Last updated: August 2023
This Privacy Policy (“Policy”) governs how Global-e (“Global-e”, “we”, “our” or “us”) collect, receive, use, store and disclose Information (sometimes
referred to as “Personal Information”, as defined below) about individuals in
connection with the use of our online services for the order processing and the
sale of products to you (“Service”).
References to Global-e (or “we”, “our” or “us”) will refer to the Global-e group including the entities,
subsidiaries and affiliated companies listed <<here>>.
This policy explains our privacy practices for
processing Personal Information, as defined below, related to the Service. Your
Information will be collected, used or disclosed only in accordance with the
terms of this policy.
If you do not wish your Information to be collected,
please do not submit it to us. However, please bear in mind that we will not be
able to process your order or be limited in performing all or part of the Service
without receiving your details.
If you are a resident of, or
placing your order from one of the countries listed in the section of “Additional information for users of certain jurisdictions” then the additional and specific terms may apply to you. Please review
them.
Global-e may change and update the terms of this
Policy from time to time. If we decide to change our Policy materially, we will
post the revised Policy on our website with an updated effective date and we
will inform you of such changes by any appropriate means. If you continue to
use the Service after these changes are posted, you agree to the revised
Policy.
For your convenience, we included below summary of this
Policy. This will give you an overview of our practices. Please take the time
to read our full Policy for detailed information on each section.
Your Information is collected directly and indirectly from
you, when you fill out your details on checkout, contact customer service, or interacting
with the services on the webstore. We also receive information from our third
parties such as the Retailer.
In order to process the transaction and deliver the purchased products, your
Personal Information such as your name, email address and delivery address is required.
We will also need your payment details (e.g. credit card number) to have your
payment processed. If you contact our customer support, we will need any other
relevant Information, that will help us to solve the inquiry.
We use your Information for performing the contract
with you and for our related legitimate interests. This includes supporting the
Retailers as well as improving the Services and our products, testing new features and protecting the Service from any misuse and
violations. We may, subject to obtaining your consent or otherwise subject to
taking all required legal measures, use your information for communicating
specific offers, promotions or market activities related to the Service. If you
have agreed to such communication, you will be able to unsubscribe from them at
any time.
For improving your cross-border shopping experience, certain
types of information are collected by using different types of cookies. ‘Traffic/Session’
information including your IP addresses is logged, all as detailed under our
Cookie Policy available using this <<link>>, so please
make sure you review it. Our Service does not respond to Do Not Track (DNT)
signals. Data used for analytic purposes is aggregated and/or anonymized, and
we may use it without sending any further notice.
Sharing your Information with others
Information required for processing your order will be
shared with third parties including, for example, the Retailer, payment
processors or facilitators and shipping carriers. If you provided your specific
consent, we would provide the Retailer with your Information for the Retailer
marketing purpose.
We will also share your Information with third party service
providers including those who provide analytics, as further detailed in our
Cookie Policy, if necessary, to fulfil the purposes for collecting the
Information, provided that any such third party will commit to protect your
privacy as required under applicable law and this Policy, and all in connection
with performing or rendering the Service.
If you do not agree with the sharing or disclosure of
your Information to the Retailer or to any third-party mentioned in this
Policy, we may not be able to perform the Service. By agreeing to this Policy,
you agree to the disclosure of your Information as referenced or mentioned in
this Policy. You will also need to read and understand the privacy policies of
those retailers. We will not sell your Information.
We take steps to de-identify and anonymize parts of
your Information so that it no longer can be used to directly or indirectly
identify you (we will do this in a way that will also prevent this data from
ever being re-identified).
We do not intend to collect Information from anyone we
know to be under the legal minimum age in each jurisdiction where the Service
is available (“Minimum Age”). If you believe that we have
collected such information, please contact us at [email protected].
Merger, acquisition or any other structural change
will require us to transfer your Information to other entities, provided that
the receiving entities will comply with similarly protective policy in accordance
with applicable law.
For completing your online orders
you may be redirected to third party websites (for example, PayPal), that are
subject to their own privacy policies (please read these policies and make sure
you understand them).
We do our best to protect
your Information, and allowing you to fulfill all of your right under local
privacy laws. You may terminate your use of the services at any time.
We implement systems, applications and procedures to
secure your Information, to minimize the risks of theft, damage, loss of
Information, or unauthorized access or use of Information. We retain data as needed.
We respect your right for data
retention and your rights to access the information, to correct and to request
from us to delete records from our systems. At any time you can send
requests by contacting us at [email protected].
Not all your requests can be accommodated at the time
of contacting us due to regulatory requirements. However, we keep Information
only for legitimate and lawful purposes, and only for the duration required for
complying with applicable laws.
Global-e adheres to applicable laws and regulation
regarding the transfer of Personal Information across jurisdictions and
geographical regions.
