Privacy Policy – GlobaHub AG

1. INTRODUCTION

The protection of your privacy is important to GlobaHub AG, a company incorporated under the laws of Switzerland, which principal place of business at Alpenstrasse 2, 6300 Zug, Switzerland, and its affiliates (hereinafter “GlobaHub”, “we” or respectively “us”, “our”).

Our privacy mission is to establish and maintain strong data protection and privacy practices that safeguard personal information and build trust in our messaging services.

Our privacy vision is to be recognized as a privacy and data protection leader in the telecommunications industry, by providing compliant, secure, and transparent messaging services that enable our customers and partners to communicate with confidence.

When we refer to personal data, we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data or to an identification number (“Personal Data”). When we refer to “processing”, we mean any operation or set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Our Privacy Policy applies to all users and others who access the website https://globahub.com/, its subdomains and landing pages operated by us (the “Websites”), the messaging service platform accessible at https://retail.globahub.com/ (the “Platform”), and/or persons whose Personal Data we may process as a result of our business activities (“Users”). We also refer to such persons by “you” in the text. The reference to the services provided on or through the Platform is the “Services”. The Privacy Policy does not apply to services we provide or buy under separate contractual agreements (“Service Agreement”) with our clients or business partners unless the Service Agreement expressly implements this Privacy Policy as an integral part of the corresponding Service Agreement.

GlobaHub processes your Personal Data as legally permitted under EU General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data privacy laws. Any Personal Data, whether sensitive or not, is processed confidentially and under the terms stipulated below.

We encourage you to review our Privacy Policy on a regular basis and whenever you intend to provide personal data to us. We may amend this Privacy Policy from time to time to reflect changes in our information handling practices as well as to follow applicable law and legislation.

2. OUR ROLES

Our roles may differ regarding various information we process within our business activities. We are the controller of Personal Data collected by us through the Websites and we may be a controller or a processor for Personal Data collected on the Platform. The term “controller” means the organization which determines the purposes and means of the data processing and is responsible for processing such data in a manner consistent with the applicable privacy law. The term “processor” means an organization who processes personal data on behalf of the controller.

GlobaHub as a processor
By using our Platform, our customers are able to send or exchange their communications with their end-users using different communication channels (SMS, email, etc.). We are not in a direct relationship with our customers’ end-users, so we distribute these communications through telecom operators and other communications providers. When we do this, we act as the processor on behalf of our customers and process the relevant data for the sole purpose of providing our Services to them. We do that within limits and according to customers’ instructions and in line with the Services terms and conditions, agreement for Services, or data processing or similar agreement concluded with the customer.

GlobaHub as a controller
We are a controller when we process Personal Data for our own purposes and do not act on behalf of someone else. We are committed to processing that data as described in this Privacy Policy and respecting all obligations arising from the applicable privacy law.

3. PERSONAL DATA WE PROCESS

We process different categories of Personal Data depending on our role and type of business activity we perform.
3.1. User Data
“User Data” means Personal Data we collect on the Websites and Platform or by other means for which we are controller. This includes:
1. Personal Data you submit on the Websites.

When you fill in our contact form, you may need to provide your contact data, such as name, company name, title/ position/ role and contact details (telephone number, e-mail).

2. Personal Data you submit on the Platform.

You share this data when you create an account on the Platform, namely first name, last name, login, password, VAT number, and company name.

3. Payment information.

When you purchase our Service, we’ll ask you to provide our payment processor with your payment method information like a credit card or your Paypal account and your billing address. Our payment processor acting on our behalf, gathers this so we can bill you for your use of our products and services. Our payment processor will share your billing address with us. We’ll also use your billing address for tax calculation and audit purposes.

