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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: 6/27/2025

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 an identified or identifiable 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 dataExamples of personal data we collectCategories of entities to whom we disclose this personal dataCategories 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, and browser used to access the Services
  • Web page interactions
  • Referring webpage or source through which you accessed the Services
  • Statistics associated with interactions between device or browser and the Services
  • Service providers
  • Analytics Partners
  • Advertising Partners
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 determine the retention period for each of the categories of Personal Data listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.

Categories of sources of personal data

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

Our Commercial or Business Purposes for Personal Data

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. We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:

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 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:

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:

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.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. If we collect personal information subject to the CCPA, that information, our practices, and your rights are described below.

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of certain information about our data collection, use, and disclosure. The table in the “Categories of Personal Data We Collect” section above summarizes the categories of personal information we collect; the categories of sources of that information; whether we disclose, sell, or share that information to service providers or third parties, respectively; and the criteria we use to determine the retention period for such information. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described above in “Our Commercial or Business Purposes for Processing Personal Data.”

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 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. 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 engage in “sales” or “sharing” of your Personal Data - e.g., 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 18 years of age.

"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

Residents of other states also have the following rights:

You may request to exercise these rights by contacting us using the “Exercising Your US Privacy Rights” instructions below. If we determine that you are a resident of a state that provides these rights, we will act on your request.

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:

Some states allow consumers, under certain circumstances, to authorize another individual or business, called an authorized agent, to make requests on your behalf.

Some states also give consumers the right to appeal a denial of their request by contacting us as described in the notice of denial. If you reside in a state that provides a right to appeal, we will note that in our correspondence responding to your request.

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”) or the U.K. equivalent 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.

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.

Transfers of Personal Data

We may collect, process, and store your information in the United States and other countries. The laws in the United States regarding the handling of this information may be different from the laws of your country. Any such transfers will be governed by standard contractual clauses or other safeguards, as required by relevant law and which can be found in our Data Processing Agreement, which is incorporated into this agreement and policy

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 June 2025.

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 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.

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