G-P Privacy Policy

Your privacy is important to Globalization Partners LLC and its subsidiaries and affiliates (“G-P,” “our,” “we,” or “us”). This Privacy Policy applies when you use our Services (as described below) and explains how G-P collects, uses, shares and protects the Personal Information of individuals, customers, job applicants, and others who interact with us. These interactions include both online and offline activities with G-P and/or your use of any of our products and services, including, but not limited to, the G-P Platform, our website, and any of our other online tools or applications (collectively, “Services”).

In the course of using our Services, you may provide us with personally identifiable information. This refers to any information about you that can be used to contact and/or identify you, information on your use of the Services that may be connected with you, (“Personal Information”).

Types of Personal Information we collect may include your full name, email address, home address, contact telephone numbers, and, if you become a registered user of our Services, user IDs and passwords.

It may also include work information, such as job title and other business or company information, including, but not limited to, state and country of company residence, occupation, industry, payment information and/or banking details to complete your purchase orders and/or any other information needed to provide a requested proposal.

We may also collect demographic information, such as your age, gender, interests, and preferences. Forms that you choose to complete will indicate whether information requested is mandatory or voluntary, for their applicable purposes.

When you visit our website, our servers automatically record information that your browser sends whenever you visit a website. This information may include, but is not limited to, your Internet Protocol address, browser type, the web page you were visiting before you came to our website and information you search for on our website. Like many websites, we also use “cookies” and other technologies to collect information. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of our website or all functionality of our Services. For more information about our use of cookies and other technologies, see the section on “Use of Cookies and Social Media Features” in this Privacy Policy.

We may collect your Personal Information when you:

• Use our website or applications.
• Request quotes, services, support, whitepapers, or information.
• Place orders for services or register for events or webinars.
• Create and manage an account.
• Use our Services.
• Register for our events, webinars and meetings.
• Apply for a job.
• Participate in our surveys or other promotional activities online or in any other venue.
• Provide a testimonial about our business.
• Subscribe to our newsletters, G-P programs, marketing emails or other materials.
• Interact with us on third party social networks (subject to that third party’s terms of use and privacy policies).
• Visit our offices.
• Contact us.

When visiting the careers page of our website, we collect the information that you provide in connection with your job application, such as business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide during the application process. For more information on this matter, please consult our Candidate Privacy Notice.

Please note that G-P Services may be offered in conjunction with the services of another company. If you intentionally interact with such Services by registering for, or use such Services, both G-P and the other company may receive information collected in conjunction with such Services and may use the information according to each company’s privacy policy and other agreements with you.

We may collect information about you from third party sources such as public databases, our partners, joint marketing partners, social media platforms, and from other third parties. Examples of the information we may receive from other sources include page-view information from business partners with which we operate co-branded services or joint offerings. We may use the information to enhance our ability to provide relevant marketing, better tailor our Services to you and help prevent and detect fraud.

In some cases, another user (such as an administrator) may create an account on your behalf and may provide your information to us, including Personal Information (most commonly when your company requests that you use the G-P Platform or any other Service). We collect Personal Information under the direction of our customers and often have no direct relationship with the individuals whose personal data we process. If you are an employee of one of our customers and would no longer like us to process your information, please contact your employer and us at the contact information below.

In order to offer you a more consistent and personalized experience in your interactions with G-P, information collected through one source may be combined with information we obtain through other sources. This may include information that allows us to identify you across multiple devices through which you access our website. We may also supplement the information we collect with information obtained from other parties to create customised profiles about you. Examples of how we may use this information include using your data to help us to improve your experience using our website, to present you with options tailored to your preferences and for targeted advertising purposes as explained below.