4. Personal Data collected automatically.

This includes the following data:
Web Logs. As is true with most websites and services delivered over the Internet, we may gather certain information and store it in log files when you interact with our Websites or Platform. This information includes internet protocol (IP) addresses, as well as browser type, date/time stamp.
Analytics information. We collect anonymized and aggregated analytics information when you use our Websites and/or Platform to help us improve our products and services.
Google Analytics. Our Services use Google Analytics, a web analytics service of Google Ireland Limited (Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). The use includes the “Universal Analytics” operating mode. This facilitates the assignment of data, sessions, and interactions across several devices to a pseudonymous user ID and, thus, the analysis of a user’s activities across devices. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
Cookies and other tracking technologies. We use cookies to enable the Websites and Platform functionality, make it easier for you to navigate our site, and help us with our marketing efforts. You can decide whether to accept or reject cookies other than essential cookies. You can manage your cookie preferences by clicking on the “Cookies Settings” or the equivalent button on our cookie banner. For more general information on Cookies, please visit http://www.allaboutcookies.org/. You can also change your browser’s settings to delete already set cookies and not to accept new ones. Please learn more about our cookies practices in our Cookie Policy.
Your consent choices and preferences to process Personal Data / use cookies / receive newsletter and other services requested by you.

5. Usage data collected on the Platform.
When you use our Platform, we collect a variety of data to enhance your experience and maintain the functionality of our Services:
Communication Details:

Telephone numbers of individual data subjects.
Device location data generated during the provision of Services.
Date, time, duration, and type of communication.
Other data that may be considered as Personal Data according to applicable law.

Activity Logs:

Identification of the source of Service requests.
Optimization and maintenance of Service performance.
Investigation and prevention of system abuse.

6. Other Data You May Submit to Us
In addition to usage data, we may collect other types of data when you interact with our Platform in various ways:
Participation in interactive features on our Websites or related landing pages.
Participation in surveys, contests, promotions, sweepstakes, activities, or events.
Job applications.
Requests for customer support.
Communication via third-party social media sites.
Any other form of communication with us.

3.2. Service Data
“Service Data” means Personal Data for which we are a processor, such as routing and message data, including message content, that is created and processed as a part of provision of Services. User Content is any data you may share with us while using our Services and includes some technical logs necessary for the Services to run. We use this data as necessary to provide the Services to you only. This Personal Data is exchanged as a result of using the Services, such as text message bodies, voice and video media, images, email bodies, email recipients, sound, and, where applicable, details User submits to the Services from its designated software applications and services and (b) data stored on User`s behalf such as communication logs within the Services.

If you are an end user of a GlobaHub customer, this Privacy Policy does not apply to the services that our customers provide to their end users. Our customers have their own policies regarding the collection, use, and disclosure of the personal data of their end users. If you are an end user of one of our customers and want to learn about how that customer handles your personal data, we encourage you to read the customer’s privacy policy. Only the customer can assist you with requests for access or deletion.

4. THE LEGAL BASES AND PURPOSES OF PROCESSING YOUR PERSONAL DATA

We will handle your Personal Data using one or more of the following legal bases, depending on which features of our Services you use:
– Contract. We use your Personal Data to fulfil our contractual obligations and provide the Services to you.
– Consent. For example, when you create an account on the Platform, we may ask you to permit us to process your Personal Data.
– Legitimate interest. We may process your Personal Data in relation to our interests in providing the Services to you, our legitimate commercial interests, our interest in protecting the security and integrity of the Services, and wider societal benefits, as allowed under the law.
– Legal obligations. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.

Our mission is to improve our Services and constantly provide new user experiences. As part of this mission, we may use your Personal Data for the following purposes and under the applicable legal basis:

