Privacy Policy

Welcome to the privacy policy of Globy, Inc. (herein as "Globy," "we," "us," or "our").

Globy provides this website and associated B2B marketplace, tools, and software (collectively, the "Globy Services").

Globy values your privacy and the protection of your personal data. This privacy policy describes what information we collect from you, how we collect it, how we use it, how we obtain your consent, how long we keep it in our databases, with whom we share it, and the rights that apply to you.

By using the Globy Services, providing any of your personal data to us, and agreeing to the terms of the privacy policy, you confirm that:
(I) you have read, understood, and agree to this policy;
(II) you have reached the age from which the legislation of the country of your stay allows you to give consent to the processing of your personal data. In any case, in order to use the Globy Services, you must be at least 16 years old (at least 13 years old in certain regions) or one of your legal representatives or guardians must have read and agreed to the terms of the privacy policy on behalf of you.

Your use of the Globy Services is also subject to our Terms and Conditions. Please ensure you review it to understand the conditions with which you must interact with the Globy Services.

In this privacy policy, the words "you", "your" and "user" refer to you, the user of the Globy Services (including Suppliers, Buyers, and website visitors).

1. GENERAL INFORMATION; DATA CONTROLLER

The personal data of users that are collected and processed through this website is controlled by:

GLOBY, Inc
Globy Inc., 1216 NE 63rd St, Vancouver, WA 98665, United States
[email protected]

Under the General Data Protection Regulation (GDPR) and similar laws, we are your "Data Controller," as we decide how your personal data is handled when you use the Globy Services.

1.1. EU REPRESENTATIVE

Globy has appointed a representative in the European Union in accordance with Article 27 of the General Data Protection Regulation (GDPR).

EU Representative details:
GLOBY TRADE & LOGISTIC LIMITED
Archiepiskopou Makariou III, 9 5, CHARITINI COURT, 1st floor, Flat/Office 102
1071, Nicosia, Cyprus
[email protected]

The EU Representative is mandated by Globy to be addressed, in addition to or instead of Globy, by data subjects located in the European Economic Area and by EU supervisory authorities on all issues related to the processing of personal data for the purposes of Article 27 GDPR, including communications in relation to compliance and the exercise of data subject rights.

The appointment of the EU Representative does not affect Globy's responsibility or liability under the GDPR.

2. HOW WE OBTAIN YOUR CONSENT

We process personal data only where we have a lawful basis under applicable data protection laws (including GDPR). Creating an account and using the Globy Services requires processing that is necessary to perform a contract with you or to take steps at your request prior to entering into a contract. Where we rely on consent for a specific processing activity, we will request it separately and you may withdraw it at any time by sending us your request through our contact information.

By creating an account and using the Globy Services, you acknowledge this privacy policy. We process personal data primarily to perform our contract with you (Art. 6(1)(b) GDPR) and to comply with legal obligations (Art. 6(1)(c) GDPR). Where we rely on consent for a specific purpose, we will request it separately and you may withdraw it at any time.

3. TYPES OF DATA COLLECTED

The data we collect from our users helps us to continually improve the user experience on the website and provide our services appropriately. These are the types of data we collect:

1. Information you provide to us. You provide personal data when you visit the website, register as a user (Supplier and Buyer), post products to the B2B Market (Supplier), contact a Supplier (Buyer), make a sourcing request (Buyer), use the instant freight calculator (Quick Logistics), post an unclaimed cargo, contact a seller (unclaimed cargo), contact us through our contact information and contact forms and provide personal data to communicate with you. As a result of those actions, you may provide us with the following data:

   • Name
   • E-mail address
   • Phone
   • Address, State, County, ZIP Code, City
   • Company name
   • Office address
   • Year of foundation
   • Number of employees
   • Annual revenue
   • Company social links
   • Any additional information related to you that you provide to us through our website for the purposes of using the Globy Services (e.g., in messages, listings, or support requests).

   Globy collects personal data that you provide directly (e.g., when you register or contact us) and may also collect certain technical and usage data automatically (e.g., IP address and device identifiers) when you use the website, as described below.

   Contact information: We may access some personal data about the user, such as name and email address, when the user or any third party communicates with us through our contact information. Personal data provided through our contact information is processed using our email service provider acting as a processor on our behalf. We access such communications as necessary to respond to inquiries and provide support, subject to retention limits described in this privacy policy.

