GlobalReach Technology EMEA Limited is a company incorporated and registered in England and Wales with company number 11104294 with its registered office at 110 Cannon Street, London, EC4N 6EU.
GlobalReach Technology Inc. is a company incorporated and registered in Delaware, USA with company number 6621093 with its registered office at 21600 Oxnard St, 19th Floor Woodland Hills, CA 91367.
For the purpose of data protection laws in the UK, GlobalReach Technology EMEA Limited is the data controller and is therefore responsible for your personal data.
Personal data we collect
Personal data means any information about an individual from which that person can be identified. It does not include data where your identity has been removed or not associated with or linked to your personal data (anonymous data).
We may collect, use, store and transfer the following kinds of personal data about you:
- Identity data includes your first name, last name, title, gender.
- Contact data includes your address (home, postal or other physical address), email address and telephone numbers.
- Transaction data includes details about payments to and from you and other details of services you have purchased from us and our fulfilment of your order.
- Profile data includes, in relation to your customer account, details of your interests, preferences, feedback and survey responses.
- Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Technical data includes traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access our website.
- Usage data includes information about how you use our website.
Please note that where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services that you request). In this case, we may have to cancel a service you have requested but we will notify you if this is the case at the time.
How we collect personal data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity and contact data by filling in forms, by corresponding with us via our website or by post, phone or otherwise, when you register with us, subscribing to any services we offer, downloading information posted on our website, requesting information or further services from us, or when you enter into a contract with us.
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual equipment, browsing actions and patterns.
The purposes for which we use personal data
We will only use your personal data when the law allows us to. We may collect and process the following personal data about you for the purposes specified:
- Registration. Identity and contact data that you provide at the time of registering to use our website or subscribing to our services will be used for the purpose of providing you with the services that you have subscribed to.
- Enquiries. If you contact us, we will use the identity and contact data that you supply in order to deal with and/or respond to your request or as is necessary for the performance of a contract with you or in order to take a step at your request prior to entering into a contract and/or where such processing is in our legitimate interests. We may also retain a record of that correspondence.
- Performance of a contract. We will process your identity, contact, and transaction data where it is necessary for the performance of a contract we are about to enter into or have entered into with you.
- Advertising, marketing and public relations. We may use your identity, contact and profile data to form a view on what we think you may want or need, or what may be of interest to you as our customer and in doing so we may periodically send promotional emails about new services, special offers and other information that is deemed relevant to your use of our services. This is necessary for our legitimate interests in growing and developing our business including our services. You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, have not opted out of receiving that marketing. We will however ask for express consent before we share your personal data with any third party for marketing purposes. You can ask us to stop sending marketing communications at any time by contacting us.
- Surveys. If you choose to complete a survey that we use for research purposes we will retain the information that you provide in response to that survey. This is necessary for our legitimate interest in understanding our customers and developing our business and informing our marketing strategy.
- Administration. We may use your identity, contact and technical data for the purpose of protecting our business and our website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. This is necessary for our legitimate interest in running our business, the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, and for compliance with our legal obligations.
- Website analytics. As you navigate our website, technical and usage data may be collected automatically. We do this to find out things such as the number of visitors to the various parts of the website, and to help us to improve the content of the website and to customise the content or layout of the website for you, in accordance with our legitimate interests. This is necessary for our legitimate interest in defining types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
- Fault reporting. If you contact us to report a fault with our website, we will use the identity and contact data provided for the purposes of rectifying that fault in accordance with our legitimate interests.
- Recruitment. Personal data provided for an employment opportunity will be processed so as to allow us to process and evaluate the merits of that application in accordance with our legitimate interests.
We may also use personal data which you provide to us, where the law allows us to do so, as follows:
- To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we need to comply with a legal or regulatory obligation, including the prevention of crime.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We will only use your personal data 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of personal data to third parties
Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not be disclosed to any other individuals or other entities except in the following circumstances:
- On occasion, we need to hire other companies to help us to serve you better and in some of these cases, we may need to share personal data that is necessary to perform tasks for us, such as market research companies.
- Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
- Where we are under a legal duty to do so in order to comply with any legal obligation.
- In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as such terms are defined in section 1159 of the UK Companies Act 2006 (as amended from time to time).
If we or substantially all of our assets are acquired by a third party, in which case personal data that we hold about our customers will be one of the transferred assets.
We require all third parties that process personal data on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. We urge you to take every precaution to protect your personal data when you are on the internet.
Some of our employees and certain of our group companies are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You have the right to:
- Request access to your personal data commonly known as a “data subject access request” (DSAR). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new personal data that you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) links on any marketing message sent to you or by contacting us at any time.
- Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, service experience or other transactions.
You will not have to pay a fee to access your personal data 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 request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Other websites and links
Our website may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy policies or for the content, accuracy or opinions expressed in such websites. We do not investigate, monitor or check third party websites for accuracy or completeness and the inclusion of any linked website on or through our website does not imply approval or endorsement by us of the linked website.
GlobalReach Technology may from time to time send push notifications. “Push notification” means a message which is delivered directly by GlobalReach Technology to your device during the course of providing the services to you. You can change your push notifications preferences to opt-out (or to request and enable push notifications) at any time by modifying the settings within your device’s notification settings.
From time to time GlobalReach Technology may insert a tracking pixel into our marketing emails that you have signed up for, or requested, these are used to gauge feedback from our marketing interactions, this data is never sold or passed on to third parties and is used for the sole purpose of evaluating marketing campaigns. You may opt-out of our marketing notifications at any time. Your email application should allow you to block such tracking pixels if you wish.
Controlling your personal information
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
The information you provide to us will be held on our computers and may be accessed by any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time (if any). We may also use your information to send you offers and news about our services or those of other carefully selected companies which we think may be of interest to you. We may contact you by post, email, telephone or fax for these purposes.
You have the right to ask us not to process your personal data for marketing purposes. If you do not wish to be contacted by us with information about our services or those of other companies or you want to limit the way in which we may contact you please e-mail firstname.lastname@example.org
We may also pass your information on to any successor or potential successor in title to our business and suppliers that process data on our behalf both in the United Kingdom and abroad. We may also use and disclose information in aggregate (so that no individual customers are identified) for marketing and strategic purposes.
Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.
If you believe that any information we are holding about you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our GDPR statement is located here – https://globalreachtech.com/gdpr
Information on our ISO27001 accreditation – https://globalreachtech.com/iso-27001
Contact us electronically here – https://globalreachtech.com/contact
UK postal details
GlobalReach Technology EMEA Limited
110 Cannon Street, London, EC4N 6EU
US Postal Details
GlobalReach Technology Inc.
21600 Oxnard St, 19th Floor Woodland Hills, CA 91367
Updated: February 2021