There are three general categories of information we collect.

1.1 Information you give to us necessary for the use of the Globatalent App or website.

We ask for and collect the following personal information about you when you use the Globatalent App or website. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations (such as anti-money laundering regulations). Without it, we may not be able to provide you with all the requested services.

• Account Information.
When you sign up for a Globatalent account, we require certain information such as your first name, last name, email address, and date of birth.
• Profile Information.
To use certain features of the Globatalent App or website (such as trading certain amounts or receiving a debit VISA), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
• Identity Verification Information.
To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
• Payment Information.
To use certain features of the Globatalent App or website, we may require you to provide certain financial information (like your bank account or wallet ID number) in order to process payments and comply with applicable law.
• Communications with Globatalent and other Members.
When you communicate with Globatalent or use Globatalent App or website to communicate with other Members, we collect information about your communication and any information you choose to provide.

1.2 Information we automatically collect from your use of the Globatalent App or website.

When you use the Globatalent App or website, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Globatalent App or website.

• Geo-location Information.
When you use certain features of the Globatalent App or website, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Globatalent may also collect this information even when you are not using the App if this connection is enabled through your settings or device permissions.
• Usage information.
We collect information about your interactions with the Globatalent App or website such as the pages or content you view, your searches for listings and other actions on the Globatalent App or website.
• Log data and device Information.
We automatically collect log data and device information when you access and use the Globatalent App or website, even if you have not created a Globatalent account or logged in. That information includes, among other things: details about how you’ve used the Globatalent App or website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Globatalent App or website.
• Cookies and similar technologies.
We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Globatalent App or website, or engage others to track your behavior on our behalf.
• Payment transaction information.
Globatalent collects information related to your payment transactions through the Globatalent App or website, including the payment instrument used, date and time, payment amount, payment instrument expiration date and other related transaction details.

1.3 Information We Collect from Third Parties.

Globatalent and the Globatalent App or website may collect information, including personal information, that others provide about you when they use the Globatalent App or website, or obtain information from other sources and combine that with information we collect through the Globatalent App or website. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Globatalent App or website, create and maintain a trusted and safer environment and comply with our legal obligations.

2.1 Provide, Improve, and Develop the Globatalent App or website.

Enable you to access and use the Globatalent App or website. Enable you to communicate with other Members. Operate, protect, improve, and optimize the Globatalent App or website and experience, such as by performing analytics and conducting research. Provide customer service. Send you service or support messages, updates, security alerts, and account notifications. To operate, protect, improve, and optimize the Globatalent App or website and experience, and personalize and customize your experience (such as making listing suggestions or ranking search results), we conduct profiling based on your interactions with the Globatalent App or website, your search and booking history, your profile information and preferences, and other content you submit to the Globatalent App or website. We process this information given our legitimate interest in improving the Globatalent App or website and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

2.2 Create and Maintain a Trusted and Safer Environment.

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity. Conduct security investigations and risk assessments. Verify or authenticate information or identifications provided by you. Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required. Comply with our legal obligations. Resolve any disputes with any of our Members and enforce our agreements with third parties. Enforce our Terms of Service and other policies. In connection with the activities above, we may conduct profiling based on your interactions with the Globatalent App or website, your profile information and other content you submit to the Globatalent App or website, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Globatalent App or website if such processes detect a Member or activity that we think poses a safety or other risk to the Globatalent App or website, other Members, or third parties. We process this information given our legitimate interest in protecting the Globatalent App or website, to measure the adequate performance of our contract with you, and to comply with applicable laws.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Globatalent or partner campaigns and services) and social media advertising through social media platforms such as Facebook, Instagram or Google). Personalize, measure, and improve our advertising. Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Globatalent or its third party partners. Conduct profiling on your characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think may be of interest to you. We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Globatalent App or website.

3. SHARING & DISCLOSURE

3.1 With Your Express Consent

Where you have provided express consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Globatalent Account or when you participate in promotional activities conducted by Globatalent’s partners or third parties.

3.2 Sharing between Members.

To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us.

3.3 Profiles, Listings, and other Public Information.

The Globatalent App or website lets you publish information, including personal information, that is visible to the general public. Based on our legitimate interest to promote the Globatalent App or website we may display parts of the Globatalent App or website (e.g., listing page) on sites operated by Globatalent’s business partners, using technologies such as widgets or APIs. Information you share publicly on the Globatalent App or website may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Globatalent and Globatalent App or website may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Globatalent, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Members, or (v) to protect the rights, property or personal safety of Globatalent, its employees, its Members, or members of the public. These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Globatalent App or website secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Globatalent’s property, its Members and the Globatalent App or website. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

3.5 Service Providers.

Globatalent and Globatalent App or website uses a variety of third party service providers to help us provide services related to the Globatalent App or website. Service providers may be located inside or outside of the European Economic Area (“EEA”). For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Globatalent Services through third party platforms and software tools (e.g. through the integration with our APIs), or (vi) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy. Globatalent will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

3.6 Social Media Platforms.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook, Instagram or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Globatalent App or website. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest. The social media platforms with which we may share your personal data are not controlled or supervised by Globatalent. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider. Please note that you may, at any time ask Globatalent to cease processing your data for these direct marketing purposes by sending an e-mail to contact@globatalent.com.

3.7 Aggregated Data.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. OTHER IMPORTANT INFORMATION

4.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Globatalent App or website for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. These activities are carried out based on Globatalent’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.]

5. THIRD PARTY PARTNERS & INTEGRATIONS

The Globatalent App or website may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Globatalent doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Globatalent, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

6. YOUR RIGHTS

You may exercise any of the rights described in this section in case you wish to access, amend, correct, remove, or limit use of your information before the Data Controller by sending an email to contact@globatalent.com or a notice to GBT World Limited, Berkeley Suite 35, Berkeley Square, W1J5BF, London, the United Kingdom. Please note that we may ask you to verify your identity before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of your information through your Account settings.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Globatalent Account).

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Globatalent App or website to you, you can request that we erase your personal information and close your Globatalent Account. Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations.
• Because we maintain the Globatalent App or website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by Globatalent you may withdraw your consent at any time by changing your Account settings or by sending a communication to Globatalent specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of Globatalent override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Globatalent not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Globatalent will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

7. OPERATING GLOBALLY

To facilitate our global operations Globatalent may transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

8. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Globatalent Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Globatalent Account, please contact us following the instructions in the Contact Us section below.

9. CHANGES TO THIS PRIVACY POLICY

Globatalent reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Globatalent App or website and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Globatalent App or website will be subject to the revised Privacy Policy.

10. CONTACT US

If you have any questions or complaints about this Privacy Policy or Globatalent’s information handling practices, you may email us at contact@globatalent.com or contact us by sending written notice to GBT World Limited, Berkeley Suite 35, Berkeley Square, W1J5BF, London, the United Kingdom.