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Privacy Policy


 

GLOBO Language Solutions, LLC (“GLOBO,” “our,” “we”) is committed to safeguarding the privacy of confidential and personal information, including personal data relating to individuals who may be customers, website visitors, clients of our customers, employees, and contractors. When you visit our website or the GLOBO HQ platform, you trust us with your personal information and we take your privacy very seriously.  This privacy notice describes how we handle and protect individual personal data, including explaining what information we collect, how we use it, and what rights you have in relation to it. 


This Privacy Policy applies to information collected through GLOBO’s website, social media sites, mobile applications, the GLOBO HQ Platform, and/or any related services, sales, marketing or events (we refer to them collectively in this Privacy Policy as the “Sites”).  This Privacy Policy applies to the public facing GLOBO website, as well as the product(s) that customers and their clients will use pursuant to a contract for language services to be provided by GLOBO.  Where applicable, discussions have been made in this Privacy Policy. 

 

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us. By using our Sites, you are agreeing to the terms of this Privacy Policy, and any information you submit through these Sites could be collected, processed, used and/or disclosed in accordance with these terms.  

 

The policies and disclosures contained in this Privacy Policy may change over time, so please check this webpage, www.helloglobo.com periodically for changes.

 

If you have any questions about GLOBO’s Privacy Policy and/or data collection practices, please contact Jonathan De Jong, Vice President, Engineering at jonthan@helloglobo.com.


Who We are and What Services Does GLOBO Provide?


GLOBO provides multi-channel translation and interpretation technology services to a variety of industries including, healthcare, insurance, finance and the government.  GLOBO’s full range of language services include, On-Demand Telephone Interpretation, Video Remote Interpretation, On-Site Interpretation, Document Translation, On-Demand Text Translation, Transcreation and Fluency testing (“Services”). 

 

What Data Do We Collect and How Do We Collect It?

We gather various types of information, including, in some instances, information that identifies or may identify you as an individual (“Personal Information”).  


Information You Provide To Us:


We collect personal information that you voluntarily provide to us. The Personal Information that we collect depends on the context of your interactions with us and our different Sites, the choices you make, and the product features you use.  


From the Public Website: We may collect any Personal Information that you choose to send to us or provide to us through our website, for example, on our “Request a Demo” online form, or if you register for a GLOBO Webinar.  If you contact us through the GLOBO website, we will keep a record of the correspondence and we will keep the Personal Information you provide to us.  This could include name, address, contact information and/or payment information.


From the Product(s) and Services:  We receive and store the information that you request with respect to Services provided by GLOBO and/or when using the Services pursuant to a contract with GLOBO.  This applies to not only GLOBO’s customers, but also any clients of those customers who may access GLOBO’s products as a client of one of GLOBO’s customers. The types of information we may collect directly from our customers and their users may include: first and last names, usernames, passwords (including password hints and similar security information used for authentication and account access), email addresses, postal address, phone number, medical identification numbers, transactional information, as well as any other contact or other information customers, and/or customers’ users, choose to provide us or upload to our system in connection with the Services GLOBO provides.  


Payment Data: We also collect data necessary to process your payment if you make a purchase, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your question.  


All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.


Information that We Automatically Collect:


GLOBO may collect information relating to your device and/or usage information.

When you use the Public Website: When you visit the website, we collect certain information related to your device, such as your device’s IP address, referring website andwhat pages your device visited.

When you use our Product(s) and Services:  GLOBO keeps track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers or other devices, the time a user logged on, and performance metrics related to their use of the Services.  We also log information about our customers and sometimes their users when they use one of our Services.  GLOBO also performs geo-location of users accessing the application as well as IP addresses. We use various technologies to collect information which may include saving cookies to users’ computers.

Mobile Device Access and Data:  We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, camera, microphone, and other features.  If you wish to change our access or permissions, you may do so in your device settings.  We may request to send you push notifications regarding your account or the mobile application.  If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

 

Information Collected from Other Sources

We may collect limited data from public databases, marketing partners, and other outside sources.  We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties.  Examples of information we receive from other sources include: social media price information; marketing leads and search results and links, including paid listings (such as sponsored links). Additionally, we gather information about phone numbers that call into our services, and numbers we place calls to.    


Information Use, Sharing and Disclosure

When you access or use our Services, we collect, use, share and otherwise process your personal information for the purposes described in this Privacy Policy.  We rely on a number of legal bases to use your Personal Information in these ways. These legal bases include where:


  • Necessary to perform the contractual obligations in our Terms of Use and Scope of Services forms, and in order to provide Services to you;
  • You have consented to the processing, which you can revoke at any time;
  • Necessary to comply with a legal or regulatory obligation, court order, or to exercise or defend any impending or asserted legal claims;
  • Necessary for the purpose of our ,or a third party’s legitimate interest, such as those of visitors, customer or partners;
  • Occasionally necessary to protect your vital interest or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).