G-P may use your Personal Information to:

• Deliver our Services and support or carry out the transactions you have requested.
• Create, update, support and manage your account.
• Provide training.
• Handle your support tickets related to the Services.
• Send communications to you, including information about your transaction status, notifications about order confirmations, G-P’s Services, events, promotional offers and surveys.
• Facilitate your use of our website, online G-P chat forums, including G-P blogs, podcasts, resources and webinars.
• Offer Live Chat assistance to respond to your online inquiries.
• Facilitate communications from G-P business partners.
• Facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, communicating with the job candidate and monitoring recruitment statistics. For more details you may consult our Candidate Privacy Notice.
• Customize, analyse and improve our Services (including the content and advertisements on our website to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you.
• Better understand our customers and online users, based on interests and interactions with our website.
• Personalize content and implement your preferences.
• Enforce our conditions of sale, website terms and separate contracts (if applicable) with you.
• Prevent fraud and other prohibited or illegal activities; which may include conducting checks against publicly available information and social media profiles.
• Protect the security or integrity of our website, our businesses, and our Services.
• Perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.

We may share your Personal Information with G-P subsidiaries and affiliates, business partners and/or customers for the purposes described in this Privacy Policy, including (without limitation) to carry out transactions you request, or to make our business (or that of our subsidiaries or affiliates) more responsive to your needs. We may also use and/or share your Personal Information with third party vendors and service providers under contract with us who help with our business operations. We engage these companies to perform tasks on our behalf and may, from time to time, need to share your information with them to provide products and services to you. These service providers are authorized to use your personal information only as necessary to provide products and services on our behalf. Such service providers may include our website hosting company, cloud computing infrastructure providers or other technology providers.

Our subsidiaries, affiliates and/or business partners may contact you with information about G-P, and G-P Services or offers. We will only share your Personal Information with entities who agree to protect your Personal Information and use it solely for the purposes specified by G-P.

In addition, G-P may share your Personal Information with participants in our sales and marketing chain, including, but not limited to, integrators, order fulfillers and some sales agents and channel partners, for the limited purposes of selling, marketing or providing support for G-P products and services.

In certain situations, we may also be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may further disclose your Personal Information as required by law such as to comply with a subpoena, court order or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

In an ongoing effort to better understand visitors to our website, we may analyse anonymous and aggregate information in order to operate, maintain, manage, and improve the website, and/or related products and services. This aggregate information does not identify you personally. We may share this aggregate data to our subsidiaries, affiliates, agents, business partners and other third parties. We may also disclose aggregated user statistics in order to describe the Services and other products and services to current and prospective business partners and to other third parties for other lawful purposes.

We may disclose your Personal Information for any purpose with your consent.

In the event of a corporate sale, merger, reorganization, acquisition, sale of all or a portion of our assets, dissolution, or similar event, your Personal Information may be part of the transferred assets. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as of any choices you may have regarding your Personal Information in the event of such a change.

Our legal basis for collecting and using your Personal Information will depend on the Personal Information concerned and the specific context in which we collect it. In general, we collect and process your Personal Information on one or more of the following bases:

Your consent. For example, situations where we have obtained your consent to process your Personal Information for certain activities (such as the use of cookies for online tracking and analysis). You are free to withdraw your consent at any time by contacting privacy@g-p.com. If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew it.
To comply with our contractual obligations. We will advise you upon collection whether the provision of your Personal Information is mandatory and of the possible consequences if you do not provide us with your information.
For compliance with G-P’s legal obligations where laws or regulations require the processing of your Personal Information (for example, health and safety, taxation, and anti-money laundering laws) or where we need your Personal Information to protect your vital interests or those of another person.
G-P’s legitimate interests which include the provision of our website and/or relevant Services, and/or the carrying out of marketing activities, provided always that our legitimate interests are not outweighed by any prejudice or harm to your rights and freedoms.

If you have any questions or need more information concerning the legal basis on which we collect your Personal Information, please contact us at privacy@g-p.com.

We will retain your Personal Information for different periods of time, depending on the type of Personal Information and the nature of your relationship with us. We will determine on a case-by-case basis for how long we need the Personal Information, but we aim to retain your Personal Information for a short period, as needed to fulfil the purpose for which it was collected. We comply with the applicable legal requirements regarding data retention, and we have our own legitimate interests in retaining your data for certain periods.

