Privacy Policy

Introduction

Glocalzone OÜ (“Glocalzone”, “we”, “our” or “us”) is concerned about online privacy issues and we would like to inform you on how we collect, use and disclose any Personal Information that individually identifies you. This Privacy Policy explains our online information practices applicable to the websites available (the “Sites”) and all Glocalzone services like apps and other products made available to you on, through or in association with the Glocalzone services (the “Services”). We will only collect, use and disclose your Personal Information in accordance with this Privacy Policy.

The Company does not knowingly collect any personal information from children under the age of 18. The Company’s Sites and Services are not offered to individuals under the age of 18. You should not use the Sites and Services if you are below 18. If you are under the age of 18, please do not submit any personal information through our Sites and Services. If you are under 18 and want to use our Websites and Products please contacts us to settle this matter individually.

This Policy sets out how Glocalzone uses and protects any personal data that you provide to Glocalzone (including personal data provided through the website www.glocalzone.com (“Website”). Policy herein tells you about your privacy rights and how data protection laws protects you. Glocalzone collects certain personal data from users, in accordance with this Policy. Glocalzone is committed to respecting and protecting the privacy of all personal data received or collected, in strict compliance with data protection legislation. Glocalzone has established this Policy so that you can understand the care with which we intend to treat your personal data.

How to contact us

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below. If you have any questions regarding your personal data and how we may use it, including any queries relating to this Policy, please contact us at help@glocalzone.com

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by emailing help@glocalzone.com with any changes.

Personal data and Basis for Collection

Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been anonimized or masked. Where Glocalzone is acting as a data controller, Glocalzone may collect, use, store and transfer different kinds of personal data about you which Glocalzone has grouped together as follows:

Identity Data includes first name, last name;

Contact Data includes email address;

Transcational Data solely on the occasion of completing a transcation and includes bank details, national identity number and telephone number for reporting obligations to authorities

Technical Data includes internet protocol address, browser type and versions, time zone setting and location, browser plug-in types and versions and platform and other technology on the devices you use to access our Website;

Profile Data includes your pictures, feedback and survey responses;

Usage Data includes information about how you use our Services or submit an enquiry or query through our Website;

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;

Why We May Collect Personal Information

We may collect Personal Information from you when you voluntarily provide it to us or use our services which based on your prior consent for processing data in order to: registration to our Sites and Services, facilitating financial transactions, provide the Sites and Services to you and other persons in accordance with your settings of the Sites and Services; improve the Sites and Services; provide you with information relating to the Sites and Services, including, without limitation, products, services, promotional offerings (including direct marketing); provide you with support in respect of the Sites and Services; meet legal and regulatory requirements.

When We May Disclose Your Personal Information

We may disclose your Personal Information to individuals or organizations who are involved in:

1. providing the Sites or Services, or information relating to the Sites and Services on our behalf such as cloud service providers, e-mail service providers and

2. maintaining, reviewing or developing our business systems, procedures or infrastructure, including, without limitation, testing or upgrading of our computer systems;

3. a transfer of technical activity data to business partners;

Where we disclose your Personal Information to individuals or organizations as stated above, we will require those individuals and organizations to collect, use and disclose Personal Information in accordance with this Privacy Policy.

Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where we are obliged to disclose Personal Information without consent. Such circumstances may include:

1. where required by law or by order or requirement of a court, administrative or law enforcement agency or governmental entity;

2. where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of 4D Sight, or its licensors, affiliates, users or other third parties;

3. where the information is publicly available.

Where obliged or permitted to disclose your Personal Information without consent, we will disclose no more Personal Information than is reasonably required.

If you fail to provide personal data

Where Glocalzone needs to collect personal data by law, or under the terms of a contract Glocalzone has with you and you fail to provide that data when requested, Glocalzone may not be able to perform the contract it has or is trying to enter. In this case, Glocalzone may have to cancel the Services but it will notify you. Glocalzone is trying to implement data minimization techniques in order to enhance the quality and mitigate the risks for personal data that are processed. Therefore, Glocalzone solely request the data which are needed to provide it’s services. How is your personal data collected? Glocalzone uses different methods to collect personal data from and about you including through:

• Direct interactions. You may give us your contact information by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you create a profile through Glocalzone; or

• Participation contact if you participate in a survey or other offer that we might make available to you; or

• Cookies. As you interact with Our Website, We may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see Our cookie policy below for further details.

We use collected information internally to improve our marketing efforts, analyse use of the Site and Application, improve our content and product offerings and customize the content of the Site and Application and layout. This allows us to improve the Site, Application and Services and better tailor your online experience.

