28th October 2020
2. What we may collect
2.1 Personal data, or personal information, (collectively referred as “Personal Data”) means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2 We may collect, use, store and transfer different kinds of personal data about you which may include but not limited to the following:
- personal data that identifies you as an individual, including but not limited to your first name, last name, email address, credit card information, and phone number;
- technical data, which may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website;
- profile data, which may include your username and password, reservations made by you, your interests, preferences, feedback, and survey responses;
- usage data, which may include information about how you use our Website and Services.
- marketing and communications data, which may include your preferences in receiving marketing from us and our third parties and your communication preferences.
- interaction data, which may include any information that you might provide to any discussion forums on the Website;
- cookies data;
- third parties information which we receive about you from other sources; and
- analytics including third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage.
2.4 We do not collect any sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How we may collect and use your data
3.1 We will take reasonable steps to ensure that your personal data is processed and used lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a contractual or legal obligation to which we are subject;
d) processing is necessary for system administration and to report aggregate information to our advertisers;
e) processing is necessary to protect the vital interests of you or of another natural person;
f) processing is necessary for the performance of a task carried out in the public interest; and/or
g) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your Personal Data by way of different methods to collect data from and about you including through direct interactions with us. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a) visit one of our websites;
b) use any of our Services;
c) create an account on our Website;
d) subscribe to our Services or publications;
e) request marketing information to be sent to you;
f) enter a competition, promotion, or survey; or
g) provide us with some feedback.
3.3 In addition to the above, we may use the information in the following ways:
a) to ensure that content from our Website is presented effectively to you;
b) to carry out services relating to your purchase order (e.g. to fulfil your order request, to respond to your question regarding our products, to process your purchase, to track the status of your order etc.) We may also use your data to assess your creditworthiness, for which we may engage third parties;
c) to personalise your website experience and to allow us to deliver the type of content and product offerings in which you are most interested;
d) to administer a contest, promotion, survey or other such activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your personal information;
e) provide information, and services that you request, or (with your consent) which we think may interest you;
f) prevent or detect any misuse or fraud;
g) If you have opted-in to receive our marketing information (e.g. periodic newsletters), we may contact you via e-mails, SMS, telephone or any other electronic means for marketing, advertising, and opinion research purposes.
In order to be able to contact you with information which may be of interest to you, your overall interaction with Globics will be combined, analysed and used. We may use your personal data for marketing, advertising, and opinion research purposes. The period of use of the personal data will not be longer than we deem necessary but may be unlimited. If you would no longer like to receive such marketing information from us, please refer to the “How can you opt-out, remove or modify information you have provided to us?” section below. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programs and ‘members-only’ content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us.
3.4 We may keep a record of browsing activity and purchase history which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.
In addition, if you don’t want us to use your Personal Data for any of the other reasons set out in this section 3, you can let us know at any time by contacting us at firstname.lastname@example.org, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.
3.5 You have the right to withdraw consent to marketing at any time by contacting us at email@example.com and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible services to you.
5. Where we store your data and security
5.2 Data security is of great importance to us. To protect your data, we have put in place suitable physical, electronic, and managerial measures to prevent unlawful or accidental destruction, accidental loss, unauthorized disclosure or access or other unlawful forms of processing. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
5.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
5.4 Due to the open nature of the Internet, it is impossible to guarantee that any of your Personal Data stored and collected will be free from unauthorized access. Notwithstanding the security measures that we take, the transmission of data via the internet may not be completely secure and we advise you to take suitable precautions when transmitting to us data via the internet. We disclaim any liability for any theft, loss of, damage or unauthorized access of any data or communications. By using our Website, you acknowledge that you understand and agree to assume these risks.
5.5 If we give you a password upon registration on our Website, you are solely responsible for keeping this password confidential. Please don’t share it with anyone.
5.6 We will not keep your Personal Data longer than it is necessary. We may however be required to retain Personal Data for a longer period of time to ensure we comply with legislative and regulatory requirements. We will review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
6. Disclosing your information
6.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your Personal Data. Such third parties will be contractually obliged to treat such information in the strictest confidence.
6.3 Where any of your Personal Data is required for such a purpose, we will take all reasonable steps to ensure that your Personal Data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the applicable laws (including where applicable, the GDPR).
7. Your rights
7.2 You have the right to:
– request access to, deletion of or correction of, your Personal Data held by us at no cost to you;
-request that your Personal Data be transferred to another person (data portability);
-be informed of what data processing is taking place;
-to object to processing of your Personal Data; and
-complain to a supervisory authority.
7.3 You also have rights with respect to automated decision-making and profiling as set out in section 10 below.
8. Links to other sites
8.1 Please note that our terms and conditions and our policies will not apply to other websites that you visit via a link from our Website. We have no control over how your Personal Data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
10. Automated Decision-Making and Profiling
10.1 In the event that we use Personal Data for the purpose of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under the applicable laws (including, where applicable, the GDPR), requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
10.2 The right described in section 10.1 does not apply in the following circumstances:
a) the decision is necessary for the entry into, or performance of, a contract between the you and us;
b) the decision is authorised by law; or
c) you have given your explicit consent.
10.3 Where we use your Personal Data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All Personal Data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
11. Terms and Conditions
11.1 Please also visit our Terms and Conditions at https://www.globics.com/privacy-center/terms-and-conditions/establishing the use, disclaimers, and limitations of liability governing the use of our Website.
12. Your Consent
13. Dispute Resolution
13.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.
13.3 All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.
13.4 If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.
14. Governing Law