How Do We Use the Data We Collect?

GLOBO processes your information for purposes based on legitimate business interests, for legitimate business purposes, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.


We use Personal Information collected via our Sites for a variety of business purposes described below.  We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.  


We use the information we collect or receive as follows:

  • We use your Personal Information to send you product, service and new feature information and/or information about changes to our terms, conditions and policies.
  • We use your Personal Information to provide you with access to our Services and technology platform.
  • We may use your information to request feedback and to contact you about your use of our Sites.
  • We may use your information in order to enable user-to-user communications with your consent.
  • If you choose to link your account with us to a third party account, we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
  • We may use your Personal Information for internal operations such as troubleshooting, testing, statistical and survey purposes and to ensure that our information is being presented in the best manner possible.
  • For Purposes Made Clear upon Submission.  GLOBO may use your information for a purpose that was made clear when the information was given.  For example, if an individual requested a demo or information about GLOBO’s Services.
  • GLOBO may use information it collects from customers and their users in connection with the Services we provide for a range of reasons, including: to set up a user account; to provide user support; to provide, operate and maintain the Services; process and complete transactions, including invoicing; manage customer’s use of the Services and respond to inquiries and comments; send customers technical alerts and updates; investigate and prevent fraudulent activities, unauthorized access and other improper activities; and for other purposes about which we notify customers and users.
  • To transfer any necessary information to a GLOBO Customer or a customer’s client in connection with the Services rendered by GLOBO.
  • We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

We use your Personal Information in this context based on the contract that we have in place with your or our legitimate interests.  



How Do We Share and Disclose Information to Third Parties?

GLOBO will only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.


We may process or share data and Personal Information on the following legal bases:

  • Consent: We may process your data if you have given us specific consent (or provided consent as a result of your relationship with GLOBO’s Customer pursuant to which GLOBO is performing its Services) is given as a result to use your Personal Information in or for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.  Likewise, if you are a client of one of GLOBO’s customers, we may process your personal information to fulfill the terms of the contract we have entered into with the customer. 
  • Legal Obligations:  We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena (including in response to public authorities to meet national security or law enforcement requirements).  We may also disclose your personal information as evidence in litigation in which we are involved.
  • Vital Interests and Keeping our Services Safe and Secure: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies (including privacy and security), suspected fraud, situations involving potential threats to the safety of any person, and illegal activities.

More specifically, we may need to process your data or share your Personal Information in the following situations:

  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.  Affiliates include any parent company, subsidiaries, joint venture partners of other entities/organizations that we control or that are under common control with us. 
  • Vendors, Consultants and Other Service Providers: We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf.  These companies include, for example, our payment processing providers, product feedback and marketing services, website analytics companies (i.e. Google Analytics), CRM service, and others.
  • Business Partners:  We may share your information with our business partners to offer you certain products, services or promotions.

How Long Do We Keep Your Information?

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including any executed agreements with customers, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, compliance or other legal requirements).


When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any other further processing until deletion is possible.


Security: How Do We Keep Your Information Safe?

We aim to protect your Personal Information through a system of organizational and technical security measures.


We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information we collect, process and/or hold in our records from loss, misuse and unauthorized access, disclosure, alteration and destruction.  However please also remember, that we cannot guarantee that the interest itself is 100% secure. Unfortunately, no company or service can guarantee complete security.  Although we will do our best to protect your personal information, unauthorized entry or use, hardware or software failure and other factors may compromise the security of user information at any time.  Therefore, transmission of personal information to and from our Sites is at your own risk.  Moreover, you should only access the services within a secure environment, such as selecting and protecting your password appropriately, limiting access to your computer or device and browser, and by signing off after you have finished accessing your account.


Do We Use Cookies and Other Tracking Technologies?

We may use cookies and other tracking technologies to collect and store your personal information.  Our Cookie Policy is set forth below.  


Cookie Policy

A cookie is a small piece of data (text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as a language preference or login information.  GLOBO uses these first party cookies.  Other cookies, which are cookies from a domain different from the domain of the website you are visiting are also used by GLOBO.  These are third party cookies.  These are used for marketing and advertising efforts.  


We use cookies and other tracking technologies for the following purposes:


  • Assisting you in navigation;
  • Assisting in subscribing to our services, login, and your ability to provide feedback
  • Analyze your use of our products and services; and 
  • Assisting with our promotional and marketing efforts (including behavioral advertising)

We classify the cookies that we use in the following categories:


  • Strictly Necessary Cookies
  • Performance Cookies
  • Functional Cookies
  • Targeting Cookies

Strictly Necessary Cookies:  These cookies are necessary for the website to function and enable you to move around the website and use its features.  These cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.    You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.


