Who uses your Personal Data?

This data privacy notice refers to personal data collected as part of our activities mentioned below and informs you about how your Personal Data is handled at our end.
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The company responsible for processing your Personal Data is:

Name: Globus AI AS (hereinafter referred to as ‘we’, ‘us’, ‘our’)
Address: Rådhusgata 6, 4306 Sandnes, Norway
E-mail: privacy@globus.ai

How we use your Personal Data?

For each activity mentioned below (Activities 1 - 5), we note the purpose (‘Purpose’) for which we use the Personal Data, to whom this Personal Data regards, the categories of Personal Data being used, the legal bases we rely on, the source from where we received the Personal Data, for how long we keep the Personal Data and with whom we might share the Personal Data. Please note that no processing activities include automated decision-making.

The provision of Personal Data is not a statutory or contractual requirement (unless specified otherwise). It is also not necessary to enter into a contract with us. You are not obliged to provide Personal Data. The consequence of failure to provide Personal Data would be inability to achieve our Purpose.

Your rights

Where we use your Personal Data for the activities mentioned in this Privacy Notice, you may:

• request further details about how we use your Personal Data, including receiving a copy of your Personal Data (‘Right of access’)
• request that we correct, update or erase your Personal Data (‘Right to rectification’)
• request that we restrict the use of your Personal Data (‘Right to restriction’)
• object to us using it, or that we use it for direct marketing (‘Right to object’)

Where we use your Personal Data specifically based on your consent, you also have the right to request that we transfer your Personal Data to you or a third party (‘Right to data portability’).

If you wish to exercise your rights, you can contact us by sending an e-mail to privacy@globus.ai

How to file a complaint

If you have any queries that cannot be clarified as a result of internal dialogue with us or you wish to file a complaint, you can contact the Norwegian Data Protection Authority at https://www.datatilsynet.no

Activity 1: Business partner and client management

Purpose

The purpose with business partner and client management is to:

• carry out contract management, provide professional services to our customers and consumers;
• communicate effectively with business partners and client representatives, respond to their questions, comments, complaints or other communications, including any queries relating to our products;
• monitor activities and communications with business partners and client representatives, to record correspondence with them, including to ensure service quality, compliance with procedures and for internal training purposes of our employees and consultants.

Who are you?

Business partner or client representative

Type of Personal Data being used

• Contact, other ID and personal information - name, email, social media accounts, phone number;
• Work related information (title, details of the organization where you work);
• Correspondence with you (e.g. any feedback, complaints, requests, inquiries and comments from you via telephone, email, or records of any online, paper or in-person correspondence and interactions with you). If you have communicated with us by phone, we will collect details of the phone number used, and any information collected via a call recording;
• Information about requests opened by you and closed;
• Logs of activities performed;
• Information about documents signed by you on behalf of client;
• Profile image (avatar) (if uploaded by you).

Legal basis for the use of your Personal Data

• Comply with our legal obligations, see Article 6(1)(c) of the General Data Protection Regulation 2016/679, cf. §13 of the Bookkeeping law (Lov om bokføring (bokføringsloven), LOV-2004-11-19-73);
• Pursue our legitimate interest (see Article 6(1)(f) of the General Data Protection Regulation 2016/679):

- to carry out contract management, provide professional services to our customers and consumers, and, where relevant, - receive professional services from them;

- to communicate effectively with business partners and client representatives, respond to their questions, comments, complaints or other communications, including any queries relating to our products;

- to monitor activities and communications with business partners and client representatives, to record correspondence with them, including to ensure service quality, compliance with procedures and for internal training purposes of our employees and consultants.

Source

• You (data subject)
• Your employer's other representatives

How long do we store your Personal Data?

As a general rule, we will keep your Personal Data for up to 2 years from the day of the last interaction with you.
Where we need to comply with our legal obligation under the Bookkeeping law (Lov om bokføring (bokføringsloven), LOV-2004-11-19-73), we will keep your Personal Data for 3,5 years.

Sharing of your Personal Data with third parties and its transfer to a third country

We may share your Personal Data with third parties such as task management vendors, CRM vendors, documentation signing vendors, general business management vendors, contractors and investors. Your Personal Data are first disclosed to these third parties at the moment of their collection.