Global-e’s data servers are located
in the United States of America (“USA”). If you used Global-e services,
your data is stored and processed in USA.
We transfer Information within the Global-e group,
only in accordance with the law and this Policy based on the place of your
residency and the sub-processors fulfilling the transaction. Data transfers are
protected under legally binding agreements. If you are located in the European
Union, the UK or Switzerland, your information is protected under the Standard
Contractual Clauses or pursuant to applicable Transfer Adequacy Decision.
For the European Economic Area (“EEA”), such
transfers to third parties (outside the European Economic Area) will be
governed by a contract based on the model contractual clauses for data
transfers approved by the European Commission or other appropriate safeguards.
Dispute Resolution
Contact us at: [email protected]. We will make good-faith efforts to resolve any existing or potential
dispute with you.
Additional information for users of certain jurisdictions
If you are a user in certain jurisdictions, we have
some clarifications and further information for you in relation to the
applicable local law. Please read the section “Additional information for users of certain jurisdictions”.
Changes to this Privacy Policy – We will
update this Policy from time to time and post any material changes we make. If
you continue to use the Service after these changes are posted, you agree to
the revised Policy
Contact us
Please contact us at: [email protected] for further information. Our EU-GDPR representative
according to Art. 27 GDPR is Rickert Rechtsanwaltsgesellschaft mbH, Colmantstraße 15, 53225 Bonn, [email protected]. Our UK representative is Globale UK Limited,
of 154 Clerkenwell Rd, London EC1R 5AB, UK, [email protected].
To perform the Service, we require to process your
first name, last name, email, phone number, postal address and payment
information including the payment method and payment details (or payment
voucher details) that you provide. Tad ID or identity number (local ID,
passport) may be also required if such information is requested by the customs
or tax authorities in your country (for example to facilitate customs clearance
or remittance of import taxes and duties). If you have contacted the costumer
services of Global-e or the Retailer with enquiries, we will receive and
process any Information that you provide for resolving such matter.
Purchases. When you
interact with Global-e’s checkout your Information is collected. When you place
an order for the purchase of merchandise offered on the Retailers’ sites, we process
such orders using the information you provided and required for completing your
online transaction and for delivering the order to your chosen delivery address
or providing costumer support in accordance with the Service Terms and
Conditions.
Retailers. In certain
cases, where for example, you are pre-registered with the Retailer or the
payment method, we may receive part of the Information from the Retailer to
pre-populate transaction in forms for ease of completion by you.
Log Files. We use log
files from your computer or device when you interact with the Service. The information
contained in log files includes internet protocol (or IP, which is the unique
address that identifies your computer or device on the internet), type of
browser, Internet Service Provider (ISP), date/time stamp, referring/exit
pages, clicked pages and any other information from your browser.
Cookies. We use cookies and similar tracking
technologies to make sure that our Service is continuously improved and meets
your needs. Please review our full Cookies Policy for more
information on the types of cookies we use and their expiration dates. We use
essential cookies for providing, improving, and optimizing the Service and your
experience. Our cookies include cookies provided by third parties used to
secure your transaction and to create statical reports based on aggregated and
anonymized Data. We use standard analytics tools such as of Google Analytics,
Hotjar, Heap and Fullstory (the full and current list
is stated in the Cookie Policy).
By completing the checkout process and using the
Service for the purchase of goods, you provide us with the legal basis to use
and retain your Information as needed to provide you the Service and to improve
it.
As a matter of legitimate business interest, if
applicable, we may use your Information to prevent and detect fraud and abuse
of the Service. We may use the Information to communicate with you in relation
to the Service, and in relation to security inquiries or other administrative
communications related to transactions you have initiated or completed through
the Service. Such communication might include request to identify or
authenticate your access to the Service, and is required for maintaining the
integrity and security of our customers and systems, Service and business.
Please note that such communications are not related to marketing, and
therefore, we do not rely on or require your consent.
In addition, we may also create aggregated statistical
data, inferred non-personal data or anonymize data for
personalizing your user experience, troubleshooting and to ensure our content
and Service are presented in the most effective and relevant manner for you and
your device.
Analyzing anonymous, aggregated and analytical
Information
We may share anonymized or aggregated information with
Retailers, marketing and public relations agencies, or
other third parties including our subsidiaries and affiliated companies. This
information does not contain Personal Information. We have secured procedure
for de-identify your Information. This ensures that this data cannot be
re-identified. When using anonymized information, we will do so without notice
to you. We will also disclose Anonymous Data (with or without compensation) to
third parties, including advertisers and partners.
“Anonymous Data”
means data that cannot identify an individual user, and such identification is
irreversibly prevented, such as aggregated data about the use of our Service.
Therefore, such data does not constitute “Information” and the use and
disclosure of same would not affect any of your rights under applicable privacy
laws.