   Verification information: The Globy Services may provide Suppliers with the option to verify their profiles and provided data to receive a verified badge. We use Vespia for verification, and they may, on our behalf, process verification information, which may contain personal data such as verified corporate information. Vespia will handle the data processing in accordance with its privacy policy. Verification data is used solely to verify supplier profiles and prevent fraud and misuse.

   Payment information: You may submit payment method information to Stripe through our website. This may include personal data as your credit card information and billing details. This personal data is automatically directed to Stripe, third-party payment processor, and is used only to process Seller banner advert subscriptions or any other paid Globy services on our website. We do not store and process your full payment card details on our servers; we may receive limited payment-related data from Stripe such as transaction status, time and date, and billing details necessary for invoicing and record-keeping. You can review Stripe's privacy policy to understand how they protect your payment method data. The personal data related to payments will be stored on servers managed by Stripe, Inc. (or its affiliated entities or subprocessors), a payment processing service headquartered in the United States. Stripe stores payment data on its secure servers located in compliance with applicable data protection laws and standards, including in the United States. You can find out more about the privacy policy of Stripe, Inc. at the link: https://stripe.com/privacy.

   User content: Globy collects and processes user content, which includes personal data entered on our website (including photos, feedback, seller listing, etc.), solely for the provision and improvement of the Globy Services and performing our contract with you, and where applicable, based on our legitimate interests in maintaining and improving the Globy Services and ensuring website safety. We are committed to maintaining the confidentiality and security of this content and may disclose it only where necessary for the operation of the Globy Services to third-party service providers acting on our behalf, where required by law, or to protect the rights and safety of Globy and its users. Users have the right to access, modify, and request deletion of their information, in accordance with our data retention policies and applicable law. Use of our website implies consent to the processing of this data as described in this privacy policy.

   Automatic collection of personal data. As you browse our website, certain usage data is automatically collected using cookies (see our Cookie Policy for more about cookies). These include technical personal data such as the IP address of your device, the type and version of your browser, the specific pages you visit on our website, the date and time of your access, the amount of time you spend on those pages, and other diagnostically relevant data.

   In the case of access via mobile devices, we also collect data specific to use, its unique identifier, the IP address of the device, the mobile operating system, and the type of mobile browser, along with other identifiers and diagnostic data. In addition, we collect data that your browser automatically provides each time you visit our website or access our website using a mobile device. We process this technical usage data to operate the website, ensure security, prevent fraud and abuse, troubleshoot errors, and improve performance. The legal basis is our legitimate interests in operating and securing the website and, where applicable, to perform our contract with you when you use authenticated features.

   Google Analytics and Mixpanel: We use analytics tools like Google Analytics provided by Google, Inc., USA ("Google") and Mixpanel. These tools and technologies collect and analyze certain types of data, including IP addresses, device and browser identifiers, referring and exit URLs, feature use metrics and statistics, usage history related to your interaction with the website, media access control address (MAC Address), mobile unique device identifiers, and other similar data via the use of cookies. The data generated by Google Analytics and Mixpanel (including your IP address) may be transmitted to and stored on servers in the United States. We use Google Analytics and Mixpanel collection of data to enhance the website and improve the Globy Services.

   You can opt out of analytics tracking. You can install the Google Analytics Opt-out Browser Add-on for Google Analytics. You can install other browser extensions for blocking analytics in general. You can also simply block analytics cookies through your browser cookie settings.

   For more about analytics, please consult Google's privacy policy here.

   Social Media: On our website, we provide you with a variety of links and tools that allow you to interact with various social networks. You are welcome to use these functions to share your data as you wish. However, we strongly recommend that you review the privacy and data protection policies of each of the social networks you use through our website to understand how they handle your personal information.

   • Facebook
   • Twitter
   • YouTube
   • Linkedin

   Transaction details: Stripe, our payment process may provide us with data about banner subscription purchases. This may include the name of the purchaser, payment method used, time and date, billing address, and similar data.

   Sensitive data: Some of the data we collect may be sensitive data, as per laws such as the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). We exercise additional protection on such data. For example, we do not directly collect and store any payment information but rather allow our payment processor with adequate protection collect it directly.