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We may transfer your Personal Data to third parties located outside the EU and the European Economic Area - including USA and the United Kingdom. The United Kingdom has been approved by the European Commission as providing essentially equivalent protections to EU and European Economic Area data protection laws and, therefore, no additional safeguards are required to transfer your Personal Data to this jurisdiction. Where your Personal Data is transferred to USA - we have entered into EU Commission-approved standard contractual clauses, copy of which may be provided to you upon request sent to privacy@globus.ai

Activity 2: Direct marketing & public relations activities

Purpose

The purpose is to provide client representatives, business partners and prospects with information (by email or other messages) about our platform and services that we offer. We have a legitimate Interest to contact leads within our outbound sales development activities. When these activities are a form of direct marketing, we carefully choose whether we will contact a lead or not by assessing potential benefits of our product and services for their companies. We have a strong belief that their companies may benefit from our communication.

Who are you?

Business partner, client representative, prospect, website visitor, subscriber

Type of Personal Data being used

• Contact information (e.g. name, address, email, phone number);
• Work information (Company and work title)
• Marketing preferences (e.g. details of your marketing and communication preferences and information we collect to help determine what products and services may be of interest to you);
• Correspondence with you;
• Online identifiers (IP address; Information obtained via email web beacon pixels as to whether our emails are opened and whether there have been any clicks through to links within the email).

Legal basis for the use of your Personal Data

• Pursue our legitimate interest (see Article 6(1)(f) of the General Data Protection Regulation 2016/679):
• to provide you with information (by email or other messages) about products and services.

In case your consent is required to conduct direct marketing and public relations activities, we will ensure to obtain your consent in advance, see Article 6(1)(a) of the General Data Protection Regulation 2016/679.

Source

• You (data subject)
• Data enrichment platforms
• Corporate websites and other public sources
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How long do we store your Personal Data?

As a general rule, we will keep your Personal Data for up to 2 years from the day of the last interaction with you.

Sharing of your Personal Data with third parties and its transfer to a third country

We may share your Personal Data with third parties such as task management vendors, CRM vendors, documentation signing vendors, general business management vendors, contractors and investors. Your Personal Data are first disclosed to these third parties at the moment of their collection.
We may transfer your Personal Data to third parties located outside the EU and the European Economic Area. Our CRM vendor hubspot.com has servers in the USA. More information on how Hubspot handles privacy can be found here: https://legal.hubspot.com/dpa.

We have team members who have access to data in the UK and Russia. The United Kingdom has been approved by the European Commission as providing essentially equivalent protections to EU and European Economic Area data protection laws and, therefore, no additional safeguards are required to transfer your Personal Data to this jurisdiction.

Where your Personal Data is transferred to USA or accessed from Russia- we have entered into EU Commission-approved standard contractual clauses, copy of which may be provided to you upon request sent to privacy@globus.ai

Activity 3: Analytics of marketing interactions

Purpose

The purpose is to evaluate the effectiveness of our marketing interactions with you, in particular, to analyze:

• (via email web beacon pixels) whether our emails are opened and verify any clicks through to links within the email;
• which of our emails are more interesting to you;
• how you interact with our emails, our employees and/or our internet-based resources over time.

Who are you?

Business partner, client representative, website visitor, subscriber

Type of Personal Data being used

• Contact information (e.g. name, address, email);
• Work related information (e.g. title, workplace);
• Marketing preferences (e.g. details of your marketing and communication preferences and information we collect to help determine what products and services may be of interest to you);
• Survey information (e.g. your responses to market surveys that we conduct);
• Correspondence with you;
• Information obtained via email web beacon pixels as to whether our emails are opened and whether there have been any clicks through to links within the email.

Legal basis for the use of your Personal Data

The use of your personal data is necessary for us to:

• Pursue our legitimate interest (see Article 6(1)(f) of the General Data Protection Regulation 2016/679):
• to evaluate the effectiveness of our marketing interactions with you.

In case your consent is required to conduct direct marketing and public relations activities, we will ensure to obtain your consent in advance, see Article 6(1)(a) of the General Data Protection Regulation 2016/679.

Source

• You (data subject)
• Data-enrichment platforms

How long do we store your Personal Data?