Marketing
We do not use your
Information for marketing purposes.
Retailers. In
connection with using our Service to make purchases of products available on
webstores, we will share the Information with such specific Retailer who
operates the website through which you made your purchase. Such Retailer will
then be entitled to use your Information as if that Retailer has collected this
information directly, subject to the Retailer’s own privacy policy. For
instance, the Retailer needs to know that you have made a purchase in order to
process its delivery, to handle any requests with respect to the items you
purchased or process returns/replacements. The Retailer may also need to use
the Information to validate your subscription or membership or otherwise allow
you to take advantage of any loyalty scheme that it administers.
If you do not agree with the disclosure of your
Information to the Retailer, we may not be able to perform the Service.
Global-e Intra-group affiliates. We will share your Information with our subsidiaries and group
companies (listed <<here>>) if your purchases are made from locations which require such sharing
or transfer for the performance of the Service or the delivery of your order,
or for such other data processing related to the acquiring of your order,
customs clearance and import formalities or fulfilling tax filing obligations
directly related with the fulfilment of your order. We will also share and
transfer Information to our affiliated companies for storing or processing such
information on our behalf in connection with our provision of the Services.
Such information will be transferred to other jurisdictions around the world
where our servers and systems are located, as described under the “Transferring
Personal Information outside your Territory” below.
Third party
service providers. We will share (insofar as such sharing is necessary) your Information
with our third-party service providers (such as hosting providers, payment
processors, fraud detection and prevention service providers, licensed customs
brokers, data and website analytics services and order fulfilment providers)
whose tools, software, and services we use to process and complete your
transaction(s).
We do not sell your information to others, and do not share your
Information with third-parties other than as outlined under this Policy, or to
the extent necessary for providing you with the Service.
Legal Obligation and necessary disclosure. We may use the Information
to comply with any applicable legal obligations, to enforce any applicable
terms of service and to protect or defend the Service, our rights, the rights
of our users/customers or others. We will
disclose your Information or any information you submitted if we have a good
faith belief that disclosure of such information is helpful or reasonably
necessary to comply with any applicable law, regulation, legal process or
governmental request; enforce the terms of sale, including investigations of
potential violations thereof; detect, prevent, or otherwise address fraud or
security issues; or protect against harm to the rights, property or safety of
Global-e, its users, yourself or the public.
Sharing Information in case of a Structural Change. We
will disclose or transfer your Information if we are acquired by or merged with
a third-party entity, or if we are bankrupted or liquidated. If we will use
your Information or disclose for any purposes not covered in this Policy in
this regard, then we will make efforts to ensure that you receive prior
notification of the new purpose and where relevant, your consent obtained for those
new purposes.
Global-e adheres to
applicable laws and regulation regarding the transfer of Personal Information
across jurisdictions and geographical regions.
For providing you with the Service, and as part of our
cross-border operations, your Information may be transferred to Israel, the
United Kingdom (UK), the European Union and the United States, and shared
between Global-e entities, and additional parties, including the Retailer and
other service providers and sub-processors for fulfilling the Service. We
require such third parties to process such information in compliance with
Global-e policies and procedures. By agreeing to this Policy, you provide
affirmative and informed consent that your Information will be transferred,
collected, used, and disclosed in accordance with this Policy.
Global-e accepts full responsibility for the
protection of your Information, according to the applicable privacy legislation
and this Policy during these onward transfers to third parties. By accepting this Policy, and continuing to
use the Service, you give us your express consent to process and transfer you data as described
in this Policy.
If you are a resident of, or placing your order for
fulfilment into one of the countries listed in the section of “Additional
information for users of certain jurisdictions”, additional and
specific terms may apply to you. Please review them.
We follow generally accepted industry standards, including
the use of appropriate administrative, physical and technical safeguards, to
protect the integrity and security of the Information. For example, certain
sensitive Information (such as data relating to fraud) is transmitted over a
Secure Sockets Layer channel and is encrypted; our payment gateway is Payment
Card Industry compliant. However, no method of transmission over the internet,
or method of electronic storage, is fully secure.
Your Information will also be retained by us as
necessary to and relevant to our legitimate operations, including time
necessary to identify, issue or resolve legal proceedings, enforce the Service
Terms and Conditions, to meet our reporting requirements and as otherwise
required in accordance with applicable law obligations.
We will take appropriate steps to delete or
permanently de-identify Information at the point such information is no longer
needed by us for our legitimate business or legal obligations. While we strive
to use generally accepted means to protect your Information, we cannot
guarantee its absolute security or confidentiality. If you have any questions
about security on the Service, you can contact us at: [email protected].