Purpose of processing	Legal basis	Example of processing	Duration of processing
To enable you to access and use our Websites	Contract, legitimate interest	We use your User Data processed automatically (namely, essential cookies and certain web logs) to enable your access and navigation on the Websites	Retained only temporarily (as expressed in our cookies statement) before anonymization and as needed to enable your use of the Websites
To enable your use of the Platform and to provide Services to you	Contract	We use your User Data that you submit on the Platform, Payment information and information collected automatically to provide you with all requested Services. We use your Service Data as a processor to enable the functionality of the Services only	For the duration of the business relationship between you and GlobaHub
To enhance user experience by providing personalized content and features	Consent, legitimate interest	We use User Data collected automatically on the Websites and on the Platform (cookies and similar technologies) to provide you the best user experience possible	For the duration of your consent (until you opt-out or the opt-in ceases to be relevant)
To evaluate and improve the performance and design of the Websites, the Platform and our Services	Consent, legitimate interest	We use User Data collected automatically on the Websites and on the Platform (cookies and similar technologies, analytics information) to understand how you use the Websites and Services and to improve them for your convenience	For the duration of your consent (until you opt-out or the opt-in ceases to be relevant)
For analytics and product development	Legitimate interest	We analyse User Data collected automatically, for example log information on use of the Platform (as collected by tracking technologies described on our cookies policy, and other analytics and reporting instruments) to develop new functionality and improve our Services	Retained only temporarily (as expressed in our cookies policy) before anonymization
For marketing and promotion and to send you promotional communications	Consent (for such practices where you have explicitly opted in or registered) or legitimate interests (when we reach out to you as a person of interest where the law allows us to do so)	We use various User Data collected on the Websites and the Platform (excluding Payment information) to build our marketing strategy and advertise our Services, to send you newsletters, information, and invites for seminars or webinars, white papers or similar marketing activities	For the duration of your consent (until you opt-out or the opt-in ceases to be relevant) or, when not based on your opt-in until you are no longer associated with a relevant lead
To communicate with you and send you system and transactional messages	Contract, consent or legitimate interest as the case may be	We use your User Data you submitted (contact information) to communicate with you when you contact us, to contact you regarding your purchases on the Platform, and send you other system communications according to your request or a contract you entered with us	For the duration of the business relationship between you and GlobaHub
To promote the website in social media by using the social media plug-ins placed on the Websites	Consent, legitimate interest	Some technical identifiers originated from social media services are used to enable plug-ins functionality and help us with our marketing efforts	For the duration of your consent (until you opt-out or the opt-in ceases to be relevant)
Administering opt-outs and opt-ins	Legal obligation under privacy and marketing laws	The contact data you share with us and/or information collected automatically is used for maintaining features for opt-out and opt-in (such as consents and unsubscribe features) as required by law	As required to maintain an appropriate opt-in and opt-out register in each instance
To enhance security and to protect us from fraud or other inappropriate conduct	Legal interest or legal obligation as the case may be	We use various User Data for security purposes and to detect inappropriate behaviour such as fraud, spam, phishing and similar harmful activities. Where the law allows or requires us to do so, we may also perform such activities with your Service Data	Retained for a period as needed to perform security activities and keep evidence for inappropriate behaviour
To comply with any legal obligation, we are subject to	Legal obligations under tax laws and other national reporting laws	We use User Data you submitted to us and your Payment information to fulfil our legal obligations on tax and other mandatory reporting under the applicable law	We will delete such records when we are no longer legally obligated to retain them but may retain anonymized records, if the law allows
To establish, exercise or defend legal claims, and/or to protect and assert our and your legal rights	Legitimate interest	We use your contact data and User Data collected automatically to protect our interests in official proceedings	For as long as needed for legal proceedings
To respond to legitimate authority requests for information	Legal obligation	Your User Data may be used to respond to authorities` requests according to legal requirements in each jurisdiction
To aggregate, anonymize or de-identify your Personal Data	Legitimate interests	We may aggregate or de-identify your User Data so it no longer allows to identify you and is not Personal Data no more	Aggregated and/or anonymized information may be retained for indefinite period according to applicable law

In all cases above, GlobaHub will limit the Processing of Personal Data to the extent required to fulfil the specific purpose.

Your respective Personal Data will be held in our website database or stored on the servers of our hosting services providers. Cookie data is retained based on the cookie’s duration and is cleared upon expiration. Analytics data is retained for a limited period, for analysis and improvement purposes.