As a general rule, we will keep your Personal Data for up to 2 years from the day of the last interaction with you.

Sharing of your Personal Data with third parties and its transfer to a third country

We may share your Personal Data with third parties such as task management vendors, CRM vendors, documentation signing vendors, general business management vendors, contractors and investors. Your Personal Data are first disclosed to these third parties at the moment of their collection.
We may transfer your Personal Data to third parties located outside the EU and the European Economic Area - USA, and the United Kingdom. The United Kingdom has been approved by the European Commission as providing essentially equivalent protections to EU and European Economic Area data protection laws and, therefore, no additional safeguards are required to transfer your Personal Data to this jurisdiction. Where your Personal Data is transferred to USA - we have entered into EU Commission-approved standard contractual clauses, copy of which may be provided to you upon request sent to privacy@globus.ai

Activity 4: Website management

Purpose

The purpose is to build, run, host, manage and improve our website (https://www.globus.ai/), to ensure that the content is relevant and presented in the most effective manner for you and your device, that you have a positive experience when navigating our website, and to allow you to participate in/register for interactive features of our services. Additionally, the purpose is to keep our websites safe and secure, administer our websites for internal operations, including troubleshooting, data analysis (including traffic data analysis), testing, and research, statistical and survey purposes.
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Our website uses cookies to distinguish you from other users. They help us to provide you with a good experience when you browse our website and ensure that the content is relevant to you. To learn more about how we use cookies, please visit our Privacy Policy and Cookie Policy.

Who are you?

Website visitor

Type of Personal Data being used

• Contact, other ID and personal information - name, email, social media accounts, phone number;
• Work related information (title, details of the organization where you work);
• Correspondence with you (e.g. any feedback, complaints, requests, inquiries and comments from you via telephone, email, or records of any online, paper or in-person correspondence and interactions with you);
• Information about digital interactions with you (e.g. use of chat rooms, contact forms, or other interactive forums);
• Cookies by means of which the following Personal Data is used:
• Technical information (e.g. user ID, login information, browser type, time zone setting, browser plug in types and versions, operating system and platform);
• Information about visit to our websites (e.g. the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), products a website visitor viewed or searched for, pages a website visitor accessed, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page);
• Geolocation data.

Cookies also include strictly necessary cookies for the operation of the website and delivery of its services.

Legal basis for the use of your Personal Data

The use of your personal data is necessary for us to:

• Pursue our legitimate interest (see Article 6(1)(f) of the General Data Protection Regulation 2016/679):
• to manage and administer our website and to provide you with the content and services on our website.

Some use of cookies require that we obtain your prior consent, see Article 6(1)(a) of the General Data Protection Regulation 2016/679. For further information, please see our Privacy Policy and Cookie Policy.

Source

• You (data subject) (device)

How long do we store your Personal Data?

As a general rule, we will keep your Personal Data for up to 2 years from the day of the last interaction with you.
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For cookies specifically, please see our Privacy Policy and Cookie Policy.

Sharing of your Personal Data with third parties and its transfer to a third country

We may share your Personal Data with third parties such as task management vendors, CRM vendors, documentation signing vendors, general business management vendors, contractors and investors. Your Personal Data might be first disclosed to these third parties at the moment of their collection depending on the context of the processing.
We may transfer your Personal Data to third parties located outside the EU and the European Economic Area such as USA. Where your Personal Data is transferred to third countries - we have entered into EU Commission-approved standard contractual clauses, copy of which may be provided to you upon request sent to privacy@globus.ai

Activity 5: Social media management

Purpose

The purpose is to ensure that the content is relevant and presented in the most effective manner for you, and that you have a positive experience when navigating the sites, and to allow you to participate in/register for interactive features of our services. Additionally, the purpose is to keep our websites safe and secure, administer our websites for internal operations, including troubleshooting, data analysis (including traffic data analysis), testing, and research, statistical and survey purposes.

Who are you?

Visitor of the social media sites

Type of Personal Data being used

• Contact, other ID and personal information - name, email, social media accounts, phone number;
• Work related information (title, details of the organization where you work);
• Correspondence with you (e.g. any feedback, complaints, requests, inquiries and comments from you via telephone, email, or records of any online, paper or in-person correspondence and interactions with you);
• Information about your digital interactions (e.g. your use of chat rooms, message boards, social media pages or other interactive forums including any comments, photos, videos or other information that you post online);
• Photographs, videos and voice recordings (e.g. that you post online);
• Survey information (e.g. your responses to market surveys that we conduct).

