Privacy Policy and Cookie Policy

“Effective” date October,1st 2020  

Globus AI AS (“Globus AI”, “we”, “us”), is responsible for processing personal data on this website and committed to protecting and respecting the privacy of all persons contacting, visiting, or otherwise submitting information to us. References to “you” or “your” are references to individuals who use the website.

This Privacy Policy does not cover any processing of personal data that we conduct as a data processor – meaning, where we process data on our customers’ behalf and following their instructions when users use our services. For those activities Data Processing Agreement applies that we enter into with our customers (which are the data controllers in this case).

This Privacy and Cookie Policy (“Privacy Policy”) is developed to protect your privacy and assist you in better understanding how your personal information is collected through this website, and how we use it as we interact with you.  

By using the website you confirm that you are or have had the opportunity to become aware of this Privacy Policy.

If you have any questions or comments regarding privacy issues on the website please contact us by email privacy@globus.ai

1. Types of information we collect

Globus AI collects information about people who visit our website www.globus.ai.

We collect both “Personal Information” and “Anonymous Information”.
Personal Information is information that can be used to identify you, such as your full name, email address, phone number, IP address, as well as information that is linked to such information.  
“Anonymous Information” is information that we cannot use to identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the website , such as use and usage data, browser information, the number of visits to each page, the duration of each visit, the country and region of visitors, and traffic origin to the extent that information is not linked to your Personal Information.  

2. Purposes and legal basis

We collect Personal Information that you voluntarily provide to us during your use of the website via:

●    a request for a demonstration of our product, subscribe to a newsletter, or receive other offers as described on the website.

To fulfill that request, we require your full name and contact details (email address, phone number).  The purpose is to provide you with information (by email, sms, messenger, or telephone) about products or services that you might receive from Globus AI and offers that are similar to those that you have enquired about or which may interest you.
Either your consent or our legitimate interest in promoting our products and services, subject to providing you with the ability to opt-out of marketing communications is the legal basis for processing. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. In this case, we will no longer process your data.

This information will be used solely for the purposes described above and will not be shared with other parties.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.  

●    While Submitting your job application, your Personal Information included in your CV, as well as full name, email address, phone number and answers to the questons related to the offer will be used as outlined in our candidate privacy notice.
Your Consent is a legal basis is this case.
If you do not want your Personal Information to be used, please do not submit your application.  Information collected via technology.

●    We use third party service providers (e.g. Google Analytics) to obtain analytics an aggregated basis for the sole purpose of analyzing and making improvements to the website.
As it is Google collecting information about you in this case and sharing some of it with us, you should refer to their separately maintained privacy policies or notices (described in the Cookies section below).
Our legitimate interest is in (a) understanding our user base so that we can better tailor and improve our website, including tailoring it to your needs by ensuring that content on the website is presented in an effective manner for you and for your device and (b) in optimizing (i) the presentation of our services and tailoring them to our user’s environment and needs, (ii) the visitor experience and to analyze how visitors use the site, and (iii) to provide our own data analysis, research for statistical purposes in order to innovate and improve our products and services, (iv) to gain insights into how to drive product and service improvement.

3. Cookies

This website uses cookies and related technologies for a number of purposes, including website functionality, analytics and advertising. The use of these technologies can involve the processing of Personal Information. For more information about how the website uses cookies and related technologies, and your choices regarding cookies, please refer to our Cookies Policy below. Where cookies or similar technologies are required the legal basis is your consent.  Otherwise, our legitimate interest in understanding the success of our advertising campaigns and measuring the effectiveness of any advertising we serve to you.


4. Storing documentation containing personal data

Globus AI stores customer information in Nutshell (our CRM system), containing  full names, addresses, telephone numbers, email addresses, and other personal information. The access to these documents is restricted and the information is used on a need-to-know basis only.
More information on how Nutshell handles privacy can be found
here.

Nutshell uses Amazon Web Services (AWS) to store and secure all customer data. Your data is encrypted at rest in our databases, and accessed through 256-bit TLS 1.2 encryption.
Your data is securely stored in the United States on AWS servers.
Nutshell has entered into a Data Processing Addendum with AWS that protects the transfer of data from the EU to our US servers.
Data transfers from the EU and EEA to the US are covered under these agreements and the AWS EU-US Privacy Shield
certification.
Nutshell offers EU Model Clauses, also known as the Standard Contractual Clauses, to meet the requirements of customers who operate or collect personal data in the EU.


