Globality Privacy Policy

Category of Personal Data	Examples of Personal Data We Collect	Categories of Entities to Whom We Disclose this Personal Data:	Categories of Third Parties To Whom We Sell or Share this Personal Data:
Identifiers, such as Profile or Contact Data	First and last name Email Phone number Profile photo Unique identifiers such as passwords	Service Providers Globality Customers	Not sold or shared
Internet or Other Electronic Network Activity Information, such as Device/IP Data and Web Analytics	IP address Type of device/operating system/browser used to access the Services Web page interactions Referring webpage/source through which you accessed the Services Statistics associated with the interaction between device or browser and the Services	Service Providers Analytics Partners Advertising Partners	The information may be disclosed to or collected directly by these services (i.e., Google Analytics)
Professional or Employment-Related Data	Job title Employer	Service Providers Globality Customers	Not sold or shared
Geolocation Data	IP-address-based location information	Service Providers Globality Customers	Not sold or shared
Other Identifying Information that You Voluntarily Choose to Provide	Identifying information in emails or letters you send us	Service Providers	Not sold or shared

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us.
    • When you use our interactive tools and Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically.
    • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
    • If you use a location-enabled browser, we may receive information about your location.
• Public Records
  • From the government or other sources, including, in limited instances, publicly-available websites associated with our Suppliers.
• Third Parties
  • Vendors
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    • We may use vendors to obtain information to generate leads and create user profiles.
  • Advertising Partners
    • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing, and Improving the Services
  • Providing you with the products, services, or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics, and product development.
  • Personalizing the Services, website content, and communications based on your preferences.
  • Doing fraud protection, security, and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
• Marketing the Services
  • Marketing and selling the Services.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Globality or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
• Meeting Legal Requirements and Enforcing Legal Terms
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Globality or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Additionally, note that when you create a user account, your Profile Data may be visible to other users of the Services, such as employees of our Customers and Suppliers based on your user preferences and choices on the Platform.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services.
• Globality Customers. Globality Customers use our Services to obtain information on prospective Suppliers. To this end, to provide our Services, we disclose Personal Data of, for example, employees of Suppliers on our platform.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time. You can choose whether or not to accept Cookies by default through your internet browser’s settings or you can adjust your cookie preferences at any time by clicking the link on the bottom of the webpage.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies (e.g., Google Analytics) allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at at privacy@globality.com.

Special Information for Job Applicants

When you apply for a job with us, we may collect Personal Data from you, including:

• Personal Data you provide in connection with your application.
• Personal Data that you make available in your social media accounts.
• Personal Data about you that is available publicly.
• Personal Data that you authorize us to collect via third parties, including former employers or references.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your U.S. Privacy Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@globality.com. Exceptions to these rights may apply.

Access

You have the right to obtain information regarding the categories of Personal Data we collect, sell, share,  or disclose. That information is provided in the “Personal Data” section above. 

You also have the right to request access to the specific pieces of Personal Data Collected about you over the past 12 months and information regarding the source of that Personal Data, the purposes for which we collect it, and the third parties and service providers to whom we sell or disclose it. 

Deletion

You have the right to request that we delete the Personal Data that we have collected directly from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct the Personal Data that we have collected about you.

Personal Data Sales and Sharing Opt-Out and Opt-In

We do not engage in “sales” or “sharing” of your Personal Data. Internet or Electronic Network Activity Information. Under the CCPA, a business “sells” Personal Data when it discloses Personal Data to a third party for monetary or other benefit. A business “shares” Personal Data when it discloses Personal Data to a third party for the purposes of cross-context behavioral advertising. A company may be considered a third party either because we disclose Personal Data to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using Personal Data for purposes unrelated to the service it provides to us.

You have the right to opt out of our sale or sharing of your Personal Data to third parties. To exercise this right, please visit our Do Not Sell or Share My Personal Data webpage or contact us. Your right to opt out does not apply to our disclosure of Personal Data to service providers. To our knowledge, we do not sell the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

“Shine the Light” Law

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Data to third parties for their own direct marketing purposes. We do not share your Personal Data with third parties for those third parties’ direct marketing purposes

Other State Law Privacy Rights

Colorado, Connecticut, Utah, and Virginia

Residents of the states of Colorado, Connecticut, Utah, and Virginia have the following rights:

• Opt out of “sales” of Personal Data and use of their Personal Data for “targeted advertising,” as those terms are defined under applicable law. 
• Opt out of “profiling” under certain circumstances, as defined under applicable law. (Residents of Colorado, Connecticut, and Virginia only.)
• Confirm processing of and access to Personal Data under certain circumstances.
• Delete Personal Data under certain circumstances.
• Correct Personal Data under certain circumstances.