Legal basis for the use of your Personal Data

The use of your personal data is necessary for us to:

• Pursue our legitimate interest (see Article 6(1)(f) of the General Data Protection Regulation 2016/679):
• to manage and administer our social media pages and to provide you with the content and services on our social media site.

We may also use special categories of Personal Data that you manifestly made public, e.g., on our social media sites, see Article 9(2)(e) of the General Data Protection Regulation 2016/679.

Source

• You (data subject) / your social media accounts

How long do we store your Personal Data?

Usually, Personal Data are stored until Personal Data themselves or your user account are deleted by you or by the social media provider. In any event Personal Data is not stored for longer than necessary for the purpose for which they are processed. Please read privacy statements of respective social media providers to get more detailed information as to the storage periods applied by the specific social media provider.

Sharing of your Personal Data with third parties and its transfer to a third country

When you visit our social media sites your Personal Data are shared with the social media providers - this happens at the moment of their collection.
Sharing your Personal Data with the social media providers may imply their transfer to a third party located outside the EU and the European Economic Area - USA. Where your Personal Data are transferred to USA - a EU Commission-approved standard contractual clauses have been concluded as a safeguard.

Activity 6: Investor and shareholder relations

Purpose

• Build and maintain relationships with existing and perspective investors in Globus AI and those who apply to invest in the company;
• Ensure a proper administration, keeping our records up to date,  and follow up of our shareholders and investors and to share relevant information about the company with them;
• Communicate effectively with investors, respond to their questions, comments or other communications;
• Monitor activities and communications, to record correspondence, including to ensure overview.

Who are you?

Shareholder or perspective investor.  Where the applicant, or investor, is an institutional investor, then we will need to process Personal data about directors, officers and ultimate beneficial owners of the institutional investor. This notice also explains how we Process Personal data about these individuals.

Type of Personal Data being used

• Contact, other ID and personal information - name, email, social media accounts, phone number;
• Work related information (title, details of the organization where you work);
• Correspondence with you (e.g. any feedback, requests, inquiries and comments from you via telephone, email, or records of any online, paper or in-person correspondence and interactions with you);
• Information about your digital interactions (e.g. your use of chat rooms, message boards, social media pages or other interactive forums including any comments, photos, videos or other information that you post online), logs of activities performed on our website;
• Information about documents signed by you.

Legal basis for the use of your Personal Data

Legitimate interest (see Article 6(1)(f) of the General Data Protection Regulation 2016/679), see also Norwegian PLC Act.

We may also use special categories of Personal Data that you manifestly made public, e.g., on our social media sites, see Article 9(2)(e) of the General Data Protection Regulation 2016/679.

Source

• You (data subject)
• Website of an organization you work for
• Other investors
• Social media accounts

How long do we store your Personal Data?

As a general rule, we will keep your Personal Data for up to 5 years from the day of the last interaction with you.

However, the retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which we have to keep your Personal data).  For example, we may keep some of your Personal data for the purposes outlined above and for as long as we maintain an ongoing relationship with you to manage our business relationship or you are lawfully included in our mailing list and have not unsubscribed.  

Sharing of your Personal Data with third parties and its transfer to a third country

We may share your Personal Data with third parties such as professional advisers (such as our accountant Relevant Regnskap and auditor Frigg Revisjon AS), CRM vendor (Hubspot), documentation signing vendors (SignRequest),  capitalization table management and valuation software vendor (Carta), general business management vendors and contractors (MS O365).
We will be able to provide their details and full list of processors upon request to privacy@globus.ai.  
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We may transfer your Personal Data to third parties located outside the EU and the European Economic Area - USA and the United Kingdom. The United Kingdom has been approved by the European Commission as providing essentially equivalent protections to EU and European Economic Area data protection laws and, therefore, no additional safeguards are required to transfer your Personal Data to this jurisdiction.
Where your Personal Data is transferred to USA - we have entered into EU Commission-approved standard contractual clauses, copy of which may be provided to you upon request sent to privacy@globus.ai