Personal data related to recruitment is operated by Personio GmbH, which offers a human resource and applicant management software solution in accordance with their privacy notice.

5.Your rights

Subject to applicable law, you may have some or all of the following rights in respect of your Personal Information:  
●    Access to own Personal Information: You may also have the right to obtain a copy of the Personal Information held about you, and to be informed of certain details, such as (a) the source of your Personal Information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your Personal Information may be transferred.
●    Accuracy and right of rectification: we seek to ensure that your Personal Data is accurate, complete and kept up-to-date to the extent reasonably necessary for the purposes described herein. You also have the ability to update the information we hold about you should you request that by sending an email to us.  
●    Right to Erasure: if the Personal Information is incorrect, incomplete or not processed in compliance with applicable law or this Policy, you may have the right to have your Personal Information rectified or deleted in accordance with applicable law.
●    Right to Restriction: you can limit the way that we use your Personal Information in certain circumstances. This is an alternative to requesting the erasure of their data.
●    The right to data portability: allows individuals to obtain and reuse their personal data for their own purposes across different services.
●    Right to object: In certain circumstances (e.g., where your Personal Information is processed on the basis of our legitimate interests), you may have the right to object to the processing of your Personal Information on the basis of compelling grounds related to your particular situation and in accordance with applicable law.  
●    Right to prevent direct marketing: You may have the right to request that we do not process your personal data for marketing purposes. In such a case, you can control your initial marketing preferences by following an ‘unsubscribe’ link within a marketing email.  
●    Right to withdraw consent: If the processing of your Personal Information is based on your consent, you may have the right to withdraw your consent to such processing at any time. It is worth noting that the withdrawing of consent has no impact on earlier processing on such basis, and does not prevent us from invoking another legal basis for the processing of the relevant Personal Information.
●    Right to lodge a complaint: You may have the right to lodge a complaint before the relevant data protection authority or supervisory authority.
You may lodge a complaint with a supervisory authority for your country. You may find the list of supervisory authorities under http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.html   or by the search function of the European Commission website.  
We may ask you for additional information to confirm your identity and for security purposes before complying with your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.  
Some rights may be subject to exemptions created by applicable law or may only be exercisable in certain circumstances. We will communicate openly with you to help you to understand whether, and to what extent, a right is exercisable. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

6. Security

We are committed to ensuring the security of your personal information by using reasonable and appropriate physical, electronic, and administrative safeguards.    

7. Direct marketing

Any communications that promote our product and/or services are considered “direct marketing.” If you’re a customer of ours, we’ll only send you direct marketing that’s related to your use of Globus AI, unless you consent to receive other types of communications. If you’re not a customer, we will only send you marketing communications that you consent to. You can always unsubscribe from your account email settings or by clicking the unsubscribe link in our emails.

8. Transfer

We may transfer your Personal Information to countries located outside of the EEA. Some of these countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available http://europa.eu). With regard to transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate safeguards, such as compliance with the EU-U.S. Privacy Shield Framework or EU Standard Contractual Clauses, to protect your Personal Information. We are also making adequate efforts to further protect Personal information in the event of its cross-border transfer to jurisdictions not providing an adequate level of protection in a form of an analysis of the local applicable law and an assessment of the likelihood of a request from local law enforcement agencies for access to the transferred data. You may obtain a copy of these measures by contacting our Data Protection Officer at privacy@globus.ai.  
 

9. Changes to this Policy

We may modify or update this Policy and if we make changes, we’ll revise the “Effective” date at the top of this Policy, however, you will be notified of important changes in policy (ex., goals, procedure for exercising rights) and we may provide additional notice such as on the Globus AI website homepage or via the email address we have on file for you.

In this instance we will post a notice on our website within a reasonable time prior to the change becoming effective. We recommend periodically reviewing this page for any updates and the latest information about our privacy practices.  
If you have any questions regarding privacy practices of Globus AI, please contact us by email at privacy@globus.ai. We will comply with applicable law with respect to any changes we make to this notice and seek your consent to any material changes if this is required by applicable law.



