LAST UPDATED: April 5, 2023
- consumer a natural person acting in an individual or household context and does not include a natural person acting in a commercial or employment context
- controller means the person or entity that determines why and how personal information is processed
- personal information means information that is linked or reasonably linkable to an identified or identifiable individual person
- processing means any operation (or set of operations) performed on personal information), such as collecting, analyzing, and storing
- processor means the person or entity processing personal information on behalf of a controller
Our processing of personal information is subject to the laws in the jurisdictions in which Global operates. Privacy rights may vary depending on each consumer’s place of habitual residence.
- by e-mail at [email protected], or
- by telephone at 1-781-894-8800, or
- by U.S. mail at 800 South Street, Suite 500, Waltham, MA 02453.
- INFORMATION WE COLLECT
Global is the controller of the personal information that Global collects from or about consumers in connection with the Sites. Global collects the personal information that consumers choose to share with us, which typically includes the following categories of personal information:
|Personal Information Collected||Why the Personal Information is Collected|
|Contact Information and Similar Identifiers (Name, email address or other username, password, telephone number and similar contact information and purchase related contact information)||When you choose to participate in Global’s events, we collect the information that you use to register or participate. When you participate in surveys, you give us your responses to our questions. To respond to your request in a form filled out on a Site or in-person to download content or sign up for emailsTo manage features of the Sites that allow you to share your personal information|
|Audio and Video Information||We may collect audio and similar information when you contact our customer service team or when you participate in a Global event or meeting. We may monitor or record your online or telephone discussions with our customer service team for training purposes and to ensure service quality. We will announce when your telephone calls or video are recorded, as required by law.|
Information Automatically Collected by the Sites
We use various technology tools to automatically collect your browser and/or device type, browser language, the date and time of your visit and certain cookies that identify your device and browser, browsing history and other information regarding your interaction with the Sites, as well as the third-party websites and mobile apps that you see before or after you use the Sites.
Please see Section 3 for more information about the data collection technology that we use to automatically collect information through the Sites and how we use them.
- COOKIES AND OTHER DATA COLLECTION TECHNOLOGY
We use different kinds of technology tools to recognize you, your browser(s) and/or your device(s) when you use the Sites and to collect personal information about you when you interact with the Sites. These tools include cookies, tracking pixels (sometimes called web beacons) and embedded scripts, which we refer to collectively as data collection technology.
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically stores the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. Pixels are snippets of computer code embedded on websites that can collect information.
Data collection technology collects data related to usage and performance of the Sites, such as:
- IP address and time zone
- browser type and language
- computer or mobile device type and operating system
- device identifiers – IMEI/UDID (a numeric identifier for mobile devices) and MAC address (another kind of numeric identifier for mobile devices)
- user settings
- browsing history and activities conducted while using the Sites
- websites visited before and after the Sites
- Location Data (with consent)
Data collection technology enables Global to monitor and analyze usage, technical and navigational metrics; customize user experience; set or communicate with cookies; understand whether consumers visit the Sites after seeing an online advertisement displayed on a third-party website; measure the success of email marketing campaigns; improve performance of the Sites; and to help detect and prevent fraudulent use of the Sites.
If you want to learn more about data collection technology, many online resources are available, such as www.allaboutcookies.org.
Cookies. The Sites use the following cookies:
- Strictly necessary cookies, which are required for the operation of the Sites. Without them, for example, you would not be able to register or log in for the Sites that we offer.
- Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Sites and to help us to improve the way Sites function.
- Functionality cookies, which are used to recognize you when you return to the Sites.
You have the right to decide whether to accept or reject cookies used in the Sites. . You can set your browser to refuse all cookies or to indicate when a cookie is set. (Most browsers accept cookies automatically but allow you to disable them but note that some features of the Sites may not work properly without cookies.) You also may be able to reject device identifiers by activating the appropriate setting on your mobile device.
Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) also have a “Do Not Track” (DNT) feature that tells a website that a consumer does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user.
As of the “Last Updated” date above, consumers may disable Google’s cookies or delete any individual cookie. Google Analytics supports an optional browser add-on that – once installed and enabled – disables measurement by Google Analytics for any site you visit.
To opt-out of personalized advertising generally, visit DAA Opt-Out Page (web browser only). Opting out does not mean you will not see advertising – it means you will not see personalized advertising from the companies that participate in the opt-out programs. Also, if you clear your cookies, you many need to opt-out again.
