal Information such as your name, email address, phone number, and third-party account credentials (for example, your log-in credentials for other third-party sites). If you provide your third-party account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand that some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions and that this Privacy Notice covers Third Party Account Information transmitted to our Services. Certain information may be required to register with us or to take advantage of some of our features.

We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may email you about your use of the Services. We may also receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Services. If you do not want to receive communications from us, please indicate your preference by contacting Globality InfoSec through our contact page.

Information collected automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device. This information may include your IP address, geolocation data, device identification, cookie information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. For more information about cookies, please reference the Cookie Policy below.

If you click on a link to a third-party website or service, a third party may transmit cookies to you. Again, this Privacy Notice does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services—for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. 

We use analytics and tracking tools to help analyze how our users use the Services. Google Analytics uses cookies to collect information such as how often our users visit the Services, what pages they visit, and what other sites they used before coming to the Services. We may use the information we get from these analytics and tracking tools to improve our Services. These analytics and tracking tools collect the IP address assigned to you on the date you visit the Services, but these tools do not collect your name or other Personal Information. We do not combine the information generated through the use of analytics and tracking tools with any Personal Information. Although analytics and tracking tools plant a persistent cookie on your web browser to identify you as a unique user the next time you visit the Services, only the hosts of these analytics and tracking tools (in this case, Globality) can use the cookie. Globality’s ability to use and share information we collect about your visits to the Services is restricted by our own Terms of Use and this Privacy Notice. If you would like additional information about the analytics and tracking tools we use, please contact Globality InfoSec through our contact page. Finally, you can opt out of these analytics and tracking tools.

Information collected from other websites and Do Not Track policy

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain elements of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

How do we use your data?

Globality primarily collects user data to operate Globality’s business and provide the Services. We may use your data to authenticate access to an account, communicate with you about your account, match user projects with service providers, and generally enable your usage of the Services and the Globality Platform. Globality may use your data to send you information and updates about our Services that are relevant to you. The data we collect may also be used to manage Globality’s business needs, such as monitoring, analyzing, and improving the Services.

We may use your data to comply with our obligations under applicable laws and regulations, enforce Globality’s Terms of Use, or respond to your requests (such as GDPR or CCPA data subject right requests).

Globality neither rents nor sells to anyone your Personal Information in personally identifiable form. We may share your Personal Information with third parties as described in this section.

De-identified Personal Information

We may de-identify your Personal Information so that you are not identified as an individual, and we may provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to partners (or allow partners to collect such information) in a manner that would identify you as an individual person.

Affiliated businesses

In certain situations, businesses or third-party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with Globality). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such a transaction or service. One such service may include your ability to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third-party account. We have no control over the policies and practices of third-party websites or businesses concerning privacy or anything else, so if you choose to take part in any transaction or service related to an affiliated website or business, please review all such businesses’ or websites’ policies.

Agents

We employ other companies and people to perform tasks on our behalf, and we may need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Note that an “agent” may also be considered a “partner” in certain circumstances and would be subject to the terms of the “Information that’s been de-identified” section.

User profiles and submissions

Certain user profile information—including your name, location, and any video or image content that a user has uploaded to the Services—may be displayed to other users to facilitate user interaction within the Services or address your request for our Services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.

Business transfers

We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. If we (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party. In these cases, we will notify and inform all users prior to the asset transfer completion.

Cross-border transfers of Personal Information

We are a global corporation with operations in over forty-five countries, and we have developed global data security practices designed to ensure that your Personal Information is appropriately protected. Please note that Personal Information may be transferred, accessed, and stored globally as necessary in accordance with this privacy policy.

Globality is certified under the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information. Pursuant to this certification, we agree that transfers of Personal Information from the European Economic Area (“EEA”) will be transferred and processed pursuant to the Privacy Shield Framework for the relevant Services. When conducting those activities on behalf of our EEA customers, we hold and/or process Personal Information the EEA customer provided at the direction of that customer. We will then be responsible for ensuring that third parties acting as agents on our behalf do the same.

With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, we are subject to the U.S. Federal Trade Commission’s regulatory enforcement powers.

Protection of Globality and others

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Globality, our employees, our users, or others.

How do we store your data?

We enforce strict security practices and maintain technical and physical security measures designed to protect your personal data against unauthorized access and misuse. Globality securely stores your data using AWS and fully encrypts all data in transit and at rest. Other security measures include firewalls, physical access controls, and round-the-clock security monitoring. For more information regarding Globality security practices, please reference our Security & Trust page. While we are fully dedicated to securing Globality systems, you are responsible for preventing unauthorized access to your account and Personal Information by appropriately selecting and protecting your password and/or other sign-on mechanisms.

