Global-e Privacy and Cookies Policy
This Privacy and Cookies Policy (“Policy”) governs how we, Globale U.K. Ltd. (together with our respective affiliates and subsidiaries, "Global-e", "we", "our" or "us"), collect, receive, use, store and disclose Personal Data (defined below) about individuals in connection with the use of our online order processing and fulfilment services (the “Service”).
We make great efforts ascertaining that your Personal Data is safe and used properly.
This policy explains our privacy practices for processing Personal Data regarding our Services (as defined below). The processing of your Personal Data is subject to the terms of this policy.
The summary of this Policy will give you a quick and clear view of our practices. Please take the time to read our full Policy.
If you do not wish us to collect your information, please do not submit it to us. However, please bear in mind that we will not be able to process your order without receiving your details.
The Personal Data That You Provide Us – If you use the Service, we will need your Personal Data (such as your name, email address and physical address) to process the transaction and deliver the purchased products. We will need your payment details to process your payment. We will also receive any Personal Data that you provide us when you contact our customer support.
The Personal Data That We Collect – We automatically log 'traffic/session' information including IP addresses and your user agent. We collect session durations and additional activity information.
What Do We Do with the Personal Data? – We use your Personal Data for performing the contract with you and for our related legitimate interests. We maintain the Service, make it better, and continue developing it, and protect us and the Service from misuse and law violations.
Sharing Personal Data with Others – We will share some of the Personal Data that we collect with the specific Retailer who owns or operates the website from which you made your purchase. We will provide the Retailer with your Personal Data for Retailer’s marketing purposes, if you provided your specific consent. We will share your Personal Data with service providers and other third parties, if necessary, to fulfil the purposes for collecting the information, provided that any such third party will commit to protect your privacy as required under applicable law and this policy.
EU-US Privacy Shield – We are self-certified to the EU-US Privacy Shield Framework, in connection with processing Personal Data from EU member states. The Federal Trade Commission (FTC) has jurisdiction over our compliance.
Disclosure of Information to Authorities – We may be required by law to disclose information to the authorities.
Sharing Personal Data in case of a Structural Change - a merger, acquisition or any other structural change may require us to transfer your Personal Data to other entities, provided that the receiving entities will comply with similarly protective policy in accordance with applicable law.
Anonymous, Aggregated and Analytical Information – We may use Anonymous Data or disclose it to third parties without limitations provided that the data is not identifiable.
Your Choice – You may terminate your use of the Service. Our Service responds to Do Not Track (DNT) signals.
Other Sites and Services - The Service may contain links to third party websites and services that are subject to their own privacy policies.
Children’s Privacy - We do not intend to collect Personal Data from anyone we know to be under 16 years. If you believe that we might have collected such information, please contact us.
Security and Data Retention – We implement systems, applications and procedures to secure your Personal Data, to minimize the risks of theft, damage, loss of information, or unauthorised access or use of information. We retain data as needed, to provide the Service and for legitimate and lawful purposes.
Your Data Subject Rights – At any time, you may contact us and request to exercise your rights in accordance with the law.
Commitment. We are committed to protecting your privacy.
Global-e Privacy and Cookies Policy
1.Introduction.his Policy explains our online information practices and the choices you can make about the way your Personal Data is collected and used in connection with the Service. "Personal Data" "Personal Data" means any information relating to an identified or identifiable individual including a first and last name an email address, a home or other physical address, or other contact information. It also includes indirect identifiers such as credit card information or online identifiers.
2.Service Terms and Conditions.This Policy forms part of the terms and conditions of our Service (the “Service Terms and Conditions”).
3.Using your Personal Data.If you decide to use the Service and enter into the Service Terms and Conditions with us, we need to collect and use certain of your Personal Data in the ways explained in this Policy in order to provide you with the Service.
4.Modification.We reserve the right, at our discretion, to change this Policy at any time. Such change will be effective thirty (30) days following posting of the revised Policy within the Service, and your continued use of the Service thereafter means that you accept those changes. Global-e will, as necessary, obtain any consents required under applicable laws if it seeks to collect, use or disclose your Personal Data for purposes other than those for which the Personal Data has been collected, unless otherwise required or permitted by law.
5.What Personal Data We Collect and How We Collect It.We receive and/or collect Personal Data from you in the following ways:
5.1.PurchasesThe Service enables you to purchase online merchandise from retailers in certain countries that do not normally provide order processing and fulfilment services (“Retailers”). If you choose to make a purchase, payment and/or place an order via the Service we will require sufficient information, including Personal Data, from or about you in order to process and complete the transaction, as well as to provide subsequent notification and support services. This information may be provided by you to us directly or in certain cases (where you are pre-registered with the Retailer) specific information may be provided by the Retailer to pre-populate transaction forms for ease of completion by you.
5.2.Transaction - we collect information about the item(s) purchased and about you the purchaser, in particular: first name, last name, email and postal address and payment information including the payment method and payment details (with expiration dates) and any payment voucher details that are provided.
5.3.Delivery - we collect information about the preferred shipping and delivery details relevant to the specific transaction and contact details to send notification of the placement shipping and fulfilment of the order.