   Your permissions: We may access certain data about you strictly when you permit it. For example, we may access your social media account data when you register using the social feature; or we may access your device file manager and gallery to import your media. Where we access your privacy via these permissions, you may revoke access at any time you so wish.

4. HOW LONG WE KEEP YOUR DATA

Personal data provided by our users through our website will be kept for the time necessary to adequately provide our services and fulfill the legitimate purposes described in this policy in section 5 or until the user closes the user account or requests the deletion of their data, unless a longer retention period is required or permitted by applicable law. Globy may retain personal data for a longer period only where such retention is necessary for a specific purpose and has a valid legal basis under GDPR for the purposes described in section 5 of this privacy policy. In addition, Globy may be obliged to retain personal data for a longer period provided that this is required for compliance with a legal obligation or by order of an authority. Once the retention period has expired, the personal data will be deleted. Where personal data has already been deleted, we may be unable to provide access to such data, without prejudice to the data subject's rights under GDPR.

5. HOW WE USE YOUR PERSONAL DATA

In general, we use the data we collect primarily to provide, maintain, protect and improve our website and to provide Globy Services properly. We use the personal data collected through our website as described below:

Performance of a contract (Art. 6(1)(b) GDPR). We process personal data on this legal basis where it is necessary to provide the Globy Services and perform our contractual obligations to you, including:

• For user registration and account management (for Suppliers and Buyers).
• To facilitate the publication of products on the B2B Market.
• To facilitate Suppliers contact with Buyers and vice versa.
• To send Buyers sourcing requests to Suppliers.
• To facilitate the publication of unclaimed cargoes.
• To facilitate contact with Sellers (unclaimed cargo).
• To provide our freight calculator (Quick Logistics).
• To enable users to calculate the load of items using the Load Calculator.
• To process Seller banner ad payments.
• To facilitate communication between users (chat).
• To respond to your comments or questions through our support service.
• To send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

Legitimate interests (Art. 6(1)(f) GDPR). We process personal data on this legal basis where it is necessary for our legitimate interests (e.g., security, fraud prevention, and strictly necessary service improvement), provided such interests do not override your fundamental rights and freedoms, including:

• To verify Sellers to keep our website safe from fraudulent listings and illegal activities.
• To link or combine your information with other data we obtain from third parties to help us understand your needs and provide you with better service.

Legal Obligation (Art. 6(1)(c) GDPR). We process personal data on this legal basis where it is necessary to comply with legal obligations, including:

• To keep records of transactions as required by law and for accounting and tax purposes.
• To send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

Consent (Art. 6(1)(a) GDPR). We rely on your consent where required by applicable law for specific purposes, including:

• To understand how our website is used and improve user experience.
• To send you relevant information about our website and the Globy Services.
• For marketing purposes of Globy.
• To link or combine your information with other data we obtain from third parties to help us understand your needs and provide you with better service.

In rare cases, we may process personal data to protect your vital interests or the vital interests of another individual, such as in emergencies requiring immediate intervention.

6. HOW WE SHARE PERSONAL DATA

7. MARKETING

Email marketing: By using the website and Globy Services, you consent to the use of your personal data, including name and email address, for the sole purpose of receiving service-related communications about our website and the Globy Services (e.g., account, security, billing, and support messages). Such communications are not marketing and are sent without requiring your consent, as they are necessary for the performance of our contract with you or compliance with legal obligations. Globy respects your privacy and does not share this data with unauthorized third parties. We send marketing communications only where required on the basis of your prior opt-in consent. If you wish to stop receiving marketing communications, you can unsubscribe at any time by using the "unsubscribe" option available in the same marketing emails or by sending your request through our contact information.

Interest-based advertising: Globy uses interest-based advertising to deliver targeted advertisements tailored to your preferences and browsing habits. Where required by applicable law, we enable interest-based advertising and related profiling only after obtaining your opt-in consent. This means that we, or third-party advertising service providers acting on our behalf, may collect information about your online activities over time and across different websites, applications, and other online services to show you ads that are more relevant to your interests. You can withdraw your consent at any time and you have the right to object to processing of your personal data for direct marketing purposes, including related profiling.

We use cookies, pixels, and similar tracking technologies to gather analytics and your interests, including your clicks, searches, pages accessed, IP address, and so on. This data is used to create profiles that help us and our third-party advertising partners deliver personalized advertisements, measure the effectiveness of these advertisements, and better understand your interests.