If we need to process your information for a specific purpose not clearly outlined in this Policy and not concerning our ability to provide you with all requested Services and features of the Platform, or a justified legitimate interest, we will ask you for consent while amending the list of purposes above.

5. NEWSTELLER

When you subscribe to our newsletter, we collect and store Personal Data shared by you in the online request form according to this Privacy Policy. If you wish to unsubscribe, please click the “Unsubscribe” button in the newsletter you have received from us and your Personal Data will be automatically deleted.

6. SHARING OF YOUR INFORMATION

We will only share your information with third parties in the ways described in this Privacy Policy. Without your permission, we do not share Personal Data with third parties for their marketing purposes (including direct marketing). We will not rent or sell your Personal Data to any third parties.

To the extent reasonably necessary, we may disclose your Personal Data with:

our affiliates/employees other third parties if any who support this website or otherwise are required to Process your Personal Data for the purpose of GlobaHub’s business operations;
third parties who provide marketing and/or additional support services;
law enforcement bodies, state agencies, courts, regulatory authorities or similar if required to be disclosed for compliance with a legal obligation to which we are subject, to protect your or third party’s vital interests, or to exercise or defend our legal claims;
other third parties, upon your prior written consent/instruction or on the basis of our legitimate interest.

6.1. Third-party tools
We occasionally engage outside businesses to process your Personal Data on our behalf. They are the “processors” of your Personal Data. Processors assist us in managing the Services, facilitate our communication with you, and carry out other related tasks. To complete these objectives, they may process specific Personal Data on our behalf, acting under our instructions and subject to demands of applicable data protection laws. To the degree applicable legislation requires, we will execute data processing agreements with our processors and maintain responsibility for their actions.

GlobaHub uses trusted third-party services in order to improve the use of this website. These third-party services include tracking, measurement, and optimization purpose tools as well as other tracking technologies to gather non-personal information and record website traffic.

Third-party services help us to better understand the visitors’ experience (e.g. how much time you spend on which pages, which links you choose to click etc.) and hence enable us to build, maintain, and improve the website with such feedback.

We may also use campaign tools in order to measure the success of our marketing campaigns, improve the quality of this website and make it relevant to the needs of visitors.

The table below contains more specific information on our third-party service providers and their respective tools, together with the description of each service provided by such tool. For more information on privacy policies implemented by each of the third service providers please follow the link indicated in the table itself. If you do not want to share your Personal Data with third-party providers, in some cases, as also indicated in the table below, you can for example use their Opt-out Browser add-on and withdraw your consent.

Third-party Service	Third-party Provider	Tool/Service description	Link to Privacy Policies and Opt-Out and Settings Preferences
Amazon Web Services	Amazon Web Services, Inc.	Hosting services	AWS Data Processing Addendum
Google Analytics	Google, Inc	Tool for tracking and reporting the website traffic	Privacy policy Opt-out
Google Tag Manager	Google, Inc	Tool for Managing JavaScript and HTML tags used for tracking and analytics on website	Privacy policy
Google Search Console	Google, Inc	Tool for monitoring the website traffic and performance	Privacy policy
Google Data Studio	Google, Inc	Tool for creation of internal reports	Privacy policy
Google Optimize	Google, Inc	Tool for testing the effectiveness of website variations	Privacy policy
Hotjar	Hotjar Ltd	Tool for evaluating the visitor’s experience (e.g. how much time they spend on which pages, which links they choose to click) and enabling to build and maintain the website with this feedback	Privacy policy Opt-out
Facebook button Facebook “Share” button	Facebook Inc.	Social media plug-ins for promotion of social media profiles and increase of website traffic through social media	Privacy policy
LinkedIn button LinkedIn “Share” button	LinkedIn Corporation	Social media plug-ins for promotion of social media profiles and increase of website traffic through social media	Privacy policy
YouTube button	YouTube LLC	Social media plug-in for promotion of social media profiles and increase of website traffic through social media	Privacy policy
Google Ads	Google, Inc	Marketing campaign tool	Privacy policy Ads Personalization
Facebook Ad Campaign Pixel	Facebook Inc.	Marketing campaign tool	Privacy policy Ads Personalization
LinkedIn Ad Campaign Pixel	LinkedIn Corporation	Marketing campaign tool	Privacy policy Opt-out