5.4.Enquiries - when you contact us, or when we contact you, we may receive and process any Personal Data that you provide us.
5.5.Log Files.We may make use of log files that we collect automatically from your computer or device when you interact with the Service. The information contained in log files includes internet protocol (IP) (the unique address that identifies your computer or device on the internet), type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. Such information may be used for legitimate interests such as analysing trends, administering the Service, authentication for security purposes of a user's movement around the Service, and gather broad demographic information relating to how purchasers interact with the Service.
5.6.Cookies and Other Tracking Technologies.See under “cookies” below.
6.2.Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the site owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (though how long will depend on the lifetime of the specific cookie or whether you choose to manually delete such cookies). For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org..
6.3.Cookies are used by us on the website where we provide the Service to you for the following purposes:
6.3.1.Authentication cookies:We use session cookies and / or persistent cookies (up to three days) to enable our Service to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. These cookies allow you to proceed through many pages of the Service quickly and easily without having to authenticate or reprocess each new area you visit. For example, these cookies remember your shipping country and selected currency. They also remember you if you return to the Service.
6.3.2.CUID cookie:This is a persistent cookie which remains on your browser for longer and which collects information about customer behaviour on a Global-e enabled website (which usually sits on the Retailers website domain), in particular regarding a customer's preferred language, country and currency. This information is made available to Retailers, who can disable the cookie if they wish so that it is not placed on your device. The information is used to provide the Retailer with relevant information regarding your preferences, should the Retailer wish to customize or adapt certain parts of the website.
6.3.3.Google Analytics (“GA”) cookies:Google sets persistent cookies (up to two years) to recognize and count the number of site visitors as well as providing other information about the visit such as duration, route through the site and what sites the visitor came from. This information helps us to improve the way our Service works, for example by making sure users find what they need easily. Click here for more information about GA cookies. Click here to opt out of Google Analytics.
7.The Way We Use or may disclose Personal Data.If you submit or we collect Personal Data through the Service, then such Personal Data may be used in the following ways:
7.1.Performance of our contract with you. We will use your Personal Data to provide the Service under the Service Terms and Conditions.
7.2.Legitimate business interests. We will use your Personal Data to improve our Service, to prevent or detect fraud or abuse, to personalise your user experience, to contact you in connection with the Service and any transactions that you have initiated or completed, and to identify and authenticate your access to the parts of the Service that you are authorized to access. Where your Personal Data is needed to fulfil the Service under the Service Terms and Conditions, a failure to provide that information may mean we are unable to complete the transaction meaning that we will refer you back to the specific Retailer.
7.3.Responding to Your Enquiries. We may use your designated email address and contact information for the legitimate purpose of responding to a "Contact Us" or administrative requests submitted by you.
8.Sharing Personal Data with Others.
8.1.Transferring Data to Retailers. In connection with using our Service to make purchases we will share the Personal Data that we collect from you (but with the exception of payment data such as credit card number details) with the specific Retailer who owns and/or operates the website from which you made your purchase. Such Retailer will then be entitled to use your Personal Data as if that Retailer has collected this information directly, subject to the Retailer’s own Privacy Notice. For instance, the Retailer needs to know that you have made a purchase in order to process delivery of your purchase, to handle any requests by you to return or replace a product, or needs to know if you are already a subscriber or member of their services so that you can take advantage of any loyalty scheme that they administer.
8.2.Marketing. While we do not use your Personal Data for our own marketing purposes, we will disclose your Personal Data for marketing purposes to the specific Retailer who owns and/or operates the website from which you made your purchase where you have provided your specific consent via our Service to receive their marketing by either email, telephone, text message or post. In order to understand how the Retailer uses your Personal Data you should check their privacy notice and policies.
8.3.Using Affiliates to Store/Process Data. We may share your Personal Data with our subsidiaries (including, but not limited to, Global-e Australia Pty. Ltd. if purchases are made from Australia) or affiliated companies for the purpose of storing or processing such information on our behalf in connection with our provision of the Service. We require these parties to process such information in compliance with this Privacy and Cookies Policy and subject to security, contractual and other appropriate confidentiality safeguards. Such information may be transferred in this regard to other countries around the world where our or their servers and systems are located. Where you use our Services from Europe to make purchases, your data is stored on servers within the European Economic Area (EEA). In the event however that we transfer such Personal Data outside the (EEA) such transfers will, in the absence of an EC adequacy decision relevant to the destination country or to the transfer, be subject to appropriate EC approved standard contractual clauses relevant to Personal Data transfers between a data controller and a data processor; (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
8.4..Using Third Party Service Providers. We may share (in so far as such sharing is necessary) your Personal Data with our third-party service providers (such as hosting providers, payment processors, anti-fraud service providers, licensed customs brokers, and order fulfilment providers) whose tools, software, and/or services we use to process and complete your transaction(s). We use commercially reasonable efforts to ensure that such third-party service providers will only process your Personal Data as part of providing the Service and subject to security, contractual and other appropriate confidentiality safeguards. Such third-party service providers may be located in countries outside the EEA and if there is a transfer of Personal Data outside the EEA we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient) - https://www.privacyshield.gov/welcome) or enter into appropriate EC approved standard contractual clauses relevant to Personal Data transfers between data controllers or between a data controller and a data processor (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
9.1.Resolution of Privacy Shield queries and complaint mechanism - In compliance with the Privacy Shield Principles, Global-e commits to resolve complaints about our collection or use of Personal Data transferred pursuant to the Privacy Shield Framework. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Privacy officer at: firstname.lastname@example.org. Global-e has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning Personal Data transferred from the EU. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of the EU DPAs are provided at no cost.