How Glocalzone uses your personal data

Glocalzone will only use your personal data when the law allows us to, ie, if we have a legal basis for doing so, as outlined in this Policy or as notified to you at the time we collect your personal data, and for the purposes for which it was collected for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. All processing activities carried out by Glocalzone is legally based on the performance of the membership agreement which is signed between you and Glocalzone. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

How your personal data may be shared

Where we act as the data controller, personal data processed by Glocalzone may be shared as follows: Glocalzone provides collected information to authorities, as may be appropriate for regulatory purposes, our service providers such as Google Firebase, Google Analytics as reasonably necessary or appropriate to provide the Services. Glocalzone servers are hosted by Amazon Web Services and are located in EEA. We also disclose your contact details to SendGrid, Sendloop and Mailchimp for mailing purposes. Wirecard is a business partner of Glocalzone on financial transcations. However, EU authorities have deemed the payment institutions to be in he capacity of data controllers. Therefore, Glocalzone only directs you to Wirecard to complete and fulfill the transcation and Glocalzone does not collect any financial data from you.

Travelers

As providing our services involve bringing together shoppers and travelers, in order to fulfil your requests, appropriate personal data will be passed on to the relevant travelers who need to process your personal data so that they can reach out to you.

We require all third parties to respect the security of your personal data and request that travelers do the same, to treat your personal data in accordance with the law. We do not allow any other third-party service providers that we appoint to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Some of Our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data to countries outside of the EEA as a data controller to other people or companies it will based on your prior consent. Where we do so, Glocalzone shall take all steps to ensure that any country to which the personal data has been transferred has suitable protection mechanisms in place to protect personal data, including (if applicable) use of EU Model Clauses in any contract with that third party for steps to be taken to keep personal data secure.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (We call this marketing). Therefore we use Google Analytics for marketing purposes and you will only receive marketing communications from Glocalzone if you have either requested information from us, and you have not opted out of receiving that marketing.

Cookies

Cookies are small pieces of data that are stored by a user’s web browser on the user’s hard drive for a period of time. Cookies may record information a user accesses on one webpage to simplify subsequent interactions with that website by the same user, or to use the information to streamline the user's transactions on related webpages. Cookies make it easier for a user to move from webpage to webpage and to complete transactions over the Internet. We use “cookies” to make Glocalzone easier for you to use and to provide better services.

Glocalzone also uses “cookies” to store and sometimes track information to make your online experience easier and more personalized. We collect the abovementined technical data via cookies based on the legal basis of performance of a contract.

Most major web browsers are set up so that they will initially accept cookies, but you may modify your computer's preferences to issue you an alert when a cookie is downloaded, or to disable the ability of third parties to download a cookie to you. If you choose to reject all cookies, there might be areas of the Site and Application that may not function properly.

Opting out

You can opt-out of receiving marketing communications from Us at any time by contacting us via the following methods.

1. Email Us at help@glocalzone.com providing your full name, address and postcode and the email address which you would have originally used.

2. You can also be removed from Our email database by clicking the Unsubscribe link located in the footer of all marketing email communications from us.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Third party processors will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have implemented penal clauses to our data processor agreements in order to effectively supervise the third party processing activities.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Other than in relation to government / public authorities (over whom We have no control), We take appropriate steps to ensure that anyone to whom We pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.

Personal Data Retention

We will keep your information for as long as we need it for the purpose it is being processed for. Each data category and relevant retention period is provided below:

Name During the period of Glocalzone membership

Surname During the period of Glocalzone membership

Email During the period of Glocalzone membership

Country During the period of Glocalzone membership

Telephone Number During the period of Glocalzone membership

Name During the period of Glocalzone membership

Surname During the period of Glocalzone membership

Email During the period of Glocalzone membership

IBAN During the period of Glocalzone membership

National Identity Number During the period of Glocalzone membership

We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.

Data Subject’s Rights

You can do the following at any time by contacting us via the email address or phone number given on our website: (i) see what data we have about you, (ii) change/rectify any data we have about you, (iii) have us delete any data we have about you, (iv) express any concern you have about our use of your data and (v) withdraw your consent for processing of personal data.

Children and Minors

The Website is not intended for children and Glocalzone will not knowingly collect any personal data from persons under the age of 18. Where, as part of the Services being provided we may collect information about children from you to perform such Services and we will treat such information securely.

Complaints

If you would like to make a complaint in relation to how Glocalzone may have stored, used or processed your personal data, you have the right to make a complaint at any time to the supervisory authority for data protection issues of the country you reside in.

External Websites

The Website may, from time to time, contain links to and from the websites of Glocalzone partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Glocalzone is not responsible for the content of external internet sites and you are advised to read the privacy policy of external sites before disclosing any personal data.

Security

We use reasonable security measures to help protect and prevent the loss, misuse, and alteration of the information under our control. No method of transmission over the Internet, or method of electronic storage, is completely secure, however we have implemented all reasonable measures to mitigate the risks of a data breach. Therefore, we cannot guarantee it’s absolute security

Amendments to the Privacy Policy

As and when necessary, changes to this Privacy Policy will be posted here. Where changes are significant, we may also email all our registered users with the new details, and where required by law, we will obtain your consent to these changes.