We request and collect minimal data needed for the
purposes described in this Policy. At any time, you may opt to terminate your
use of the Service. Thereafter, we will stop collecting any Information from
you. However, we will store and continue using or making available certain
Information that is related to you. For further information, please read the
“Protecting Personal Information” section in this Policy.
In accordance with the
laws applicable to you within your geographical region, you may have the
following rights with regard to you Information.
Access the Information. If you are eligible for the right of access under the applicable law,
you can obtain confirmation from us of whether we are processing Information
about you and receive a copy of that data. You may be asked to provide certain credentials to
make sure that you are who you claim you are. At any time, you can contact us
at: [email protected] and request to access the Information that we keep about you. We will
make good-faith efforts to locate your Information that you request to access.
If you find that the information on your account is not accurate, complete or
up-to-date, please provide us the necessary information to correct it.
Rectify the
Information that we keep about you. If you find that the data is not accurate, complete
or updated, then you may provide us with the necessary information to rectify
it and request the correction, amendment or deletion of your Information if it
is inaccurate or if you believe that the processing of your Information is in
violation of the applicable law.
Delete your
Information. In some cases, you have the right to obtain the erasure of Information
concerning you. We will review your request and use our judgment, pursuant to
the provisions of the applicable law, to reach a decision about your request.
Restrict the processing of your Information. In some cases, you
have the right to obtain restriction of the processing of your Information.
Transfer your Information in accordance with your
right to data portability. You have the right
to receive the Information concerning you which you have provided to us, in a
structured, commonly used and machine- readable format, and you have the right
to transmit that Information to another controller without hindrance from us.
This right only applies when the processing of your Information is based on
your consent or on a contract and such processing is carried out by automated
means.
Restrict processing to storage only. In certain circumstances, you have the right to require us to stop
processing your Information that we hold about you other than for storage
purposes. You have the right not to be subject to a decision based solely on automated
processing, including profiling, which produces legal effects concerning you or
similarly significantly affecting you.
Object to the processing of your Information
specifically for direct marketing purposes. When your
Information is processed for direct marketing purposes, you have the right to
object at any time to the processing of the Information for such direct
marketing purpose. Please contact us or the relevant Retailer directly to opt
out of their marketing activities, or use the
‘unsubscribe’ features made available through the relevant marketing
communication.
The Service is not structured to attract or be
directed to anyone under the age of 16 years or the Minimum Age applicable in
your jurisdiction. Accordingly, we do not intend to collect
Information from anyone we know to be under 16 years or
the relevant Minimum Age. In certain countries, as listed in the section of “Additional
information for users of certain jurisdictions”, the Minimum Age may be
different.
If we learn that we have collected Information from a
person who is younger than 16 years or the applicable Minimum Age, we will
delete that information quickly. If you believe that we have any such
information, please contact us at: [email protected].
The Service contains links to third party websites and
services that are not owned or controlled by Global-e including third party
payment providers. We are not responsible for the privacy practices or the
content of third party websites or services and your use of or connection to
such links and websites is at your sole risk. You should review their privacy
policies.
From time to time, we will update this policy. If the
updates have minor to no consequences, they will take effect 7 days after we
post a notice on the Service’s website. Substantial changes will be effective
30 days after we initially posted the notice.
Until the new policy takes effect, if it materially
reduces the protection of your privacy right under the then- existing policy, you
can choose not to accept it and terminate your use of the Service. Continuing
to use the Service after the new policy takes effect means that you agree to
the new policy. Note that if we need to adapt the policy to legal requirements,
the new policy will become effective immediately or as required by law.
Please contact us at: [email protected] for further information.
You can contact our DPO at: [email protected].
For information about our Global-e affiliates please
press here.
If the General Data Protection Regulation (Regulation
(EU) 2016/679) (the “GDPR”) or the UK General Data Protection Regulation and
the UK Data Protection Act 2018 (together the “UK DPA”), applies to the
processing of your Information that can directly or indirectly identify you, by
Global-e, as a data controller, then the following terms apply.
The processing of your Information by Global-e is
based on your consent and Global-e legitimate business interest, as described
under the Policy.
If EU or UK data protection law applies or if you are
located in the European Economic Area, you may contact our EU-GDPR
representative according to Art. 27 GDPR, Rickert Rechtsanwaltsgesellschaft
mbH, Colmantstraße 15,
53225 Bonn, [email protected].
If UK data protection law applies to the processing of
your Information, you may contact our UK representative, Globale
UK Limited, 154 Clerkenwell Rd, London EC1R 5AB, UK, email [email protected].
If you are a resident of the EEA or the UK, you are
entitled to your rights as detailed under this Policy.
