Global Transact Privacy Policy v.2

Global Transact, LLC, and its wholly and majority-owned entities ("GT," "we," "us," "our") are committed to protecting your privacy and compliance with all applicable data privacy laws, rules and regulations. This Privacy Policy describes what personal information we collect about you and why, how we collect and process it, how we use and protect this information, with whom it is shared, and your rights in relation to this information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices. This Privacy Policy may be supplemented by additional privacy statements, terms or notices provided to you.

Personal information (also sometimes referred to as "Personally Identifiable Information" or "Personal Data") is any information relating to an identified or identifiable person. This Privacy Policy applies to all personal information about you we collect or process through the GT website; mobile applications or other software we develop or use for business purposes; publicly available social media profiles; offline collection and third-party sources; any other means where a link or reference to this Privacy Policy is provided, and in other interactions we have with you, online and offline.

We do not collect personal information about your race or ethnicity; social origin; political, religious or philosophical opinions and beliefs; criminal records; health, genetic or biometric data; health and medical records; family; sexual life and sexual orientation.

We collect personal information about you in order to respond to your requests, provide you with information about our services, engage with you as a business partner (customer, supplier, etc.), deliver our services and otherwise perform a contract, and comply with legal obligations.

We may also be required by law to collect certain personal information about you for "Know Your Customer" (KYC) purposes or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.

In addition to collecting personal information, we may also collect information that does not identify you and is not associated with your personal information. We may also anonymize your personal information so it no longer identifies you. We can aggregate and use such information for marketing and other purposes. Because such information does not identify you, it is outside the scope of this Privacy Policy.

By using our website or otherwise providing personal information to us you agree to this Privacy Policy.

1. Personal Information We Collect

We collect information about you in three ways: directly from you, through automated technologies and from third-party sources. These include you contacting us by mail, email, telephone (landline, cellular or "Voice Over Internet Protocol" (VOIP) based), online communication platforms, participating in any cloud-based web and video conferencing meetings or calls organized and hosted by us or our third party providers, uploading information on our web based platform or that of the third party we use, providing hard copies of documents, and any other means by which you provide us with personal information.

1.1. Information You Provide to Us

We may obtain personal information about you that you directly provide to us, including, for example, the following categories of information about you and other persons associated with your organization (owners and top managers):

  • Basic personal information (e.g., name, date of birth, gender, nationality)
  • Contact information (e.g., mailing address, email address, phone number, social media identifier)
  • Government-issued information (e.g., passport, national ID, tax ID, social security number)
  • Professional or employment-related information or other background information (e.g., education, experience, qualifications, current and past employers, job title, primary job responsibilities, work location)
  • Financial information (e.g., bank account information, financial statements, income, credit history, tax information)
  • Commercial information (e.g., transaction and payment history)
  • Communications (e.g., information you provide when you communicate with us via email, our website, mobile application, web based platforms or social media, subscribe to our newsletter, or participate in our events)

At the point of collection, we will make it clear to you what personal information you are asked to provide and the reasons why you are asked to provide it.

Please note that providing personal information to us is voluntary on your part. However, failure to provide it may interfere with our ability to conduct business with you.

If you provide us with any personal information relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

1.2. Information Collected through Automated Technologies. Cookies

We may automatically collect your personal information when you visit or use our website, web-based platforms or mobile applications, including, for example, the following categories of data:

  • Technical information collected from your computer or mobile device (e.g., your IP address, browser type, MAC address, operating system, hardware type)
  • Online activity information and other information collected about your use of our website or applications (e.g., pages you visit, search terms you enter, how often you visit)
  • Location data (e.g., data derived from your IP address, country, region and town where your device is located)
  • Call data (e.g., mobile or telephone number source number, time, date and duration of call, voice messaging, which may be converted to text)

We collect this data through our servers and the use of cookies and other tracking technologies (collectively, "cookies"). Cookies are small text files which are downloaded to your computer or mobile device when you visit a website. They help track your activity and preferences on the website. In particular, our website uses the following categories of cookies:

  • Essential, or Strictly Necessary Cookies (e.g., needed for proper operation of our website, to prevent fraudulent activities, improve security, and for system administration); without them, the website may not function properly.
  • Performance and functionality cookies (e.g., to assess performance of our website, improve its operation, count visits, etc.). These cookies are only used with your consent.