We work with third-party ad networks, including Google Ads, Facebook Ads, and similar platforms, to serve personalized advertisements. These networks use their own cookies and tracking technologies to collect data about your online behavior. The information collected by these third-party networks is subject to their respective privacy policies.

For more information about Google's advertising practices, visit their Privacy & Terms page. For more information about Facebook's advertising practices, visit their Data Policy.

Managing Your Preferences: You can opt out of interest-based advertising by adjusting your cookie preferences on our website or through your browser settings. Additionally, you can use tools such as:

• The Network Advertising Initiative's (NAI) opt-out tool.
• The Digital Advertising Alliance's (DAA) opt-out tool.
• The Your Online Choices platform for EU users.

Please note that opting out of interest-based advertising does not mean you will stop seeing ads. Instead, the ads displayed on the website may be less relevant to your interests.

8. PROTECTION OF YOUR INFORMATION

In some instances, to ensure the proper functioning of the website, certain categories of our employees (such as administrative staff) or third-party service providers (e.g., independent technical service providers, hosting providers, IT services, and communication services) may have access to your personal data. You may request a list of such third parties from us at any time.

We ensure that access to your personal data is provided only to those third-party companies and individuals that can guarantee the highest level of data protection, confidentiality, and security, and who will use your personal data solely for purposes consistent with this policy and in compliance with applicable data protection laws. We limit the data provided to such service providers to that reasonably necessary for them to perform their functions (a need-to-know basis).

We adhere to industry-recognized security standards to protect your personal data, both during transmission and in storage. However, it is important to note that no method of transmission over the Internet or electronic storage is foolproof and 100% secure. Therefore, while we at Globy strive to implement commercially viable data protection methods, we cannot ensure the absolute security of your personal data. We regularly review and update our security measures in light of the risks and the nature of the data processed. We do not sell your personal data. We may disclose personal data to service providers acting on our behalf and other recipients where necessary to provide the Globy Services, comply with legal obligations, protect our rights and safety, or based on other lawful grounds under GDPR.

9. DATA BREACH NOTIFICATIONS

In the event of a personal data breach, we are committed to responding swiftly and in accordance with applicable data protection laws, including the GDPR and relevant local regulations, by promptly assessing the breach, notifying the relevant supervisory authority, within 72 (seventy-two) hours of becoming aware of the breach, providing all necessary details. Unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons where the notification is not made within 72 (seventy-two) hours, it could be accompanied by reasons for the delay.

10. INTERNATIONAL DATA TRANSFER

We collect and process personal information in the United States. However, we may maintain and transfer personal data on servers outside of the United States. We may also transfer information to our third-party service providers in their respective locations. This may occur when we use third-party services like Google Analytics, Mixpane, Vespia which may store and process personal data on servers located in various jurisdictions. Please be aware that when your personal data is transferred to third countries, such countries may have data protection laws that differ from, and in some cases provide less protection than, the data protection laws in your country. Nevertheless, we are committed to ensuring that any such transfer of your personal data is conducted in full compliance with applicable data protection regulations, including but not limited to the GDPR. By using our website, you agree that your personal data may be transferred and processed outside your home country, where data protection laws may be different from those of your country. Globy is committed to taking the necessary steps to ensure that your data is treated in accordance with applicable privacy protection rules and is adequately protected during any international transfer.

If we transfer personal data about users in the EU, EEA, and countries under the GDPR and similar laws, we rely on the approved data transfer mechanisms by these laws. Specifically, we use one of the following safeguards:

Transfer based on adequacy decisions. Whenever possible, we rely on adequacy decisions issued by relevant authorities to transfer personal data to countries or international organizations that provide an adequate level of protection.
European Commission: for transfers from the EU, adequacy decisions are adopted by the European Commission. You can access the full list of countries and international organizations that have been deemed adequate by the EC on their official website.
UK Secretary of State: for transfers from the UK, adequacy decisions are adopted by the UK Secretary of State. The full list of countries with adequacy status is available on the website of the Information Commissioner's Office (ICO).
Federal Council (Switzerland): adequacy decisions for transfers from Switzerland are listed in Annex 1 of the Data Protection Ordinance (O-FADP), which details states, territories, or sectors with adequate data protection.