6.2. Social media plug-ins
GlobaHub uses also social media plug-ins on this website in order to promote our social media profiles and increase website traffic through social media. We use plug-ins from social media like: facebook.com, linkedin.com, youtube.com. By including such plug-ins, GlobaHub does not make or implies to make a recommendation or endorse the views expressed by these third-party providers. Every time you visit our Websites and you use one of these plugins, your browser will connect to the providers of the such plugins and inform them about the websites you are viewing. These providers will receive information depending on the specific features of the plug-ins. GlobaHub does not have any influence over the data transferred and collected by these providers. Furthermore, any information shared between you and such providers is processed according to their respective privacy standards and is not under control of GlobaHub. For further information on the privacy standards of third-party plug-in providers, please visit their websites and in specific their privacy policies, such as:

GlobaHub is not responsible for any transmission, collection, or usage of data transferred to these third-party plug-in providers and makes no warranties or representations of any kind as to the legality of the data processing by such third-party plug-in providers or the accuracy or completeness of any information contained in their privacy policies and excludes any related responsibility and/or liability.

7. INTERNATIONAL TRANSFER OF PERSONAL DATA (OUTSIDE EU/EEA AREA)

As a rule, your Personal Data will be transferred to our headquarters in Switzerland, a country recognized by the European Commission as a country with an appropriate safeguard and adequate level of data protection.

In specific cases, Personal Data may be transferred to other additional countries outside of the EU/EEA. To that regard, additional safeguards will be put in place.

We try to ensure that the recipient of any Personal Data provides proper protection of the Personal Data received, in accordance with the current legislation on protecting such information. By agreeing with this Policy, you agree that we may transfer your Personal Data to any third country, a territory, or one or more specified sectors within that third country or to the international organization. Please note that we cooperate only with those service providers that have passed our security and reliability check. If applicable, we are party to data transfer agreements/data processing addendums or equivalent legal instruments with each of our service providers, and we will (i) keep each document up to date with current law and (ii) only engage in personally identifiable information transfers from safeguards area to outside safeguards area in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. Where we transfer your Personal Data as described above, we will take steps to ensure that your Personal Data receive adequate security protection where it is processed and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission.

8. YOUR DATA PRIVACY RIGHTS

With respect to your Personal Data that we Process, you have the following rights:

Right to access: You may request us to provide you with a copy of your Personal Data, generally free of charge, in an electronic format;
Right to rectification: You may request us to correct, update, and/or otherwise amend your inaccurate or incomplete Personal Data;
Right to object: You may object to the Processing of your Personal Data (in case Personal Data is processed on the legitimate interest legal basis);
Right to restrict Processing: You may restrict the Processing of your Personal Data;
Right to erasure: You may request us to erase your Personal Data;
Right to data portability: You may ask us to transfer your Personal Data to you or to a third party designated by you (in case Personal Data is processed on the consent legal basis);
Right to withdraw your consent: You may withdraw your consent (in case Personal Data is processed on the consent legal basis);
Right to file a complaint: You may file a complaint to a data protection authority.
To exercise any of the rights in relation to your Personal Data, please address your respective request to [email protected]. The exercise of rights is subject to exemptions. In case any exemption applies, we will communicate this to you in a timely manner.

GlobaHub will comply with your justified request without undue delay and, in any event, within one month of the receipt of such request. This period may be extended up to two further months where necessary, taking into consideration the complexity and number of the requests we receive.

9. CONTACTING US

If you have any questions or concerns regarding our Privacy Policy or you have any feedback or suggestions to improve this Privacy Policy, please do not hesitate to contact our Data Protection Officer via email at [email protected].