G-P may transfer your Personal Information to other companies within the G-P group of companies and/or to its business partners, if required for the purposes described in this Privacy Policy. This may involve the transfer of your Personal Information to countries outside your home country or region, including outside the European Economic Area or United Kingdom if that is your region, which may have a different level of data protection from your home country. Such countries may include, without limitation, the United States and other countries in which G-P or its subsidiaries, affiliates or business partners conduct business. In order to provide adequate protection for the transfer of your Personal Information, we have in place contractual arrangements such as the Standard Contractual Clauses (as appropriate) with our subsidiaries, affiliates and business partners in respect of such transfers. We will take all reasonable technical and organisational measures to safeguard Personal Information we transfer.

G-P has been certified and attested to confirm compliance with Service Organization Controls (SOC) 2 standards by independent auditors. SOC reports demonstrate our commitment to securing data. G-P’s security program is designed to:

Protect the confidentiality, integrity, and availability of data (including Personal Information) in G-P’s possession or to which G-P has access.
Protect against any anticipated threats or hazards to the confidentiality, integrity, and availability of data (including Personal Information).
Protect against unauthorized or unlawful access, use, disclosure, alteration, or destruction of data (including Personal Information).
Protect against accidental loss or destruction of, or damage to, data (including Personal Information).
Safeguard information as set forth in any regulations to which G-P may be subject.
The provision of Services through the G-P Platform is also certified to be compliant with the ISO 27001 standard, a key international standard governing information security management. Adherence to this standard assures that data and services are protected to the fullest extent possible. To learn more about G-P Platform security, you may visit our Security page and our Privacy & Security Center.
We use appropriate technical and organizational security measures to ensure a level of security appropriate to the risk and to protect the data supplied by you and managed by us against loss, unauthorized access, disclosure, alteration, and destruction and against other forms of unlawful or abusive treatment. The ways we do this include:

Using encryption when collecting or transferring Personal Information.
Having in place technical and organizational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and services.
Limiting physical access to our premises.
Limiting access to the information we collect about you.
Ensuring that we and our business partners have appropriate security safeguards to keep Personal Information secure; and
Where required by law, destroying or de-identifying Personal Information.

However, no transmission over the internet and no data storage method can be guaranteed to be secure 100% of the time. In particular, email sent to us may not be secure, and as such, you should take care in deciding what information you send to us via email. We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from G-P asking for your Personal Information. G-P will not request your ID or password through email.

In accordance with applicable law, you may have one or more of the following rights:

• Right to access and know the Personal Information we have about you,including the details of how we use that information and who we share it with.
• Right to request a copy of the Personal Information that we hold about you.
• Right to amend, correct or rectify your Personal Information if any of the information held about you is incorrect or out of date. Right to portability of your Personal Information.
• Right to request deletion of your Personal Information.
• Right to demand that we cease the processing of your Personal Information or that we restrict the processing of your Personal
• Information, including your Personal Information.
• Right to object to certain types of processing your Personal Information.
• Right to withdraw your consent to the processing of your Personal Information, to the extent our processing relies on your consent as the lawful basis for processing; and/or
• Right to provide us with instructions as to the processing of your Personal Information in case of death.

Depending on your location, you may have the ability to exercise these rights yourself or through an authorized agent. If you use an authorized agent, she or he must provide their name, email address, phone number, and written permission from you that includes your contact information. We will contact you using the information provided and verify your identity directly. We cannot respond to your request to provide additional disclosures or delete any personal information if we cannot verify your identity and the authorized agent’s authority to make the request on your behalf. Written permission is not required if the agent provides a valid power of attorney.

In addition, and were granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.

We will not discriminate against you for exercising any of your rights. This means that your exercise of these rights will not result in G-P: (1) denying you Services; (2) charging you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties; (3) providing you a different level or quality of Services; or (4) suggesting that you may receive a different price or rate for Services or a different level or quality of Services.