If you are based on the EEA you have a right to lodge
a complaint with a data protection supervisory authority of your habitual
residence, place of work or of an alleged infringement of the GDPR. If UK data
processing laws apply to our processing of your Information, you have a right
to lodge a complaint with the UK Information Commissioner’s Office. A summary
and further details about your rights under EU data protection laws, is
available on the EU Commission’s website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
Note that when you send us a request to exercise your
rights, we will need to reasonably authenticate your identity and location. We
will ask you to provide us credentials to make sure that you are who you claim
to be and will ask you further questions to understand the nature and scope of
your request.
As we are an international company, we may securely
share your Information with our Affiliates and our approved partners located
all over the world where necessary for the fulfilment of your purchases and
performance of the Service, as detailed in this Policy.
As detailed under “transferring
Personal Information outside your territory” , Global-e data servers are based in the USA. By using the Service you
provide us with the consent to transfer the Information in accordance with this
Policy.
The transfer of your Information outside the EEA and UK
is protected by the Standard Contractual Clauses in accordance with the
European Commission’s contracts model for the transfer of Information to third jurisdictions,
unless the data transfer is to a jurisdiction that has been determined by the
European Commission (for transfers from the EEA) or the UK Information
Commissioner’s Office (for transfers from the UK) to provide an adequate level
of protection for individuals’ rights and freedoms for their Information. When
we transfer your Information, we will make sure that our data hosting service
providers, or any other third party recipient, provide
adequate confidentiality and security commitments required by law.
For the purposes of this Policy, “Information” means any information or
an opinion about an identified individual, or an individual who is reasonably
identifiable, whether the information or opinion is true, or opinion is
recorded in a material form. We are committed to keeping your Information
secure and will use all reasonable precautions to protect it from loss, misuse
or unauthorized access or alteration. However, except to the extent liability
cannot be excluded due to the operation of statute including the Privacy Act
1988 (Cth), we exclude all liability (including in
negligence) for the consequences of any unauthorized access to, disclosure of,
misuse of or loss or corruption of your Information.
As we are an international company, we may securely share your
Information with our Affiliates and our approved partners located all over the
world where necessary for the fulfilment of your purchases and performance of the
Service, as detailed in this Policy.
By consenting to overseas disclosure, you acknowledge that we do not
guarantee that the overseas recipient will comply with the Australian Privacy
Principles and they may not be subject to privacy obligations similar to those
in your jurisdiction, as detailed under “transferring Personal Information outside your territory” . We will not be
liable to you for breaches of the Australian Privacy Principles committed by
the overseas recipient.
When we transfer your Information, we will make sure that our data
hosting service providers, or any other third party recipient, provide adequate
confidentiality and security commitments. We take reasonable steps to ensure
that third party recipients of your Information that are located outside
Australia do not breach the Australian Privacy Principles and comply with
privacy laws that are similar to those of your jurisdiction, you acknowledge
and agree that we cannot control the actions of third party recipients and so
cannot guarantee that they will comply with those privacy laws.
Nothing in this Policy restricts, excludes or modifies or purports to
restrict, exclude or modify any statutory consumer rights or other rights under
any applicable law including the Competition and Consumer Act 2010 (Cth) or the Privacy Act 1988 (Cth).
If you are unhappy with this Policy or you have a complaint about compliance
with the Australian Privacy Principles, please contact us at: [email protected]. We will respond to
your complaint and make good-faith efforts to resolve your complaint within a
reasonable time (and in any event within 30 days). If you are not happy with
how we have dealt with your complaint, you may submit a complaint to the Office
of the Australian Information Commissioner via the website at: https://www.oaic.gov.au/privacy/privacy-complaints/..
The Service is not structured to attract or be directed to anyone under
the age of 18 years or under the age of 14 without parental consent. Accordingly, we do not intend to
collect Information from anyone we know to be under that minimum age.
If we learn that we have collected Information from a person who is
younger than 18 years or under 14 years without parental consent, we will
delete that information quickly. If you believe that we have any such
information, please contact us at: [email protected].
As we are an international company, we may securely share your Information
with our Affiliates and our approved partners located all over the world where
necessary for the fulfilment of your purchases and performance of the Service,
as detailed in this Policy.
By agreeing to this Policy, you consent to your Information and
sensitive personal Information being transferred and collected, used, and disclosed
in accordance with this Policy, as detailed under “transferring Personal Information outside your territory”. Please note that
the Information collected from you may be transferred outside China Mainland
including to the European Union and the United States. By agreeing to this
Policy, you consent to your Information and sensitive personal Information
being transferred and collected, used, and disclosed in accordance with this
Policy.
Where your Information is transferred to another jurisdiction outside
mainland China, your Information will be secured by substantially appropriate
safeguards as set forth in China Data Protection Law, in particular, but
without limitation to, where applicable by the use of the standard contract
developed by the supervisory authority for the transfer of Information between
mainland China and other jurisdictions. To the extent required under the China
Data Protection Law, we will obtain separate consent from you before the
transfer of your Information. If you would like to learn more about list of overseas
data recipients where your Information is transferred to, you may contact our
privacy team at: [email protected].
