Globiana Privacy Policy

Last modified: May 25, 2018

Your Privacy Matters

Globiana’s mission is to provide support to the globally mobile and international employees to allow them to be more productive and successful. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.
This Privacy Policy applies when our Services (described below) are made available to you as a benefit sponsored by your employer.
Our Privacy Policy applies to any Member or Visitor to our Services.

Services

This Privacy Policy applies to your use of our Services.

This Privacy Policy applies to Globiana.com, MyGlobiana.com, Globiana-branded apps, and any other Globiana-related sites, apps, communications and services (“Services”).

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

Globiana (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

1. Data We Collect

1.1 Data Provided to us by your Employer

Registration

Your employer provides data necessary to create your account with us.

To create an account, we are provided data including your name, email address and/or phone number, your home country, your host country, your estimated date of relocation and the size of the family relocating with you.

Profile

We create your Globiana profile (a completed profile helps you get the most from our Services).

You don’t have to provide any additional information on your profile. Please do not post or add personal data to your profile.

1.2 Data on your Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or perform a search. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.3 Cookies, Web Beacons and Other Similar Technologies

We collect data through cookies and similar technologies.

We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools.

1.4 Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features.

1.5 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use and how you use those Services. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services so that they can be more relevant and useful to you and others.

2.1 Services

Our Services help you get settled in successfully and be more productive in your new cultural environment.

We use your data to authorize access to our Services.
Our Services allow you to get informed about your new location. Our Services also allow you to improve your personal and professional intercultural communication skills or learn new ones. We use the data we have about you (e.g., data your employer provides, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, or watch related learning content to help you towards that new skill.

2.2 Communications

We contact you and enable communications between you and Globiana coaches.

We will contact you through email, mobile phone, notices posted on our websites or apps, and other ways through our Services, including text messages and push notifications. We might send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services and reminders. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices, as they are a component of Globiana services contracted by your employer.

2.3 Advertising

We do not share your personal data with any third-party advertisers or ad networks for their advertising.

However, if you view or click on an ad on or off our site or apps, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

2.4 Marketing

We promote our Services to you and others.

We use data and content about Members for invitations and communications promoting engagement and our Services.

2.5 Developing Services and Research

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, and drive engagement on our Services.

Surveys

Polls and surveys are conducted by us through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide.

2.6 Customer Support

We use data to help you and fix problems.

We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

2.7 Aggregate Insights

We use data to generate aggregate insights.

We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, or to publish visitor demographics for Service or demographic workforce insights.

2.9 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

3. How We Share Information

3.1 Our Services

Any content you post or social action (e.g. likes, comments, shares) you take on our Services will be seen by others.
Your employer can see how you use Services they provided for your work and related information. We will not show them your searches, personal messages or chat conversations.

3.2 Related Services

We share your data across our different Services and Globiana-affiliated entities.

We will share your personal data with our affiliates and consultants to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, our coaches will recommend better content to you based on your Globiana profile or the articles you read on the Globiana Services, and we can personalize your feed based on your learning video history, because we are able to identify you across different Services using cookies or similar technologies.

3.3 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.4 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with your employer, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Globiana, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.7 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, and deleting or correcting data included in your profile.
For personal data that we have about you:
Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data your employer provided in machine readable form.
You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

4.3 Account Closure

We keep some of your data even after you close your account.

If your employer requests to close your account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2. Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

5.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provided by contacting us using the information below.
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with your employer (e.g. to deliver the Globiana Services they have requested)) and “legitimate interests”.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer here.

5.4. Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

5.5. Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please first contact Globiana online. You can also reach us by physical mail through the mailing address listed on Globiana website. If contacting us does not resolve your complaint, you can contact EU National Data Protection Authority for other options.