G-P will handle such requests in accordance with applicable law, including in the time specified by applicable law. G-P will respond to your request via the email address you use to exercise your request, or any other suitable method. Depending on your request, we may review the request with you and/or your company to assist in resolving and responding to the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We may use the email address you provide to deliver G-P email newsletters, as well as for other promotional purposes. Email messages we send you may contain code that enables our database to track your usage of the emails, including whether the email was opened and what links (if any) were clicked. If you send an email to us or fill out our “Contact Us” or “Request Info” or similar forms, we will collect your email address and the full content of your email, including attached files, and other information you provide.

You may indicate your preference to opt out of receiving promotional and marketing communications by following the unsubscribe instructions provided in promotional emails you receive or by contacting us directly at privacy@g-p.com. You acknowledge that it may take up to 10 days for us to process an unsubscribe request. Please note, however, that you are not permitted to opt out of receiving transactional emails related to any Services that you have with us.

G-P uses “cookies” (small files that a site places on your hard drive for identification purposes) and similar technologies. A cookie file can contain information such as a user ID to track pages visited. These files are used for site registration and customization the next time you visit the site. For further information on how we use cookies, please consult Cookies Preferences.

You can manage the cookies and customise your experience on our website. Please visit G-P’s cookies banner management tool on our website.

Please note that if you clear your cookies, or if you use a different browser or device, you will be asked again to consent to the use of cookies and/or interest-based advertising, which may require you to reset your choices.

G-P’s website may include links and connections to third party websites, products and services as well as so-called community plug-ins of third parties (such as Facebook, Instagram, LinkedIn, YouTube and Twitter). Third party plug-ins integrated into the G-P website are loaded from third party servers and thus the third party may install their own cookies on the user’s device. Your interactions with those third parties and applications offered on our website are subject to the privacy policies or notices of such third parties. We recommend that you familiarize yourself with those third-party privacy policies or notices.

G-P does not knowingly collect or solicit Personal Information from anyone under the age of 16. Children under 16 years old are not the target audience for our website. If you are under 16, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Policy by instructing their children never to provide Personal Information through our site.

As part of G-P’s commitment to maintain high data protection standards when transferring Personal Information between the European EEA/UK/Switzerland and the United States (“US”), G-P participates in the EU-US Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (“Swiss-US DPF”). Globalization Partners LLC and Globalization Partners US., Inc are adhering to the EU-US DPF Principles, including as applicable under the UK Extension to the EU-US DPF, and Swiss-US DPF Principles.

G-P complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce. G-P has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. G-P has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit: https://www.dataprivacyframework.gov/

In compliance with the EU-US DPF, UK Extension to the EU-US DPF, and the Swiss-US DPF, G-P commits to resolve DPF Principles-related complaints about your privacy and our collection or use of your personal information. EU and UK individuals and Swiss individuals with DPF inquiries or complaints should first contact G-P through privacy@globalization-partners.com . We will respond to your inquiry promptly.

G-P also commits to cooperate with the EU data protection authorities (EU DPAs) under the EU-US DPF, the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) under the UK Extension to the EU-US DPF, or the Swiss Federal Data Protection and Information Commissioner (FDPIC) under the Swiss-US DPF with regard to unresolved complaints concerning our handling of personal data received in reliance on EU-US DPF, UK Extension to the EU-US DPF, and the Swiss-US DPF. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the following links for more information and to file a complaint. This service is provided free of charge to you.

DPAs in the EEA: https://edpb.europa.eu/about-edpb/about- edpb/members_es#member-no
DPA in the UK: https://ico.org.uk/global/contact-us/
DPA in Switzerland https://www.edoeb.admin.ch/edoeb/en/home.html

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Further information can be found here: https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures- dpf?tabset-35584=2

G-P is subject to the jurisdiction of the US Federal Trade Commission for the purposes of DPF enforcement.

Accountability for Onward Transfers.

