Globally Locals’ Privacy Notice
Date of last update: (February 2024)
We Globally Locals are committed to protecting your personal data and respecting your privacy. We wrote this privacy notice to help you understand the information that we collect about you, how we use it and what rights you have. This privacy notice applies to our online platform ("Website").
Who we are and how to contact us
Globally Locals
(Globally Locals OÜ, Ahtri 12, privacy@globallylocals.com)
What personal information do we collect and for what do we process?
Newsletter and Marketing communications
When you subscribe to our newsletter through the website and give us consent to send marketing communications, we process the following information:
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Email address
We use this information to send you updates about our services/products. This processing takes place under the legal basis of your consent (GDPR Art. 6.1.a/LGPD Art. 7, I).
You can revoke your consent at any time and free of charge by contacting us directly. Please note that the revocation of consent will not affect the lawfulness of processing based on consent before it was revoked. You can unsubscribe to our newsletter or marketing communications by clicking the unsubscribe link provided in our communications to you.
We will store your information while you are subscribed to our newsletter and marketing communications. Please note that we may keep a record of the withdrawal of your consent and your email to not send newsletter and marketing communications to you, based on our legitimate interests (GDPR Art. 6.1.f/LGPD Art. 7, IX).
Feedback
From time to time, we may ask you to provide relevant feedback regarding our services and products. We use this information to improve our services, products and analyse our efficiency in marketing and product efforts, including by creating statistics of inquiries. For this, we process your
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Email address
We will store your information for our legitimate interests (GDPR Art. 6.1.f) for a period of one year.
Security measures
In order to implement security measures on our website and to protect your personal data, we may process your IP address, time, date, browser, and device ID. We do this based on our legitimate interests (GDPR Art. 6.1.f/LGPD Art. 7, IX). We will store your information for a period of one year.
Website usage and browsing
We process data about the use of our website and browsing in accordance with the provisions of the cookie section.
We do this based on our legitimate interests (GDPR Art. 6.1.f/LGPD Art. 7, IX), and based on your consent (GDPR Art. 6.1.a/LGPD Art. 7, I) for advertisement and analytics. We will store your information for a period of one year.
You can revoke your consent at any time and free of charge by contacting us directly. Please note that the revocation of consent will not affect the lawfulness of processing based on consent before it was revoked. We may keep a record of the withdrawal of your consent based on our legitimate interests (GDPR Art. 6.1.f/LGPD Art. 7, IX).
Contact form
When you contact us via the contact form, we collect the following information:
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First and last name
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Email address
We use this information to contact you according to your request. We process this information based on our legitimate interest (GDPR Art. 6.1.f/LGPD Art. 7, IX).
We may use this information for sending offers (marketing and sales emails) that are relevant to you. You can opt-out at any time by clicking the appropriate button in our emails to you. We will store this information for a period of 1 year – unless you become our customer, in which case, the data will be stored until you continue to use our services. At the end of this period, we will send you a final communication requesting your consent to receive marketing communications and if we do not receive a response within 5 days, we will completely delete your data from all our databases.
With whom do we share your personal data?
We may commission third parties for the provision of the service. These third parties will process your data according to our instructions and our relationship is ruled by a contract. The categories of service providers and other parties that may have access to your data are listed below:
Service providers
These parties help us to provide services to you or perform business functions on our behalf. They include:
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Hosting, technology, and communication providers.
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Support and customer service providers.
Advertising partners
These parties help us to market our (services/products). They include: (if applicable)
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Ad networks.
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Marketing providers.
Analytics partners
These parties provide analytics on web traffic or usage of the (services/products). They include:
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Companies that measure how users interact with our services.
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Companies that measure how users found or were referred to our services.
Legal Obligation
We may share the personal data that we collect with third parties in order to comply with our legal obligations.
International data transfers
International data transfers can take place when processing your personal data for the purposes indicated in section two of this privacy notice. This means that your data may be transferred or accessed by organisations located outside the European Economic Area (EEA).
For how long do we store your information?
We will retain your personal information for the length of time needed to fulfil the purposes outlined in this privacy notice (section two) unless a longer retention period is required or permitted by law.
How do we protect your personal information?
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, physical, and administrative security measures that are designed to protect your information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access to personal data transmitted, stored or otherwise processed. We restrict access to your information to those who need to know your information to provide our services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.
Cookie notice
Cookies are small text files that are placed on your device by the website that you visit. They are widely used in order to make the website work or work more efficiently, for instance, to remember language and country settings for future visits. The cookies are also used to measure visitor frequency and traffic parameters as well as to monitor the development and number of inputs.
We do not store confidential personal information such as your address and passwords in the cookies we use.
Categories of cookies that we use
Our website mostly uses first-party cookies, which are set and controlled exclusively by us, not by an external organisation. We may potentially use external services that set their own cookies, known as third-party cookies.
We may implement persistent cookies, that are saved on your device and are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.
Strictly necessary cookies
Strictly necessary cookies are necessary for the website's functioning and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but that will cause some parts of the site to not work.
Performance cookies
Performance cookies can be used to count visitor frequency on the website and the traffic sources, to determine the number of visitors and thus also measure and evaluate the use by them statistically. These cookies help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
Functional cookies
Functional cookies allow you to access the service provided by us with some features preset based on some criteria, such as the type of browser used to access the website and the language and country setting from which the service is accessed.
Marketing cookies
Marketing cookies store behavioral information of visitors, collected through their interaction on the website to show them advertising related to their navigation profile. They can be used for analytical and advertisement purposes.