In accordance with the terms of the applicable China Data Protection Law,
Individuals must be notified at the point of collection of the purposes for
which the Information was collected and thereafter the Information can only be
used for those purposes unless consent is obtained for a new purpose.
In accordance with the terms of the applicable China Data Protection
Law, you may have the following rights to your Information, including the
rights detailed under this Policy to request access to, and transfer, correction
or deletion of, your Information, and withdrawal of you consent to, or
restriction or objection to the processing of your Information, and
cancellation of your account. You also have the right to request us to explain
our Information processing rules. To the extent permitted by applicable China
Data Protection Law, a fee may be chargeable by us for complying with a data
access request. In certain instances, applicable China Data Protection Law may
allow us legitimately and properly to refuse some of these requests; for
instance, to comply with applicable legal obligations, to protect the
legitimate rights of third parties or to preserve the confidentiality of
management deliberations.
For the purposes of this Policy, China Data Protection Law shall mean
the Cybersecurity Law of the People's Republic of China (“PRC”), the PRC Data
Security Law, the PRC Personal Information Protection Law, and all related,
then current data protection provisions under the PRC Civil Code, other data
protection related laws, regulations, administrative rules, administrative
measures and national guidelines effective in China Mainland (together as
“China Data Protection Law”).
The Service is not structured to attract or be directed to anyone under
the age of 18 years. Accordingly,
we do not intend to collect Information from anyone we know to be under that minimum age.
If we learn that we have collected Information from a person who is
younger than 18 years or under 14 years without parental consent, we will
delete that information quickly. If you believe that we have any such
information, please contact us at: [email protected].
As we are an international company, we may securely share your
Information with our Affiliates and our approved partners located all over the
world where necessary for the fulfilment of your purchases and performance of the
Service, as detailed in this Policy.
In accordance with Section 33 to the Ordinance, by using the Service you
agree to your Information, being exported outside your territory, including
your name, email address, physical address, telephone number, ID number or
credit card/payment details. You consent to the Information being processed in
the Economic Area of the European Union, and transferred between Global-e
entities, as detailed under “transferring Personal Information outside your territory” , including to the
European Union and the United States, in order to provide you with the Service,
or to other third-party such as shipping providers, the Retailer of the
merchandise you purchased from and payment services providers, who may be
located outside your territory as well.
We will transfer your data only where the transfer is necessary for the
performance of the contract between you and us. You are entitled to make a
subject access request to receive a copy of the data we process about you, a
data correction request as well as a right to reject to the use of your
Information for direct marketing purposes by contacting our Data Protection
Officer at [email protected].
Under the Personal Data (Privacy) Ordinance, individuals must be
notified at the point of collection of the purposes for which the data was
collected and thereafter the data can only be used for those purposes unless consent
is obtained for a new purpose. If you are not happy with this Policy, you may
submit a complaint to the Office of the Privacy Commissioner for Personal Data. As a Hong Kong data subject you have legal rights in relation to the
Information we hold about you (to the extent permitted under applicable laws
and regulations).
As we are an international company, we may securely
share your Information with our Affiliates and our approved partners located
all over the world where necessary for the fulfilment of your purchases and
performance of the Service, as detailed in this Policy.
By using the Service your provide your consent to your
Information and sensitive personal Information being collected, used, disclosed
and transferred cross-border in accordance with this Policy and transferred
between Global-e entities, as detailed under “transferring
Personal Information outside your territory, to any jurisdiction where we have databases or affiliates and, in
particular, to the EU and the US.
You may request us to notify you about the purposes of
use of, to disclose, to make any correction to, to discontinue the use or
provision of, and/or to delete any and all of your Information which is stored
by us, to the extent provided by the Act on the Protection of Personal
Information of Japan. When you wish to make such requests, please contact us at
[email protected].
By using the Services, you signify that you have read
and understood this Policy. To the extent required under applicable law, you
also provide your consent to us collecting, using and disclosing your personal
information in accordance with this Policy.
We will transfer Information (including your name, email
address, physical address and telephone number) to shipping service providers, Retailers
of merchandise you purchase from us, payment services providers,
customs/clearance brokers and logistics providers who fulfil your orders.
Information will be transferred only where necessary for the fulfilment of your
purchases.
Under the Personal Data Protection Act 2012,
individuals must be notified at the point of collection of the purposes for which
the data was collected and thereafter the data can only be used for those
purposes unless consent is obtained for a new purpose.
As a Singaporean data subject you have legal rights in
relation to the Information we hold about you (to the extent permitted under
applicable laws and regulations).
You are entitled to make a subject access request to
receive a copy of the data we process about you, a data correction request as
well as a right to reject to the use of your Information for direct marketing
purposes. We will not charge any fee for complying with
a data access request.
