This GDPR Privacy Policy explains how Globify, Inc. (“Globify”, “we”, “our”, or “us”) collects, uses, stores, and protects personal data of users located in the EU/EEA, in accordance with the EU General Data Protection Regulation (“GDPR”). This Privacy Policy works together with our Cookie Policy, which explains how cookies and tracking technologies are used on our service.
Globify, Inc. is the data controller responsible for your personal data under GDPR.
We may collect the following categories of personal data:
We process personal data only where permitted by GDPR, including:
Certain personal data (such as your email address and password) are required to create and maintain your account and to provide the Globify service. If you choose not to provide this information, you will not be able to create an account or use key features of the service. Other data are optional and you can decide not to share them without affecting the core service.
We use your data to:
We share personal data only with categories of recipients necessary to provide and support the service, including hosting providers, analytics providers, payment processors, customer support tools, and other service providers that act on our instructions. Where required, these recipients are bound by data protection agreements that comply with GDPR.
In addition, we may disclose limited personal data (such as account identifiers or contact information) to competent legal authorities, rights holders, or claimants where necessary to respond to valid legal requests or notices, including under the U.S. Digital Millennium Copyright Act (DMCA), Japan's Provider Liability Limitation Act, or equivalent laws in other jurisdictions. Such disclosures are made only as required by law or to pursue our legitimate interests in defending against claims and maintaining platform integrity, and are subject to a case-by-case assessment of necessity and proportionality.
In general, we rely on: (1) performance of a contract to provide and manage your account and paid subscriptions; (2) legitimate interests to improve and secure our services and to prevent fraud, balanced against your rights; (3) consent for optional features such as certain cookies, marketing communications, or user research; and (4) legal obligations where we must retain or disclose data to comply with applicable law.
Cookies and similar technologies are governed by our Cookie Policy, which explains what cookies we use, the purposes of each category, and how to withdraw consent.
Because Globify is incorporated in Japan, your data may be transferred outside the EU/EEA. Japan benefits from an EU adequacy decision. When transferring data to other countries, we use Standard Contractual Clauses or equivalent safeguards.
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements.
If you are located in the EU/EEA, you have the right to:
If and when Globify begins actively marketing or offering the Services to users in the EU/EEA, it will appoint an EU Representative under Article 27 GDPR to act as our point of contact for supervisory authorities and data subjects.
Once appointed, you may contact our EU Representative for all issues related to the processing of your personal data under the GDPR using the contact details that will be provided below.
[Insert Name of Representative]
[Insert Company Name]
[Insert Address]
[Insert Email Address]
You also have the right to lodge a complaint with your local supervisory authority if you believe your data protection rights have been violated.
A list of EU/EEA supervisory authorities is available at:
https://edpb.europa.eu/about-edpb/board/members_en
Globify does not use automated decision-making or profiling that produces legal or similarly significant effects without explicit consent or another lawful basis.
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration.
We use third-party service providers to support our operations (hosting, analytics, payments). All subprocessors are bound by GDPR-compliant agreements.
Our service is not intended for children under 13. If your local jurisdiction requires a higher age threshold for consent, we comply with that standard.
For privacy-related inquiries or GDPR rights requests, contact:
legal@globify.com
Transitional EU/EEA Status.
As of the “Last Updated” date of this GDPR Privacy Policy, Globify does not actively market or offer the Services to users located in the EU/EEA. This GDPR Privacy Policy describes how Globify intends to process personal data if and when it makes the Services available to users in the EU/EEA.
Before launching the Services in the EU/EEA, Globify will (1) designate an EU Representative under Article 27 GDPR and provide the representative’s full contact details in Section 9A, (2) ensure that its Cookie Policy and consent mechanisms are fully aligned with this GDPR Privacy Policy, and (3) update this Policy and any related EU/EEA-facing documentation with all information required by applicable law.
Note: Globify has not yet appointed its EU Representative. The following contact details will be completed before the Services are launched and made available to users in the EU/EEA.