Performance Cookies:  These cookies are used for internal purposes and allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site and how visitors are using the site. They also enable us to test different design ideas for particular pages.Sometimes we contract with independent research companies to perform these services for us and when this is the case, these cookies may be set by a third party company.   


Functionality Cookies: Functionality Cookies record information about choices you have made and allow us to tailor the website to your preferences.  


Targeting Cookies: To support our efforts, we sometimes embed photos, video and other content from social media websites such as YouTube, Facebook, Google and Twitter. Pages with this embedded content may present cookies from these websites. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.  GLOBO does not control Third Party cookies. If you do not allow these cookies, you will experience less targeted advertising.


Cookies may be placed on your computer and/or mobile device by both us and by third parties with whom we have a relationship, such as our analytics services.  If you prefer not to receive cookies on this website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. If you have set your browser to not allow cookies, you will still be able to access the website; however, this may affect your full usability of this website.


Third Party Analytics:  

On some of our Sites, we also may utilize third party web analysis services provided by companies such as Google, to better understand your use of the Sites and services.  These services collect information such as how often users visit the Siets, what pages they visit and what other sites they used prior to visiting.  They use the data collected to track and examine the use of the Sites, to prepare reports on its  activities and share them with other third party ervices.  These services may use the data collected on the Sites to contextualize and personalize ads on its own advertising network.  The ability of these services to use and share information they collect about your visits to the Sties is restricted by the Google Terms of Use and privacy policies of these entities.


Collection of Information from Minors

GLOBO does not knowingly collect data from or market to children under 18 years of age.  


We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are a parent or guardian of such a minor and consent of such minor dependents’ use of the Sites. If we learn that Personal Information from users less than 18 years of age has been collected, and no guardian consent was provided, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under the age of 18, please contact us at jonathan@helloglobo.com.



What are Your Privacy Rights?

In short, you may review, change or terminate your account at any time. 


Account Information


If you would like to review or change the information in your account at any time, or terminate your account, you can contact us using the contact information provided in this Privacy Policy or log into your account settings and update your user account.  Upon request to terminate your account, we will deactivate or delete your account and information from our active databases.  However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal or regulatory requirements. 

Cookies and Similar Technologies


Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.  If you choose to remove cookies or reject cookies, this could affect certain features or services to our Sites.  


Opting out of Email Marketing


You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.  You will then be removed from the marketing email lists.  However, we will need to send you service-related emails that are necessary for the administration of your account.  


Residents of the European Economic Area


If you are a resident in the European Economic Area or in the United Kingdom , please see the section below headed, “European Economic Area Additional Information” for further information on your privacy rights regarding personal information.


California Residents


California residents have specific rights under the California Consumer Privacy Act (“CCPA”).  For more information and to exercise your rights, please see the section headed, “The California Consumer Privacy Act” below.  


Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  Certain states and jurisdictions, such as California and Delaware, require GLOBO to indicate whether it honors DNT settings in your browser concerning targeted advertising.  GLOBO adheres to the standards set forth in this Privacy Policy and does not monitor or respond to DNT browser requests.  


The California Consumer Privacy Act

This section applies to California residents.  Under the California Consumer Privacy Act (“CCPA”) California residents have certain rights regarding the personal information that businesses have about them.  This includes the right to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.  For purposes of this section, “Personal Information” has the meaning given in the CCPA, but does not include information exempted from the scope of the CCPA.


Personal Information We Collect


GLOBO collects the following information on contracted contacts, (i) identifiers, such as name, company address, email, phone number, and contact information on the primary contact and billing contact for the contract; (ii) commercial information such as a record of the services purchased or demos requested; and (iii) internet or other electronic network activity such as usage information, IP address, cookie information, and customer feedback.  In pursuit of performing the Services, the information collected is variable and configurable, and could include MRN and intake questions.


Why Do We Collect Your Personal Information


GLOBO uses identifiers to provide the services requested, such as to fulfill a request for a demo or provide you with information about our services.  We use identifiers and commercial information for general website administration and maintenance such as record keeping, troubleshooting, data analysis, testing and survey responses.  WEeuse identifiers, commercial information and internet or other electronic network activity for trend monitoring, marketing, and advertising, as well as to ensure Site security.


How Do We Collect Your Personal Information


We collect identifiers directly from you.  We collect internet or other electronic network activity from your usage of the GLOBO Sites.


With Whom Do We Share and Sell Your Personal Information


GLOBO does share Personal Information as necessary for certain business purposes as defined in the CCPA.  This would include, (1) sharing identifiers, commercial information and internet or other electronic network activity with providers of payment processing; (2) customer relationship management; (3) providing Services to the Customers’ clients; (4) consulting; (5) email; (6) fulfillment of any agreement or contract to perform the Services; and (7) product feedback.