Cookie Policy

This Cookie Policy is designed to tell you about our practices regarding cookies and how we use them. Our website uses cookies, in combination with pixels and similar devices (collectively, "cookies" unless otherwise noted) to distinguish you from other users of the website.  

By remembering information about website preferences through cookies, we provide you with a more tailored browsing experience and is required for certain parts of the website to work. In the majority of cases, a cookie does not provide us with any of your personal information.

Below is a list of the cookies we use, with a description of its purpose(s), expiry and information on refusing the cookies in “How to Block.”

What cookies are?

Cookies are small software files that are placed on your computer by websites you visit. The main purpose of a cookie is to allow a web server to identify a user’s computer and web browser to tailor various information to the user’s preferences.  

Why we use them?

Globus AI uses cookies to enable functionality and to assist with marketing its products to interested individuals. Overall, cookies help us ensure visitors’ experience browsing our website is optimized for them.  

If you wish to control cookies on our website, you can use your browser to enable, disable or delete cookies. For this, follow the instructions provided by your browser.  

These settings are usually found in the 'options' or 'preferences' menu of your internet browser.
In order to understand these settings, the following links may be helpful.
Otherwise you should use the 'Help' option in your internet browser for more details.

Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie settings in Safari

If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings or clicking on the Cookie button at the bottom of this policy and change your settings. For further information about deleting or blocking cookies, please visit: https://www.aboutcookies.org/how-to-delete-cookies/

Your consent

For performance, advertisement, site analytics and social media cookies, we request your consent before placing them on your device. You can give your consent by continuing to use our website.  If you do not wish to give consent or wish to withdraw your consent to any performance, functionality, targeting or social media cookies at any time, you will need to delete, and block or disable cookies via your browser settings.  

What cookies do we use and why?

Here are the categories of cookies we use and how we use them:  

I. Performance  

Google Tag Manager operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.   'Performance' cookies collect information about how you use our website - e.g. which pages you visit and if you experience any errors. These cookies do not collect any information that could identify you and are only used to help us improve how our website works, understand what interests our users and measure how effective our content is. All information these cookies collect is aggregated and therefore anonymous. We use performance cookies to perform: Web analytics: Provide anonymous statistics on how our website is used Error management: Help us improve the website by measuring any errors that occur. We use Google Tag Manager which runs Google Analytics to analyze traffic to our Website in order to improve our website and the website user’s experience.  

II. Site Analytics We use various analytics and performance tools to analyze how visitors interact with our website in order to be able to improve it, as well as analysis of the effectiveness of ad campaigns

 a.   Google Analytics Google Analytics creates cookies on your device that are used to collect and analyze information on your visit of our website.  These cookies don't collect information that identifies a visitor. Information collected by these cookies is aggregated and therefore anonymous. It is only used to improve how a website works and to optimize both the website and its advertising. The information is collected in an anonymous form, for example, the number of visitors, where they have come from, which pages they visited. Some of the cookies set for this purpose are automatically removed from your device when you close the browser. Others may last for a period of up to 24 months from your last visit to our site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google’s ability to use and share information collected by Google Analytics is restricted by the  Google Analytics Terms of Service  and the  Google Privacy Policy. You can also  learn more about how Google collects and processes data  specifically in connection with Google Analytics. You may prevent your data from being used by Google Analytics by downloading and installing the  Google Analytics Opt-out Browser Add-on.  The website operator analyses user behavior on the website More information can be found here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

 b.    HotJar We use Hotjar (Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta, Europe) in order to better understand our users’ needs and to optimize this service and experience.  Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. Hotjar is a company registered in the European Union, is regulated by and follows European legislation in relation to data transfers and as per Hotjar’s Privacy Policy https://www.hotjar.com/legal/policies/privacy/   your information is stored in the European Union.
For further details, please see the ‘about Hotjar’ section of Hotjar’s support site: https://www.hotjar.com/cookies