Additionally, We may transfer Personal Data to service providers in the United States that participate in the EU-U.S. Data Privacy Framework, which is subject to an adequacy decision by the European Commission. This also includes the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework. These frameworks provide specific safeguards for transfers of personal data between the EU, UK, Switzerland, and the U.S. For more information on the Data Privacy Framework (DPF) program, please visit: https://www.dataprivacyframework.gov/.

Transfer in the absence of an adequacy decision. In cases where personal data is transferred to a country that has not been deemed to provide an adequate level of protection by the European Commission or other legal authorities, we will implement appropriate safeguards to protect your data, including but not limited to: Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), explicit consent, other legal mechanisms.

Third parties whose services we use. We use several third-party service providers for various operational needs, which may involve the cross-border transfer of your personal data. These providers, including Google LLC, Stripe, Inc., Mixpanel, Inc., Meta Platforms, Inc. which are certified under the EU-U.S., UK-U.S., and Swiss-U.S. Data Privacy Frameworks.

We will take all necessary measures to ensure that your personal data is treated securely and in accordance with this policy.

11. YOUR PRIVACY RIGHTS

You can exercise any of these rights by contacting us using the following email address: [email protected]. Please note that before providing the information according to your request, we may ask you to provide additional data to confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

In the event that we receive your request, we will endeavor to respond as soon as possible, but no later than 30 (thirty) calendar days from the date of receipt of the request. You can edit your personal data from the settings section of your account through the website interface.

12. PROTECTION OF CHILDREN'S ONLINE PRIVACY

We comply with the requirements of national and international data protection regulations regarding the protection of personal data of minors.

We knowingly do not process the personal data of children under the age of 13 (applies to users who are residents of countries with a reduced minimum age for personal data processing) and children under 16, and we also do not offer them to use the Globy Services.

If we become aware that a person who has not reached the age from which it is permitted to process their personal data has provided us with their personal data without the consent of a legal representative, guardian, or other person authorized to provide such consent, we will take all necessary measures to delete such data. If you believe we might have any information from or about a child under 16 (or 13 if applicable), please contact us at [email protected].

We disclaim any responsibility or liability in the event that a person under the legal age for personal data processing begins using the Globy Services and provides their personal data without obtaining the necessary consent from their legal representatives.

It is the responsibility of such persons or their guardians to ensure that the appropriate consent is obtained prior to using the Globy Services. You must be of legal age to be in line with our privacy policy, as well as with our terms and conditions.

13. DO NOT TRACK SIGNALS

Globy does not currently respond to "Do Not Track" (DNT) signals sent by browsers. "Do Not Track" is a privacy preference that users can set in their web browsers to inform websites that they do not want certain data about their browsing activity collected. Because there is no consistent standard for handling DNT signals across the internet, Globy does not treat browser "Do Not Track" signals as a valid mechanism to express consent, withdraw consent, or object to processing under GDPR.

Where required by applicable law, we enable non-essential tracking only after obtaining your consent via our consent mechanism, and you can change your choices at any time.

14. THIRD PARTIES

Except as expressly included in this privacy policy, this document only addresses processing of personal data that Globy collects from you through our website. If you disclose your personal data to third parties, different rules may apply to their use or disclosure of the data you disclose to them. Globy is not responsible for the privacy or security practices of third parties, including those linked to or from the website. Please refer to the privacy policies of any third-party websites or services you access through the website.

15. ADDITIONAL INFORMATION FOR RESIDENTS OF THE UNITED STATES OF AMERICA

This section applies only if you are a resident of certain U.S. states that have implemented state-level privacy laws. You, as a subject of personal data, have some special privacy rights. To use them, please contact us at [email protected].

Please note! Depending on the state and legislative requirements, we have from 30 (thirty) to 60 (sixty) days to exercise your request, with the right to postpone it for 30 (thirty) days more.
If your complaint is not satisfied, you can file a complaint with the Federal Trade Commission.