By using the Service your provide your consent to your Information and
sensitive personal Information being collected, used, disclosed and transferred
cross-border in accordance with this Policy to any jurisdiction where we have
databases or affiliates and, in particular, to US, Ireland and Germany.
We take the following steps to ensure the safety of
personal information:
1. Administrative Measures: Establishment and implementation of internal
management plans, regular employee training, etc.
2. Technical Measures: Management of access rights to personal information
processing system, installation of access control system, encryption of unique
identification information, installation of security programs.
3. Physical Measures: Control access to computer rooms, data storage rooms,
etc.
We retain personal information for specified retention
periods pursuant to certain tax and export controls laws to which we are
subject. We store, in an isolated and highly secured fashion, personal
information recorded and stored in the form of electronic files so that the
records cannot be accessed or reproduced without strict procedures and subject
to meeting certain criteria of necessity. After the end of the relevant
retention period, personal information recorded and stored in electronic files
will be securely destroyed using technical measures to prevent the possibility
of recovery and paper records will be either shredded or burned.
The laws of Korea, including the Act on the Consumer
Protection in Electronic Commerce, Etc. (E-Commerce Consumer Protection Act),
the Framework Act on Electronic Documents and Transactions, and the Protection
of Communications Secrets Act, require retention of certain types of
information for a certain period of time, as follows:
|
E-Commerce Consumer Protection Act |
Records of contracts or cancellation of orders shall be retained for a
period of five (5) years. |
|
Records of payments and provision of goods shall be retained for a period
of five (5) years. |
|
|
Records of consumer complaints or dispute resolution shall be retained
for a period of three (3) years. |
|
|
Framework Act on Electronic Documents and Transactions |
Records of electronic document distribution via certified electronic
address shall be retained for a period of ten (10) years. |
|
Protection of Communications Secrets Act |
Sign-in records shall be retained
for a period of three (3) months. |
We have designated the person in charge
of personal information protection as follows in order to take full
responsibility for the handling of personal information, and to handle
complaints from and remedy damages suffered by our users related to our
processing of personal information:
Name:
Oded Griffel
Position:
DPO
Contact
Information: [email protected]
This section applies solely to individuals who reside
in the State of California. We adopted this section to comply with the
California Consumer Privacy Act of 2018 (‘CCPA’),
and the California Privacy Rights Act of 2020 (‘CPRA’) and any terms defined
in the CCPA or CPRA have the same meaning when used in this section.
The following
categories of Information will be collected from consumers within the last
twelve (12) months:
·
Identifiers and Information
categories listed in the California Customer Records statute (Cal. Civ. Code §
1798.80(e)). These include names, telephone number, postal address, online
identifier Internet Protocol address.
·
Commercial
information such as products or services purchased, obtained, or considered, or
other purchasing or consuming histories or tendencies.
·
Internet or other
electronic network activity information, including, but not limited to,
browsing history, search history, and information regarding a consumer’s
interaction with the Service.
·
Geolocation data,
such as your physical location
·
Card details for
processing the transaction of the merchandise
·
Inferences drawn from
any of the information identified to create a profile about a consumer reflecting
the consumer’s preferences, characteristics, psychological trends, preferences,
predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
We obtain the
categories of Information listed above from the following categories of
sources:
·
Directly and
indirectly from you and your activity on our Service.
·
Third parties such as
our retailers.
We use the collected
Information for one of the following business purposes:
·
To fulfill the reason
for which the Information is provided.
·
To provide you with
our products and services and to further develop and improve our products and
services.
·
To enforce our terms
and as necessary to protect our rights.
·
To respond to law
enforcement requests and as required by applicable law, court order, or
governmental regulations.
We do not sell your Information. In the preceding
twelve (12) months, we have not sold Information. We disclose Information
to third parties for business purposes as described in this Policy under “Sharing your personal Information”.
In the preceding twelve (12) months, we have disclosed
the following categories of Information for business purposes:
·
Identifiers, which we
have shared with the following categories of third parties: service providers
involved in the performance of the fulfilment of the sales contract you entered
into, including the retailer;
·
Commercial
information, which we have shared with the following categories of third
parties: the retailer of the merchandise you have purchased from us, the
shipper that delivered your purchase to, the bank or payment service provider
that acquired the transaction for purchasing the merchandise.
How we retain the Information
Your Information will be retained by us as necessary
to and relevant to our legitimate operations, including time necessary to
identify, issue or resolve legal proceedings, enforce our terms of sale, to
meet our reporting requirements and as otherwise required in accordance with
applicable law obligations.