Globality currently retains Platform data, including user information such as name and email address, for an indefinite period. This data is anonymously used to enhance the Services. However, users can request that their personal data be deleted per GDPR and CCPA guidelines by contacting Globality InfoSec through our contact page with their request.

While we continually work to protect the privacy of your account and other Personal Information we hold in our records, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

Marketing

Globality would like to send you information about our Services and updates that we think you might like. You have the right at any time to stop Globality from contacting you for marketing purposes by contacting Globality InfoSec through our contact page and opting out of marketing communications.

What are your data protection rights?

Every user is entitled to the following rights, free of charge:

  • The Right to Access— You have the right to request copies of your personal data that Globality currently stores and processes.
  • The Right to Rectification— You have the right to request that Globality correct or complete any information you believe is inaccurate.
  • The Right to Erasure— You have the right to request that Globality erase your personal data, under certain conditions.
  • The Right to Restrict Processing— You have the right to request that Globality restrict the processing of your personal data, under certain conditions.
  • The Right to Object to Processing— You have the right to object to Globality’s processing of your personal data, under certain conditions.
  • The Right to Data Portability— You have the right to request that Globality transfer the data that we have collected to another organization or directly to you, under certain conditions.
  • The Right to No Discrimination— Globality will not discriminate against users for exercising their data protection rights.

Globality will respond to all requests within thirty calendar days. For requests that are complex or otherwise difficult to resolve in thirty calendar days, Globality will notify the requester that it may take up to an additional sixty calendar days to resolve the request.

The information you can view, update, and delete may change as the Services change. Please note that we may use aggregated data derived from or incorporating your Personal Information after you update or delete it, but we will not use this data in a manner that would personally identify you.

Under California Civil Code Sections 1798.83–1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; to submit such a request, please contact us at infosec@globality.com.

Cookie Policy

“Cookies” are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Globality uses cookies to allow us to recognize your browser or device; we also use cookies to determine how and when pages and features in our Services are visited and by how many people. When you visit our websites, we may automatically collect information from you through cookies or similar technologies.

We may deliver a file to you through the Services (known as a “web beacon”) from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting to us and to advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from ad networks’ servers, these companies can view, edit, or set their own cookies—just as if you had requested a web page from their site. You may be able to opt out of web beacon tracking conducted by third parties through our Services by adjusting the Do Not Track settings on your browser; please note that we don’t control whether or how these third parties comply with Do Not Track requests.

How do we use cookies?

Globality uses cookies in a variety of ways to improve your experience on our website, including keeping you signed in, improving Services based on anonymous Platform usage metrics, and mitigating risk and preventing potential fraud.

What types of cookies do we use?

Globality uses the following categories of cookies:

  • Essential — Globality uses these cookies, web beacons, or other similar technologies to provide Globality Services. This includes technologies that enable Platform access, identify anomalous behavior, and perform other tasks.
  • Functionality — Globality uses these cookies so that we can recognize you on our website and remember your previously selected preferences. These preferences could include your location and your preferred language. A mix of first-party and third-party cookies are used.
  • Performance — Globality uses these cookies to assess and improve the performance of our website and Platform; as part of our analytic practice, this includes improving our user experience and interaction.

Any Personal Information that Globality collects through Functionality or Performance cookies is based on your consent obtained when you visit Globality’s website or sign up for Globality Services. You can withdraw this consent by managing or disabling your cookies as noted below.

How to manage cookies

You can configure your browser not to accept cookies or remove them entirely. Please note that removing cookies may limit our website’s functionality.

Privacy policies of other websites

Globality’s website contains links to other third-party websites. Globality’s Privacy Notice only applies to our website. If you click on a link to a third-party website from Globality’s page, you should familiarize yourself with the third-party website’s privacy policy.

Changes to our Privacy Notice

We constantly try to improve our Services, so we may change this Privacy Notice at any time. Any update to Globality’s Privacy Notice will be reflected in this section. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding the notices.

Globality regularly reviews this Privacy Notice and publishes any updates on this web page. This Privacy Notice was last updated on October 15th, 2019.

How to contact us

If you have any questions about Globality’s Privacy Notice or collection of data or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Globality InfoSec Contact Page

Call us (US toll-free) at: +1 (844) 257-0899  

How to contact the appropriate authority

Should you wish to report a complaint, you may contact the relevant supervisory authority.

For GDPR concerns, please contact the Information Commissioner’s Office through its website: https://ico.org.uk/.

For CCPA concerns, please contact the California Attorney General’s Office through its website: https://oag.ca.gov/consumers.