Residents of these states can exercise their rights by contacting us using the “Exercising Your US Privacy Rights” instructions below.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. Currently we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us at privacy@globality.com.

Exercising Your U.S. Privacy Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We will work to respond to your Valid Request within the legally applicable timeline.

You may submit a Valid Request using the following methods:

• Call us at: +1 (844) 257-0899
• Email us at: privacy@globality.com

If you are a resident of California, Colorado, or Connecticut, you may, under certain circumstances, authorize another individual or business, called an authorized agent, to make requests on your behalf. (Authorized agents in California must be registered with the California Secretary of State.)

Residents of Colorado, Connecticut, and Virginia have the right to appeal a denial of their request by contacting us as described in the notice of denial.

European Union and UK Data Subject Rights

EU & UK Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Globality will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@globality.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: In some cases, we may process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
  • Profile or Contact Data
  • Professional or Employment Related Data
  • Device/IP Data
  • Web Analytics
  • Geolocation Data
  • Other Identifying Information that You Voluntarily Choose to Provide
  • We may also de-identify or anonymize Personal Data to further our legitimate interests.
    Examples of these legitimate interests include (as described in more detail above):
  • Providing, customizing and improving the Services.
  • Marketing the Services.
  • Corresponding with you.
  • Meeting legal requirements and enforcing legal terms.
  • Completing corporate transactions.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data to third parties.

EU & UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@globality.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Globality's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

Transfers of Personal Data are governed by Data Protection Agreements between Globality and Globality Customers. In addition, Globality remains committed to the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU.

On July 16, 2020, the Court of Justice of the European Union issued a judgment in the Schrems II case invalidating the EU-U.S. Privacy Shield as a compliance mechanism for transfers of personal data from the EU to the U.S. The U.S. Department of Commerce has stated that it will continue to administer the Privacy Shield, and individuals can still file complaints with the Federal Trade Commission (FTC) and/or local supervisory authorities. The FTC can still enforce the Privacy Shield against current and former participating companies. We remain committed to our obligations under the Privacy Shield, and will continue to protect our customers’ data in accordance with those obligations. For more information about the Privacy Shield Program, please visit www.privacyshield.gov.

Please contact us at privacy@globality.com with any questions or concerns relating to the Privacy Shield. If your Personal data was transferred from the EU, UK, or Switzerland to the United States, and you are not satisfied with our response, Globality has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the EU-US Privacy Shield Principles. A resident of the European Union, UK or Switzerland whose enquiry has not been satisfactorily addressed may contact either the EU DPA panel at http://ec.europa.eu/justice/data-protection/bodies/authorities/third-countries/index_en.htm or the Swiss FDPIC at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html to resolve disputes pursuant to the EU-US and Swiss-US Privacy Shield Principles.

Changes to this Privacy Policy

We constantly try to improve our Services, so we may change this Privacy Policy from time to time. Any update to Globality’s Privacy Notice will be reflected in this section. Please note that if you have 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 Policy and publishes updates on this web page. This Privacy Policy was last updated on May 2023.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• Call us at: +1 (844) 257-0899
• Email us at: privacy@globality.com

Submit a form at this address: Contact Page

If you are located in the European Union, you may use the following information to contact our European Union-Based and UK Member Representatives:

• EU Representative
  • Osano International Compliance Services Limited
    ATTN: CMVO
    3 Dublin Landings
    North Wall Quay
    Dublin 1
    D01C4E0
• UK Representative
  • Osano UK Compliance LTD
    ATTN: CMVO
    42-46 Fountain Street
    Belfast
    Antrim
    BT1 - 5EF
• Osano has been appointed as Globality's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union and its counterpart under UK legislation. If you are in the European Economic Area or the UK, Osano can be contacted on matters related to the processing of personal data. To make such an inquiry, please contact Osano using the above contact.

You may print a copy of this Privacy Policy by clicking here.