You may be entitled to the following specific rights
under the CCPA and the CPRA regarding your Information:
Access to
Specific Information and Data Portability Rights. You have the right to request that we will disclose certain
information to you about our collection and use of your Information over the
past 12 months. Upon confirmation of your request, we will disclose to you:
·
The categories of
Information we collected about you;
·
The categories of
sources for the Information we collected about you;
·
Our business or
commercial purpose for collecting that Information;
·
The categories of
third parties with whom we share that Information;
·
The categories of
Information that we disclosed for a business purpose, and the categories of
third parties to whom we disclosed that particular category of Information;
·
The specific pieces
of Information we collected about you;
If we disclose your Information for a business
purpose, we will provide you with a list which will identify the Information
categories that each category of recipient obtained.
Deletion Rights. You have the
right to request that we delete any of your Information. Upon confirmation of
your request, we will delete (and direct our service providers to delete) your
Information from our records, unless an exception applies.
Nondiscrimination Right. You have the right not to be discriminated against for exercising any
of the aforementioned rights.
The Right to Correction. if you find that the data is not accurate, complete or updated, then
you may provide us with the necessary information to rectify it and request the
correction, amendment or deletion of your Information if it is inaccurate or if
you believe that the processing of your Information is in violation of the
applicable law.
Exercising Your Rights. To exercise the above rights described above, please submit your
request to us by sending an email to: [email protected]. Only you or a person authorized to act on your behalf, may make a
request related to your Information. You may also make a verifiable consumer
request on behalf of your minor child. If you submit your request through an
authorized agent, we may request that the agent provide proof of your prior
authorization, as well as information necessary to verify your identity.
A request for access can be made by you only twice
within a 12-month period.
We may ask you to provide additional information in
order to verify your identity before we respond to your request. We cannot
respond to your request or provide you with the requested Information if we
cannot verify your identity or authority to make the request and confirm the
Information relates to you. We will only use the Information provided in your
request to verify your identity or authority to make the request.
We will do our best to respond to your request within
45 days of its receipt. If we require more time (up to additional 45 days), we
will inform you of the reason and extension period in writing. If you do not
have an account with us, we will deliver our written response by mail or
electronically, at your option.
Any disclosures we provide will only cover the
12-month period preceding receipt of your request.
The response we provide will also explain the reasons
we cannot comply with a request, if applicable.
For data portability requests, we will select a format
to provide your Information that is readily useable and should allow you to
transmit the information from one entity to another entity without hindrance,
specifically by electronic mail communication.
We do not charge a fee to process or respond to your
request unless it is excessive, repetitive, or manifestly unfounded. If we
determine that the request warrants a fee, we will inform you of the reasons
for such decision and provide you with a cost estimate before completing your
request.
Specific Provisions for Brazil
Residents
Children’s Privacy
The Service is not structured to attract or be directed to anyone under
the age of 18 years. Accordingly,
we do not intend to collect Information from anyone we know to be under that minimum age.
If we learn that we have collected Information from a person who is
younger than 18 years or under 14 years without parental consent, we will
delete that information quickly. If you believe that we have any such
information, please contact us at: [email protected].
Transferring Personal
Information outside your territory
If the transfer of your Information is governed by the
LGPD, and your data is transferred to another jurisdiction outside Brazil, your
data will be secured by appropriate safeguards as set forth in LGPD Arts. 33,
34 and 35, in particular, but without limitation to, by the use of the Standard
Contractual Clauses for the transfer of data between Brazil and other jurisdictions.
If
you are a Brazilian resident, you may be entitled to the following specific
rights under the LGPD regarding your Information:
· The right to
anonymize, block or erase data that is unnecessary, excessive or processed in
violation of the LGPD;
· The
right to erase data that was processed based on consent, unless an exception
applies;
· The right to
confirm and access the Information we collect about you;
· The right
to port data to another service provider;
· The right to
receive information about the public and private entities with whom the
controller has shared data;
· The right to
receive information about the possibility of not providing consent (when it is
required);
· The
right to withdraw consent, when applicable;
· The right to
lodge a complaint with the Brazilian Data Protection Authority; and
· The
right to object to a processing activity when the processing activity violates
the LGPD
Exercising
Your Rights
To
exercise the rights described above, please submit your request to us by
sending an email to: [email protected].
Only you or a person authorized to act on your behalf, may make
a request related to your Information. You may also make a verifiable
consumer request on behalf of your minor child.
We
cannot respond to your request or provide you with the requested
Information if we cannot verify your identity or authority to make the request
and confirm the Information relates to you. We will only use the
Information provided in your request to verify your identity or authority to
make the request.
We
will respond to your request for access within 15 days of its
receipt. If you do not have an account with us, we will deliver our written
response by mail or electronically, at your option.
For data portability requests, we will select a format to
provide your Information that is readily useable and should allow you to
transmit the information from one entity to another entity without hindrance,
specifically by electronic mail communication.