Cookies will not be used to track your activities outside of our website or for any purposes not disclosed here. GT does not track your activities online over time and across third party websites to provide targeted advertising and therefore the GT website does not respond to "Do Not Track" signals.

When you click "I accept" in the cookie bar on our website, you consent to the use of cookies and tracking technologies and the corresponding processing of information. You may withdraw your consent anytime by disabling cookies in your browser. You can control cookies through your browser's settings and other tools. For more information about how to restrict or block cookies through your browser settings, and about cookies in general, you can visit www.allaboutcookies.org and www.youronlinechoices.eu. However, if you disable or reject certain cookies, you may not be able to access certain parts or make full use of our website, web based platforms or mobile applications. An opt-out of the cookies will stop tracking for certain purposes but will still allow the collection of usage data for other purposes (e.g., internal website operation purposes).

We may also use other tracking technologies on our website, such as social plugins. These are hosted by social media networks such as Facebook, Twitter and LinkedIn. Your browser sends this cookie data to that social media network when loading the social media plugin inside your browser. These data contain information on your use of our website. If you are registered with the social media network, the data will be associated with your data already stored in the social media network.

Please note that when you call us using VOIP, VOIP can be recorded and re-transmitted by GT's third party VOIP services. We cannot control this use of data by the receiver and do not assume any responsibility for such use. Do not disclose confidential or sensitive information via VOIP.

If you participate in any cloud-based web and video conferencing meetings or calls organized and hosted by GT, we or our third party providers may collect personal information about you. Examples of providers of videoconferencing applications include, but are not limited to Google Meet, Microsoft Teams, Skype, and Zoom. The types of personal data that may be collected by us during GT-hosted teleconferences may include:

  • Meeting session information (e.g., meeting title, date and time, meeting start and end time, number of meetings, frequency, average and actual duration, quantity, quality, network activity, and network connectivity; number of screen-sharing and non-screen-sharing sessions; screen resolution; join method; performance, troubleshooting, and diagnostics information
  • Participants information (e.g., your name, email address, phone number, geographic region (i.e., country code), browser, IP address, IP addresses along the network path, user agent identifier, hardware type, operating system type and version, actions taken; number and names of other participants, photos or avatars used by you during the teleconferencing session)
  • Texts of chats held during the teleconferencing session

Please be aware that teleconferencing meetings or calls can be recorded and re-transmitted by the applications providers. We cannot control this use of your data by the provider and do not assume any responsibility for such use. Because teleconferencing enables collaboration among its users, as described below, your personal data is required in order to participate in the teleconferences we host. If you participate in teleconferences hosted by GT, we will control any meeting recordings or files shared during the meeting, which will be subject to our company's policies regarding access, use, monitoring, deletion, preservation, and transfer of information. We may record meetings, which may be shared with others or discoverable in a legal matter. GT endeavors to inform all meeting attendees prior to recording and most providers' applications provide visual and/or audio notifications to all participants indicating that the meeting is being recorded. GT assumes no responsibility for the providers' notifications, or the providers' security. GT has no control over, and is not responsible or liable for the privacy of any information that you share with others during teleconferencing.

1.3. Information from Third-Party Sources

We may collect personal information about you from third parties (e.g., other companies in the GT group, our business partners, references you provided to us, due diligence service providers, public databases, social media platforms, credit bureaus and other data collection agencies, and other sources).

We may also obtain personal information about you from the organization which employs you, in which you have ownership interest or with which you are otherwise affiliated in order to provide our services to that organization. Such personal information may include, e.g., your name, date of birth, nationality, and contact details, such as an organizational email address, mailing address, phone number, job title, and other information.