9.2.Privacy Shield enforcement – Global-e is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to specific EU Personal Data received or transferred pursuant to the Privacy Shield Frameworks. In certain situations, Global-e may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
10.Necessary Disclosure. We may disclose your Personal Data or any information you submitted via the Service if we have a good faith belief that disclosure of such information is required or reasonably necessary for our legitimate interests to: (i) comply with any applicable law, regulation, legal process or governmental request that we are subject to; (ii) enforce the Service Terms and Conditions, including investigations of potential violations; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Global-e, its users, yourself or the public.
11.Merger, Sale or Bankruptcy.We may disclose or transfer your Personal Data in the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event. In the event that your Personal Data will be used or disclosed for any purposes not covered in this Policy in this regard, then we will seek where possible and within our control to ensure you receive prior notification of the new purpose and where relevant, your consent obtained for those new purposes.
12.Use of Anonymous Data. We may use Anonymous Data (as defined below) or disclose it without limitations, including use and disclosure of Anonymous Data to third party service providers in order to provide and improve our Service and products and enhance your experience with the Service. We may also disclose Anonymous Data (with or without compensation) to third parties, including advertisers and partners. "Anonymous Data" means information which does not enable identification of an individual user so that identification is irreversibly prevented, such as aggregated information about the use of our Service.
13.1.We request and collect minimal personal details that we need for the purposes described in this Policy. At any time you may opt to terminate your use of the Service according to the Service Terms and Conditions (see section 8 - Consumer Cancellation Rights). Thereafter, we will stop collecting any Personal Data from you. However, we may store and continue using or making available certain Personal Data that is related to you. For further information, please read the Security and Data Retention section in this policy.
13.2.Some web browsers offer a "Do Not Track" ("DNT") signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on the Service or through cross-site user tracking. Our Service responds to DNT signals.
14.Other Sites and Services. The Service may contain links to third party websites and services that are not owned or controlled by Global-e including third party payment providers. We are not responsible for the privacy practices or the content of third party websites or services and your use of or connection to such links and websites is at your sole risk. You should review their privacy policies.
15.Children's Privacy. The Service is not structured to attract or be directed to children under the age of 16 years. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 16 years. If we learn that we have collected Personal Data from a child under 16 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at email@example.com.
16.Security and data retention.
16.1.The security of Personal Data is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Data. For example, certain sensitive Personal Data (such as data relating to fraud) that we receive is processed over a Secure Sockets Layer channel and is encrypted; and our payment gateway is Payment Card Industry compliant. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use generally accepted means to protect your Personal Data, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Service, you can contact us firstname.lastname@example.org
16.2.Your Personal Data will be retained by us as necessary to and relevant to our Service Terms and Conditions and our legitimate operations, including time necessary to identify, issue or resolve legal proceedings, enforce our Service Terms and Conditions, to meet our reporting requirements and as otherwise required in accordance with applicable law obligations.
16.3.We will take appropriate steps to delete or permanently de-identify Personal Data at the point this information is no longer needed by us for our legitimate business or legal obligations.
17.Your Data Subject’s rights.
17.1.As an EU resident you may
17.1.1.Access the data that we keep about you. We may need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete or updated, then you may provide us with the necessary information to rectify it.
17.1.2.Contact us if you want to withdraw your consent to the processing of your Personal Data. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
17.1.3.Request to delete or restrict access to your Personal Data. We may postpone or deny your request if your Personal Information is in current use for providing our Services or to other legitimate purposes such as compliance with regulatory requirements associated with Global-e status as seller and exporter on record.
17.2.If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your Personal Data, in accordance with this Policy, will act accordingly.
17.2.1.You may ask to transfer your Personal Data in accordance with your right to data portability.
17.2.2.You may object to the processing of your Personal Data for direct marketing purposes.
17.2.3.You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
17.2.4.You have a right to lodge a complaint with a data protection supervisory authority.
17.3.We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible.
17.4.If you have any concerns about the way we process your Personal Data, you are welcome to contact our data protection team at: email@example.com, or write to us to: Global-e UK Limited 45 Leather Lane EC1N 7TJ London. We will look into your enquiry and make good-faith efforts to resolve any existing or potential dispute with you. If you remain unhappy with the response you received, you can also refer the matter to the UK Information Commissioner
18.Commitment.We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Service to meet these demands. If you have any comments or questions regarding our Privacy and Cookies Notice, or your Personal Data that we may be storing and using, please contact us By email at firstname.lastname@example.org OR By writing to us at: Global-e UK Limited 45 Leather Lane EC1N 7TJ London.
Last updated: February 2018