- HOW GLOBAL USES INFORMATION
Global uses the information that we collect from or about consumers:
To deliver the Sites
- Provide customer support and respond to requests for information
- Manage and communicate with consumers about the Sites
- Monitor and test the Sites, including to troubleshoot operational problems
For analytics and marketing
- Analyze information collected through the Sites to help us better understand consumers’ activities across the Sites
- Communicate with you by email, postal mail or telephone about Global
To learn about what you and other consumers like so we can improve the Sites
- Administer focus groups and surveys
- Conduct research and analysis to develop new features and content for the Sites
- Improve customer service
To prevent and detect fraud and abusive and unauthorized use of the Sites
- Detect bots and other disruptive code
For legal compliance, risk management and similar administrative purposes
- Comply with legal requirements in the various jurisdictions in which Global operates
- Assist law enforcement (see How We Handle a Law Enforcement Request below)
- HOW GLOBAL SHARES INFORMATION
Global shares information collected in connection with the Sites as follows:
- With the consent of the consumer.
- With Other Global Businesses. We share information that we collect through the Sites among the Global businesses.
- When Required by Law. Applicable law may require information disclosure when necessary (in Global’s good-faith judgment) to comply with legal process, such as a court order, subpoena, search warrant, government investigation or similar legal requirement or for the prevention or detection of crime (subject in each case to applicable law). (Please also see How We Handle a Law Enforcement Request below.)
- To Enforce Legal Rights. We also share information when we believe that disclosure would mitigate our liability in an actual or threatened lawsuit or when we believe necessary to (i) protect our legal rights and legal rights of consumers, customers, employees, business partners or other interested parties; (ii) pursue available remedies or limit the damages; (iii) enforce our agreements with you; or (iv) respond to an emergency.
- CONSUMER PRIVACY RIGHTS AND HOW TO EXERCISE THEM
U.S. state privacy laws provide consumers certain rights with respect to their personal information. Global will honor these rights for all consumers who submit authenticated requests in compliance with these laws.
The specific privacy rights available for consumers are:
- Right to Request Access: You have the right to know and access the personal information that Global processes about you and to obtain a copy of that personal information.
- Right to Request Deletion: You have the right to request the deletion of personal information provided by or obtained about you.
- Right to Request Correction: You have the right to request that Global correct inaccuracies in the personal information that Global holds about you.
- Right to Opt-Out of Targeted Advertising: You have the right to opt out of Global’s targeted advertising using your personal information, when applicable. (Targeted advertising is advertising based on data collected about your activities over time and across other websites and services and used to infer or predict your interests or preferences.)
- Right to Opt-Out of Sale: Depending on your state of residence, disclosure of your personal information to targeted advertising providers may constitute a sale of personal information. Global will allow you to opt out of the sale of your personal information when applicable.
How to Exercise Privacy Rights
You may submit a request to exercise a privacy right:
- By clicking on the “Your Privacy Choices” link in the footer of the Sites and completing the form
- By sending an email to [email protected] that includes your name, the email that you use/will use to communicate with Global, the privacy right(s) that you wish to exercise, the name of your authorized agent (if applicable) and documentation verifying your authorization and other information that you believe will help us verify and take action on your request
- By telephone at 1-781-894-8800
Global will respond to an authenticated privacy right request within 45 days (or, if shorter, the number of days required under applicable law). Global may notify you of an additional 45-day extension when Global determines an extension is reasonably necessary based on the complexity of the privacy right request. Global generally does not charge a fee for responding to a privacy right request but may do so if Global determines that a request is manifestly unfounded, excessive, or repetitive.
The privacy rights described above are not absolute – exceptions and exemptions apply. If an exception or exemption applies to a privacy right request, Global will explain in a written response to the request.
Global reserves the right to request additional information to authenticate any privacy right request. If Global is unable to authenticate a request after commercially reasonable efforts to do so, then Global may, in its good-faith judgment, not respond to a privacy right request.
You can appeal Global’s decision about a privacy right request by sending an email to [email protected]. In your email, please provide as much information as possible about the right you wish to exercise and the basis for your appeal of Global’s decision.
- HOW WE PROTECT INFORMATION
We use technical and organizational measures designed to protect your information against unauthorized access, use and loss. Unfortunately, we cannot guarantee the security of information transmitted through the Internet. We may suspend your use of all or part of the Sites without notice if we suspect or detect any breach of security.
If you believe that information you provided to us is no longer secure, please notify us immediately at 781-894-8800 or [email protected].
- HOW LONG WE RETAIN INFORMATION
Global retains your personal information in identifiable form only as long as necessary for the lawful purpose for which Global collected it or, if longer or shorter, to comply with law, to resolve disputes and to enforce legal agreements.
- HOW WE HANDLE A LAW ENFORCEMENT REQUEST
Global is committed to cooperating with law enforcement while respecting each consumer’s right to privacy. We respond to valid legal process issued in compliance with U.S. law.
- ABOUT CHILDREN’S PRIVACY
We do not knowingly collect personal information from children under age 13 because they are not allowed to use the Sites.
If you know that a person under age 13 has provided us with personal information without verifiable parental consent, please notify us immediately at [email protected] or by telephone at 1-781-894-8800.
- HOW TO CONTACT GLOBAL
- by e-mail at [email protected]
- by telephone at 1-781-894-8800
- by U.S. mail at 800 South Street, Suite 500, Waltham, MA 02453.