2. How We Use Your Personal Information

The legal bases for our use of your personal information are:

  • Your consent
  • Performing a contract with you or your organization
  • Our legitimate business interests, and
  • Compliance with our legal obligations.

We may use your personal information for the following purposes:

  • To provide you and/or your organization with products, services and information you requested, to provide customer support, and otherwise perform our contractual obligations to you and/or your organization
  • To purchase or otherwise utilize goods or services from you or your supply chain, or to purchase goods or services for you or your organization
  • To verify your identity when you access and use our services and to ensure security of your personal information, prevent fraud and other unlawful activities, unauthorized transactions, claims and other liabilities, and manage risk exposure
  • To communicate with you about your account, the services you requested and to comply with our contractual obligations to you
  • To analyze information about how you use our services to provide you with an improved experience
  • To build a profile about you to better understand your needs and preferences
  • To operate, evaluate and improve our business, including conducting marketing and sales activities, managing our IT and communications systems, product and service development, company assets, strategic planning, project management, operational improvement, managing our communications and customer relations, performing compliance, accounting, auditing, billing, and collection activities
  • To facilitate the functionality of our website, web based platforms and mobile applications, perform analytics, quality control, market research, and determine the effectiveness of our website and mobile applications, and develop new products and services
  • To enable our third parties to carry out certain business functions on our behalf (e.g., due diligence, statistical analysis, verification, technical, logistical)
  • To exercise our legal rights and comply with our legal obligations (e.g., to detect, prevent and respond to security incidents, fraud claims or other violations of law, enforce contracts, resolve disputes)
  • To protect our operations, privacy, safety, property, security, or those of our affiliates, you or others
  • To conduct investigations, comply with relevant industry standards, contractual obligations, our policies and procedures
  • To comply with legal or regulatory requirements (e.g., to respond to requests from government entities, including government authorities outside your country of residence)
  • For other legitimate purposes

GT does not track your activities online over time and across third party websites to provide targeted advertising.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We may process your personal information without your knowledge or consent, in compliance with the Privacy Policy, where this is required or permitted by law.

We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

We may combine personal information we obtain online with information we obtain offline, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law.

If false, inaccurate or misleading information is provided and/or fraud or other illegal activity is identified or suspected, details will be passed to fraud prevention, law enforcement and/or other relevant entities who may access and use your personal information in accordance with applicable law.

3. How We Share Your Personal Information

We may transfer, share or disclose your personal information for the purposes described in Section 2 to the following categories of recipients:

  • Companies in the GT corporate group
  • Our third-party service providers (e.g., IT, data analysis, compliance, accounting, auditing, and legal services; agents, suppliers, distributors, payment processing, order fulfilment services) which facilitate the fulfilment of our contract with you or otherwise act on our behalf based on our instructions and in compliance with this Privacy Policy
  • Law enforcement or other governmental entities, if required by applicable law or legal process (such as a court order) or if we in good faith believe that such disclosure is required to protect our rights or interests, prevent physical harm or financial loss, in response to any emergency situation, to establish, exercise or defend our legal rights, and to investigate suspected or actual fraud or other illegal activity
  • Third parties in connection with our potential or actual business reorganization (e.g., sale or transfer of all or a portion of our business or assets such as in merger, acquisition, joint venture, reorganization, dissolution, liquidation). The relevant third parties will be required to provide comparable level of protection we provide with respect to your personal information
  • To other persons or entities with your express consent

We do not sell your personal information to other organizations.

4. International Data Transfer

Your personal information may be transferred to, stored and processed in a country which may have different data protection laws than your country of residence or the country in which the information was provided. In particular, your personal information may be transferred to other companies in the GT group and to our third-party service providers which may be located abroad. Laws of some of these countries may not be regarded as providing the same level of protection for personal information as the laws of your home country.

We transfer personal information only for the purposes described in this Privacy Policy and take reasonable steps (including contractual commitments) to provide adequate protection for your personal information wherever it is located, in accordance with the standards of protection under applicable law.

