Globality
Privacy Policy

At Globality, Inc. (“Globality”), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Globality's Services is at all times subject to our Terms of Use. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

Last updated: 4/1/2024

Table of Contents

What this privacy policy covers

Globality is business of connecting procurement and business users (“Globality Customers”) with those companies or entities that they select through the Globality platform for their sourcing needs (“Suppliers”). This Privacy Policy covers how we treat Personal Data that we gather when you, including our Suppliers, access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover how we treat Personal Data that we process as a processor or service provider when providing services to our Customers, or the practices of companies we don’t own or control or people we don’t manage.

Personal data

Residents of certain states have the right to obtain information regarding the categories of Personal Data we collect, sell, share, or disclose, the categories of sources of that data, the business purposes for which we collect it, how long we retain it, and the categories of entities to whom we disclose it. That information is provided in this section and the following section, “How We Disclose Your Personal Data.” 

Categories of personal data we collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

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)
  • 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

  • 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.

Other state law privacy rights

Colorado, Connecticut, Florida, Oregon, Texas, Utah, and Virginia

Residents of the states of Colorado, Connecticut, Florida, Oregon, Texas, 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, Florida, Oregon, Texas, 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 Colorado, Connecticut, Florida, Oregon, Texas, and Virginia only.)
  • Request list of specific third parties (other than natural persons) to which Personal Data has been disclosed. (Oregon only.)

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

European Union 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.

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:

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.