Methods of processing

Glocalization Network takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Glocalization Network, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Glocalization Network (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Glocalization Network.

Legal basis of processing

Glocalization Network may process Personal Data relating to You if one of the following applies:

• You have given your consent for one or more specific purposes. Note: Under some legislations Glocalization Network may be allowed to process Personal Data until you or the owner of such data objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which Glocalization Network is subject;
• processing is necessary in order to provide a service for the owner of such data or a related third party;
• processing is necessary in order to hire services to the owner of such data or a related third party;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Glocalization Network;
• processing is necessary for the purposes of the legitimate interests pursued by Glocalization Network or by a third party.

In any case, Glocalization Network will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at Glocalization Network’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, You can check the section containing details about the processing of Personal Data.

You are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Glocalization Network to safeguard their Data.

If any such transfer takes place, You can find out more by checking the relevant sections of this document or inquire with Glocalization Network using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between Glocalization Network and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of Glocalization Network’s legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests pursued by Glocalization Network within the relevant sections of this document or by contacting Glocalization Network.

Glocalization Network may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Glocalization Network may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The Data concerning the User is collected to allow Glocalization Network to provide its Services, as well as for the following purposes: Analytics, Backup saving and management and Contacting the User.

You can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Personal Data is collected for the following purposes and using the following services:

• Analytics

The services contained in this section enable Glocalization Network to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Glocalization Network, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

• Backup saving and management

This type of service allows Glocalization Network to save and manage backups on internal and external servers managed by Glocalization Network and/or the service provider itself. The backups may include all information shared during the course of a project, request for quotation or any other type of contact with Glocalization Network.

Backup on Google Drive (Google Inc.)

Some information may be stored in Google Drive. Google Drive is a service to save and manage backups provided by Google Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Contacting the User

Contact form Glocalization Network

By filling in the contact form or contacting Glocalization Network in any way, the User authorizes Glocalization Network to use these details to reply to requests for information, quotes or any other kind of request.

Personal Data collected: address, city, company name, country, email address, first name and last name and any other data provided by you.

Mailing list or newsletter (Glocalization Network)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Glocalization Network. Your email address might also be added to this list as a result of signing up to Glocalization Network or after making a purchase.

Personal Data collected: email address, first name and last name and any other data provided. You can opt-out from this list at any point by indicating so to info@be-glocal.com . Not doing so implies you agree being on the list.

You may exercise certain rights regarding your Data processed by Glocalization Network.

In particular, You have the right to do the following:

• Withdraw your consent at any time.You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data or a related third party with their authorization.
• Object to processing of your Data.You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access your Data.You have the right to learn if Data is being processed by Glocalization Network, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification.You have the right to verify the accuracy of your Data and ask for it to be updated or corrected.
• Restrict the processing of your Data.You have the right, under certain circumstances, to restrict the processing of your Data. In this case, Glocalization Network will not process your Data for any purpose other than storing it.
• Have your Personal Data deleted or otherwise removed.You have the right, under certain circumstances, to obtain the erasure of your Data from Glocalization Network.
• Receive your Data and have it transferred to another controller.You have the right to receive your Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint.You have the right to bring a claim before your competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Glocalization Network or for the purposes of the legitimate interests pursued by Glocalization Network, You may object to such processing by providing a ground related to your particular situation to justify the objection.

You must know that, however, should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether Glocalization Network is processing Personal Data for direct marketing purposes, You may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to Glocalization Network through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Glocalization Network as early as possible and always within one month.

Legal action

Your Personal Data may be used for legal purposes by Glocalization Network in Court or in the stages leading to possible legal action arising from improper use of Glocalization Network or the related Services. You declare to be aware that Glocalization Network may be required to reveal personal data upon request of public authorities.

Additional information about Your Personal Data

In addition to the information contained in this privacy policy, Glocalization Network may provide You with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Glocalization Network and any third-party services may collect files that record interaction with Glocalization Network (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from Glocalization Network at any time. Please see the contact information at the end of this document.

How “Do Not Track” requests are handled

Glocalization Network does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

Glocalization Network reserves the right to make changes to this privacy policy at any time by giving notice to You on this page and possibly within Glocalization Network and/or – as far as technically and legally feasible – sending a notice to You via any contact information available to Glocalization Network. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of Your consent, Glocalization Network shall collect a new consent You, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Glocalization Network (or third-party services employed in Glocalization Network), which can include: the IP addresses or domain names of the computers utilized by you, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the file content and the file itself, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by You, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or Your IT environment.

User

The individual using Glocalization Network who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Glocalization Network. The Data Controller, unless otherwise specified, is Glocalization Network.

Service

The service provided by Glocalization Network as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in Your device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Glocalization Network, if not stated otherwise within this document.

Contact information: For any changes in the way your data is handled, please contact info@be-glocal.com with the subject “UPDATE ON PERSONAL INFORMATION PLEASE”. State there your questions or instructions for Glocalization Network on the way your personal data is being handled.