III. Social Media

a. Facebook Connect Our website measures conversions using visitor action pixels from Facebook, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). These allow to assess the behavior of website visitors after they click on a Facebook ad to reach the website. This allows an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization.The data collected is anonymous to us as operators of this website and we cannot use it to draw any conclusions about our users’ identities.  However, the data are stored and processed by Facebook, which may make a connection to your Facebook profile and which may use the data for its own advertising purposes, as stipulated in the Facebook privacy policy. This will allow Facebook to display ads both on Facebook and on third-party sites. We have no control over how this data is used. Check out Facebook’s privacy policy to learn more about protecting your privacy: https://www.facebook.com/about/privacy/. You can also deactivate the custom audiences remarketing feature in the Ads Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You will first need to log into Facebook. If you do not have a Facebook account, you can opt out of usage-based advertising from Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.  

b. Linkedin Analytics These cookies are set through our website to measure conversions using visitor action pixels from Linkedin, 1000 West Maude Avenue, Sunnyvale, CA, 94085, USA (“Linkedin”).  They may be used to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, the data collected is anonymous to us and we cannot use it to draw any conclusions about our users’ identities, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.  These allow the analysis of the effectiveness of Linkedin advertisements for statistical and market research purposes and their future optimization and evaluate the behavior of website visitors after they click on a Linkedin ad to reach the website.  Linkedin collects cookies (or rely on others who collect) and information about your device where you have not engaged with Linkedin Services (e.g., ad ID, IP address, operating system and browser information) to provide relevant ads and better understand their effectiveness.  To learn more about how Linkedin collects and uses information for online advertising, please visit: https://www.linkedin.com/legal/privacy-policy  If you are a LinkedIn member, you can opt out from your LinkedIn Privacy Settings here: https://www.linkedin.com/settings/?trk=nav_account_sub_nav_settings&modal=nsettings-enhanced-advertising. This will opt you out from LinkedIn data collection and targeting cookies on any computers, mobile devices and browsers you use to visit third party sites, provided you have logged onto LinkedIn.  Please note that LinkedIn's data centers are currently located in the U.S. and Singapore.  

IV. Advertising

a. Share This https://sharethis.com/  (ShareThis, Inc., 4009 Miranda Avenue, Suite 200, Palo Alto, CA , 94304). We give users the option to share our stories on social networks such as Facebook and Linkedin. To deliver this service we link to a third party website called Share This. ShareThis provides website operators with customizable social sharing tools, which makes sharing online content simple. Any user of a website can easily share anything on the web with their friends on social sites, such as Facebook, Twitter, Email, Digg, Reddit and more through using one of our tools on that website (“ShareThis Icon”). ShareThis also collects data about internet users and how they interact with content, websites and adverts which enables to facilitate the delivery of relevant, targeted advertising online to these groups. ShareThis also carries out analytics and provide insights to understand internet users’ behaviour and improve the effectiveness of online content and advertising, based on such browsing, sharing, and what is considered to be the profile of that group.     ShareThis does this by using technology such as cookies and pixels to gather information regarding the browsing and sharing activities of internet users, both on websites that use our ShareThis Icon and other websites which it’s technology installed on them. ShareThis also receives data from others who operate in the data analytics and advertising industries to analyse and aggregate the data ShareThis collects to create groups of data (called audience segments) based on defined criteria (ex., similar characteristics, interests, needs or behavioral patterns).  Targeted advertising has the aim of displaying advertising which is more likely to be of interest to internet users, based on analyses of their recent browsing and sharing activities and interactions with the website and adverts. It is also sometimes referred to as interest-based advertising or online behavioural advertising. For more information on this type of advertising, click here.  

b. Double Click, Google Ads
DoubleClick digital advertising platform: the ad technology foundation to create, transact, and manage digital advertising. Google (www.google.com) operates the Google Display Network a collection of millions of websites and mobile applications that are powered by display advertising, including many Google services like YouTube. Google also operates the DoubleClick digital advertising platform: the ad technology foundation to create, transact, and manage digital advertising for the worlds buyers, creators, and sellers. The DoubleClick platform includes the DoubleClick Advertising Exchange and Double Click Bid Manager. To learn more about how we collect and use information for online advertising, please visit http://www.google.com/intl/en/privacy.html