GLOBO does not sell Personal Information in exchange for any monetary consideration.  We do, however, share Personal Information for other benefits that could possibly be deemed a “sale” as defined by the CCPA (Cal. Civil Code 1978.140 (t) (1)).  For example, we use services that help deliver interest-based ads to you, by collecting information from our website users.  

Rights of California Residents


As a California resident you have the rights identified below as specifically identified in the CCPA.  These rights are not absolute and all requests will be processed in accordance with the law. 

  • Right to Request Disclosure.  You can request the following information about what categories of Personal Information GLOBO has sold or disclosed for a business purpose about you, and the categories of third parties to whom the Personal Information was sold or disclosed.  Additionally, you have the right to request disclosure of specific pieces of information.The following is a list of the information that you can include in your request:
    • The categories of Personal Information that GLOBO has collected about you.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • The specific pieces of Personal Information that GLOBO has collected about you.
    • Whether GLOBO disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information that GLOBO disclosed.
    • Whether GLOBO sold your Personal Information for a business purpose, and if so, the categories of Personal Information that was sold, as well as the categories of third parties to whom GLOBO sold the information.

  • Right to Request Deletion. You have the right to request that GLOBO delete any Personal Information about you that GLOBO collected from you.  Please note that there are exceptions that apply to this situation wherein GLOBO would not be required to fulfill such a request to delete information.  For example, when the deletion of information would create problems with the completion of a transaction or compliance with a legal or regulatory obligation.

  • The Right to Non-Discrimination.  GLOBO will not discriminate against you (for example,  by denying services or providing a different level of quality of services) for exercising any of the rights afforded to you under the CCPA.  This memes that we will not penalize you for exercising your rights set forth above. 

  • The Right to Opt-Out of Sale:  While GLOBO does not sell Personal Information in exchange for any monetary consideration, we do share Personal Information for other benefits that could possibly be deemed a “sale” as defined by the CCPA (Cal. Civil Code 1978.140 (t) (1)).  For example, we use services that help deliver interest-based ads to you, by collecting information from our website users.   You have the right to opt out of this “sale” by directing GLOBO not to sell your information.  Moreover, with respect to cookies, you can always customize your settings at any time.

How Do You Exercise Your Rights:  


If you are a California resident and would like to make a request under the CCPA, please submit your request using the contact information below.  We are committed to resolve any questions or complaints about your privacy in accordance with the CCPA.  


European Economic Area Additional Information

The United States, the European Economic Area, and other countries all have different laws regarding privacy and data security.  It is possible that if your Personal Information is moved from one country to another that the laws in your home country are different from the laws in the country where the information was moved.  


If you are a European visitor or customer, to the extent that GLOBO is deemed to process your personal data, it relies on the following legal grounds: (1) your consent; (2) to perform a contract between you and us; (3) to comply with a legal obligation; or (4) where we have a legitimate interest to do so, balancing this interest against your interests and fundamental rights.  These legitimate interests are administrative functions within GLOBO, marketing activities, and complying with your request for information.


Access, Correction and Deletion


If you reside in the EEA, you may exercise your personal data rights under GDPR through the contact information shared below.  Specifically, GLOBO would like to make sure you are aware of all of your data protection rights which are set forth below, subject to the exceptions allowed by law:


  • The right to access - You have the right to request GLOBO for copies of your personal data.  
  • The right to rectification - You have the right to request that GLOBO correct any information you believe is inaccurate.  You also have the right to request our company to complete information you believe is incomplete.
  • The right to erasure - You have the right to request that GLOBO erase you personal data, under certain conditions and subject to our need to retain certain information for legal or other purposes.
  • The right to restrict processing - You have the right to request that GLOBO restrict the processing of your personal data under certain conditions.
  • The right to object to processing - You have the right to object to GLOBO’s processing of your personal data, under certain conditions.
  • The right to data portability - You have the right to request that GLOBO transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, GLOBO has one month to respond to you.  If you would like to exercise any of these rights, please use the contact information set forth below.


Changes to the Privacy Notice

We may update this Privacy Policy from time to time.  The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible.  If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.  We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.


Contact Us

 

If you have any questions or comments about the Privacy Policy, you may contact our Data Protection Officer (DPO), Jonathan DeJong, by email at jonathan@helloglobo.com or by phone at (800) 555-3010, or by post to:

GLOBO Language Solutions, LLC

Jonathan De Jong

145 Greenwood Avenue

Wyncote, PA 19095

If you have any further questions or comments about us or our policies, email us at Alison@helloglobo.com.