As explained in sections 5 (“How We May Share your Personal Information”) and 8 (“International Transfers”) above we sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the DPF to a third party, the third party’s access, use, and disclosure of the personal information must also be in compliance with our DPF obligations, and we will remain liable under the DPF for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage. G-P is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf.  G-P complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The California Consumer Privacy Act (“CCPA”) and as expanded by the California Privacy Rights Act (“CPRA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of their “Personal Information,” as well as rights to know, access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. The Personal Information we collect about you will depend upon how you interact with our Services and the information you voluntarily provide us, as explained in Section 2 “Information We Collect”. Accordingly, we may not collect all of such information about you. In addition, we may collect and/or use additional types of information after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA.

To the extent that we collect Personal Information that is subject to the CCPA or CPRA, you have the following rights concerning your data processed by G-P:

• Deletion: You have the right to request that G-P erase your Personal information, and G-P will erase such information unless it is reasonably necessary for G-P to maintain your personal data in accordance with CCPA 1798.105 (d) or 1798.145.
• Correction: You have the right to request that G-P correct inaccurate Personal Information, taking into account the nature and purpose of processing the Personal Information.
• Access: You have the right to request to access the Personal Information that G-P holds about you, including specific pieces of Personal Information G-P has collected about you.
• Non-discrimination: G-P will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA or CPRA.
• Right to Opt Out of Sale of Personal Information to Third Parties: While G-P does not sell personal information to third parties, the CCPA has a broad definition of sale and certain data collected on our sites by third parties for purposes of interest-based advertising may be a “sale” under the CCPA. G-P may be categorized as a “Service Provider” under the CCPA in certain cases, such as in providing products and services to our customers. In other cases, G-P may be categorized as a business, such as in our day to day operations. The categories of third parties to whom personal information is disclosed that may be considered a “sale” under California law include advertisers and marketing partners and data analytics providers. The categories of information we may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data. To opt out of the sale of your Personal Information to third parties, please click the “Do Not Sell My Personal Information” button on our cookies banner. California residents can also turn on the Global Privacy Control (GPC) to opt out of the “sale” of your Personal Information for each participating browser system that you use. Learn more at the Global Privacy Control website.

You may submit a request to exercise your rights to the address displayed at “How Can You Exercise Your Rights?” section below.

While we do not provide your Personal Information to third parties for their use in marketing, under California law, California residents have the right to opt out of such use of their Personal Information if it occurred. 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 Information to third parties for their direct marketing purposes in the preceding calendar year. You can send your request to the address displayed at “How Can You Exercise Your Rights?” section below. You may submit a request to exercise your rights to the address displayed at “How Can You Exercise Your Rights?” section below.

In addition to the rights set forth in the “Your Rights” section, the Brazilian General Data Protection Law (“LGPD”) grants customers and users located in Brazil have the right to:

• Confirm the existence of processing.
• Correct inaccurate or out-of-date information.
• Request the anonymization, blocking, or elimination of unnecessary or excessive personal information processed in noncompliance with Brazilian data protection law.
• Request the revision of decisions made solely on the basis of automated processing of personal information whenever it affects your interests.
  Obtain information about the entities with which we share their Personal Information; and
• Request a list of third parties that have received their Personal Information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information shared. We provide this list at no cost. We will provide this information within 15 (fifteen) days from the date of the request.

To exercise your rights or if you have any questions about how your data is processed, you can contact the G-P Data Protection Officer for Brazil at:

Globalization Partners Prestação de Serviços Administrativos LTDA
C/O: Encarregado de Proteção de Dados (DPO), Filipe Lousa
Avenida das Nações Unidas, nº 12.995, 10th floor, Brooklin Novo
São Paulo/SP, CEP 04578-911
DPO: Filipe Lousa
Email: privacy@globalization-partners.com

G-P reserves the right to change, modify, or update this Privacy Policy to reflect changes to our privacy practices or applicable law. Notice of any material changes to our privacy practices will be posted in our website before such material changes become effective. You are advised to visit our website regularly for the latest information on our privacy practices. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

If you would like to exercise any of the rights listed above or if you have any questions about this Privacy Policy, please contact our Global Data Privacy Office at: privacy@g-p.com, or at:

Globalization Partners LLC
Global Data Privacy Office
175 Federal Street
17th Floor
Boston, MA 02110 USA
Fax: +1 (888) 856-0702