5. Third-Party Websites and Information Collection

Our website, web platforms and mobile applications may contain links to other websites and online services operated by third parties. Such third-party websites may have privacy policies and practices different from ours. We do not control and are not responsible for the policies or practices of such third-party websites and services. This Privacy Policy applies only to our website, mobile applications and other data collection mechanisms. Please contact third parties directly for information regarding their privacy policies.

6. How We Store, Protect and Dispose of Your Personal Information

Your personal information may be stored and processed in your region or in another country where GT, its affiliates and service providers maintain servers and facilities. We take reasonable measures to ensure that your information remains protected wherever it is located, in a manner consistent with applicable law and this Privacy Policy.

We use appropriate and reasonable organizational and technical measures designed to safeguard your personal information. It is also important that you guard against unauthorized access to your passwords and the unauthorized use of your computer and mobile devices. However, no IT system or network can be 100 percent secure so we cannot guarantee the absolute security of your personal information from hacking, other illegal activities, or equipment and network failures. If you have a reason to believe that your interaction with us is no longer secure or the security of your personal information with us has been compromised, please notify us immediately at legal@globaltransact.com.

We retain your personal information only for as long as it is necessary to accomplish the purposes for which it was provided, in accordance with applicable law, government regulations or court orders, this Privacy Policy, GT's records management policy, and contractual provisions.

Once personal information provided to GT is no longer needed to accomplish the purposes for which it was collected, it will be is disposed of or destroyed in a manner that prevents loss, theft, misuse, reconstitution, or unauthorized access to the information.

7. Children's Privacy

Our website and mobile applications are intended solely for use by individuals 18 years of age or older and therefore are not designed for or directed at children under 18 years of age. We do not knowingly collect information from children under the age of 18.

If you believe that we have collected personal information from a child under the age of 18, please contact us by using the information in the "Contact Us" section below, and we will make reasonable efforts to delete such information from our records.

8. Your Rights Over Your Personal Information

In certain countries, data protection and privacy laws may provide you with certain rights regarding the personal information we collect about you. These laws may include the rights to: Request access to your personal information

  • Request access to your personal information
  • Request correction (rectification) of your personal information
  • Request erasure (deletion) of your personal information
  • Request transfer of your personal information
  • Request restriction of processing your personal information
  • Object to processing of your personal information
  • Request transfer of your personal information

You may also have the right not to be discriminated against for exercising any of your privacy rights. For more information about your rights, visit the website of your country's data protection authority.

GT does not make decisions about you based solely on automated personal information processing.

If you would like to update or correct the personal information we hold about you, or to discuss or exercise other rights you may have under applicable local law, you or your authorized representative may contact us at legal@globaltransact.com or write to:

Global Transact, LLC
Attn: General Counsel
1703 W Huron Street
Chicago, IL 60622 USA

If you request that we delete your personal information, please note that such a request is subject to certain limitations. We may still retain your personal information as allowed by law, e.g., for tax and other record keeping purposes or to fulfil our contractual obligations with you.

If you make a request, we will respond to you within 30 days of receipt unless a different time period is specified in applicable law. It could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please note that we may require additional information from you or your authorized representative to verify your identity and honor your request. 

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If you are not satisfied with our response, you may have the right to complain to the data protection authority of your country of residence.

There is no charge for you to access your personal information or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your requests in these circumstances.

9. Updates to Privacy Policy

To reflect changes in our systems and business practices, this Privacy Policy may be updated periodically and without notice. Any changes to the Privacy Policy will be posted on the GT website and in our mobile applications with an updated revision date. Your use of our website and mobile applications after the revised Privacy Policy is posted signifies your acceptance of the revised Policy. If we make any revisions that materially change the ways in which we process your personal information, we will notify you of these changes before applying them to that information.

10. Contact Us

If you have questions, comments, requests or concerns regarding this Privacy Policy or our processing of your personal information, please contact us at legal@globaltransact.com or write to:

Global Transact, LLC
Attn: General Counsel
1703 W Huron Street
Chicago, IL 60622 USA

Effective date: 20 August 2023

This Privacy Policy replaces the Privacy Policy dated 9 October 2020.