Social media cookies
These cookies are set by various social networking services that we have included in the website so that you can share our content with your friends and networks.
The table below lists the cookies that we use on our website:
Necessary Cookies
Cookie Name: sb-access-token
Service: Globally Locals
Purpose: Stored token that maintains the access to the service and remains until logged out.
Duration: Persistent cookie stored for one year.
Type: First-party
Cookie Name: sb-ehoqvesxwytgxizgiskm-auth-token
Service: Globally Locals
Purpose: Token that will be stored after the login which contains the information about the authenticated account in order to display name and email in the authenticated page.
Duration: Persistent cookie stored for one year.
Type: First-party
Cookie Name: sb-refresh-token
Service: Globally Locals
Purpose: Stored token to automatically refresh your session if needed.
Duration: Persistent cookie stored for one year.
Type: First-party
Cookie Name: euconsent-v2
Service: Globally Locals
Purpose: Stored token that contains if the user has accepted or rejected the consent modal.
Duration: Persistent cookie stored for one year.
Type: First-party
Functional cookies
Cookie Name: NEXT_LOCALE
Service: Globally Locals
Purpose: Stored token that saves the user language in order to translate the page if needed.
Duration: Persistent cookie stored for 9 months.
Type: First-party
The placement of strictly necessary cookies is based on our legitimate interests (GDPR Art. 6.1.f/LGPD Art. 7, IX). The remaining cookies are placed based on visitors’ consent (GDPR Art. 6.1.a/LGPD Art. 7, I).
Data transfers to third countries
When third-party cookies are placed, your personal data may be processed or accessed by service providers outside the European Economic Area (EEA). The third party countries to which international data transfers take place are the U.S.A and Brazil. You can find out about all transfers to third countries made by the third parties mentioned in this cookie notice in their respective policies.
To check our international data transfers, please go to section 4 - International data transfers.
How to manage your cookie preferences
You can change your cookie preferences at any time. You can adjust the available sliders to “on” or “off” and save your preferences at the end. You may need to refresh your page for your settings to take effect.
You can also allow, block or delete cookies installed on your device by changing your browser settings. In the event that you block them, certain services that require their use may not be available to you. You can find the links to information on how to activate your cookie settings in the most important browsers below:
To find out more about cookies, including how to see what cookies have been set, please visit www.aboutcookies.org or www.allaboutcookies.org.
If you have accepted the third-party cookies, you can delete them from the browser options or from the system offered by the third-party provider.
UK & EU data subjects’ rights
Under the EU/UK GDPR, you are entitled to the following rights:
YOUR DATA PROTECTION RIGHTS
Right of Access:
You have the right to confirm whether your personal data is being processed by us and to ask for copies of your personal data.
Right to Rectification:
You have the right to request us to rectify personal information that is inaccurate and to complete the information that you consider incomplete.
Right to Erasure:
You have the right to request the erasure of your personal data, in certain circumstances.
Right to Restriction:
You have the right to request the restriction of the processing of your personal data, in certain circumstances such as when you contest the accuracy of your information, believe that the processing of your personal data is unlawful or want to object to the processing.
Right to Object:
You have the right to object to the processing of your personal data, in certain circumstances, such as when we process your personal data based on our legitimate interests.
Right to Data Portability:
You have the right to request that we transfer the personal information you gave us to another organization, or to you, where we process your personal data under your consent or based on a contract.
Automated Decision-Making:
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you, unless you have consented to the processing or if the processing is necessary for entering or performing a contract with you.
Right to File a Complaint:
You have the right to file a complaint before the competent supervisory authority. Available authorities in Europe can be found here: European Data Protection Board.
You can exercise your rights at any time and free of charge. If you make a request, we have one month to respond to you.
Please contact us at privacy@globallylocals.com if you wish to make a request.
Brazilian data subjects’ rights:
Under the LGPD, you are entitled to the following rights:
Right of access and confirmation:
You have the right to confirm whether your personal data is being processed by us and to ask for copies of your personal information.
Right to correct incomplete, inaccurate, or outdated information:
You have the right to request us to correct the personal data that you think that is incomplete, inaccurate, or outdated data.
Right to anonymise, block or eliminate:
You have the right to request the anonymisation, blocking or elimination of data that you consider as unnecessary or excessive or data processed in non-compliance with LGPD.
Right to data portability:
You have the right to request the portability of your personal data to other organisation, by the means of an express request, and subject to commercial and industrial secrecy.
Right to erasure:
You have the right to request the erasure of your personal data processed by us based on your consent, except under some circumstances laid down in Art. 16 of the LGPD.
Right to information:
You have the right to request information on the public and private entities with which we have shared your data.
Right to object:
You have the right to object to the processing of your personal data, when we do not process it based on your consent.
Right to data portability:
You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, where we process your personal data under your consent or based on a contract.
Automated decision-making:
You have the right to request for the review of decisions made exclusively by automated processing of your personal data that affects your interests, including decisions intended to define your personal, professional, consumer and credit profile or aspects of your personality.
Right to file a complaint:
You have the right to file a complaint before the Brazilian supervisory authority, ANPD (Agência Nacional de Proteção de Dados).
You can exercise your rights at any time and free of charge. Please contact us at privacy@globallylocals.com if you wish to make a request.
Changes to this privacy notice
The most current version of this privacy notice governs our processing of your personal data, and we reserve the right to review it from time to time according to the current legal requirements.