Also, you may submit a complaint as follows:
For Colorado residents, to the Colorado AG at https://coag.gov/file-complaint/
For Connecticut residents, to the Connecticut AG at https://www.dir.ct.gov/ag/complaint/
For Montana residents: https://dojmt.gov/consumer/
For Oregon residents: https://justice.oregon.gov/consumercomplaints/
For Texas residents: https://oag.my.salesforce-sites.com/CPDOnlineForm
For Utah residents: https://attorneygeneral.utah.gov/contact/complaint-form/
For Virginia residents, to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform
For residents of Florida at https://www.myfloridalegal.com/consumer-protection/consumer-complaint-form

Your rights vary depending on the laws that apply to you, but may include:

Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us, [email protected].

Access to specific data and the right to transfer data

With certain exceptions, if you are a resident of the state of California, USA, you have the right to request a copy of the personal data (defined as personal information for the purposes of this section) we have collected about you in the 12 (twelve) months prior to your request. After receiving your request and establishing your identity, we will inform you of:
– categories of personal information that we have collected about you;
– our business or commercial purpose for collecting such personal information;
– categories of third parties with whom we share this personal information.

Also, if you are an Oregon resident, you also have the right to receive a list of the specific third parties to which we have disclosed personal data in our capacity as a controller, provided that we are not required to disclose its trade secrets.

To exercise your rights, you may submit the request by sending an email to: [email protected]. We will ensure that your request is processed in accordance with the relevant legal requirements. We may require specific information from you to help us confirm your identity and process your request. You have the right not to be discriminated against for exercising any of your rights.

Non-discrimination

We will not discriminate against you for exercising your rights related to the processing of your personal information, as well as your right to refuse to receive Globy Services in the future, or for refusing to receive further marketing, informational / advertising materials from us.

Do not sell and share my personal information

California residents have the right under the California Consumer Privacy Act as well as California Privacy Rights Act to opt out of the "sale" and "share" of their personal information by a company governed by CCPA. If you are a resident of other US states that give you rights to opt out of "sale", "share" and / or use of personal information for "targeted advertising", you may also find this information helpful.

In exceptional cases, we may share your personal information as it is described in section 6. We do not and will not "sell" your personal information, but we recognize that the CCPA defines "Personal information" in such a way that providing access to identifiers associated with You may be considered a "sale". In the event that these website visitor identifiers and inferences may be identified as a sale under the CCPA, please use the "Do not sell and share my personal information" setting on the website's home page. After receiving your request through the "Do not sell and share my personal information" setting, we make a corresponding entry in our database of personal information, which indicates that we are aware of the impossibility of further selling your personal information. Also, if you would like to record your preference that we will not "sell" and "share" your personal information in the future, please contact Us via [email protected].

Finally, if your browser supports it, you can use the Universal Opt-Out Mechanism mentioned below.

Universal Opt-Out Mechanism

For residents of California, Colorado, Connecticut, New Hampshire, Texas, Montana, New Jersey, Minnesota, Delaware (effective from 01/01/2026), Oregon (effective from 01/01/2026), Maryland (effective from 01/04/2026) We recognize the Global Privacy Control ("GPC") signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States, and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect Personal information.

In order to be in line with Fair Information Practices We will take the following responsive action, should a data breach occur:
- we will notify the users via website notification within 7 (seven) business days.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and / or prosecute non-compliance by data processors.

16. CHANGES TO PRIVACY POLICY

We reserve the right to change our privacy policy at any time. Changes will be notified to our users in a timely manner and posted on the website. Your continued use of our website and our services following these changes constitutes acceptance of the changes.

17. GOVERNING LAW AND JURISDICTION

This privacy policy shall be governed by and construed in accordance with the federal laws of the United States of America and, to the extent applicable, the laws of the State of Washington, without regard to its conflict of laws principles. Any dispute, claim, or controversy arising out of or relating to this privacy policy or Globy's processing of personal data shall be brought exclusively in the U.S. District Court for the Western District of Washington or, if such court lacks subject matter jurisdiction, in the state courts located in Clark County, Washington. Each party irrevocably submits to the personal jurisdiction and venue of such courts and waives any objection based on inconvenient forum or improper venue. This applies unless binding arbitration is agreed to in the applicable section.

18. CONTACT INFORMATION

If you have questions or concerns about this privacy policy and the treatment and security of your data, please contact us using the contact information below:

For GDPR-related matters in the European Economic Area (including requests to exercise data subject rights and communications with EU supervisory authorities), you may also contact Globy's EU Representative appointed under Article 27 GDPR: