Privacy Policy for Globalstratos Management Corporation

Effective Date: 2024 October 10
Last Updated: 2024 October 10

1. Introduction

This Privacy Policy explains how Globalstratos Management Corporation (“we,” “us,” or “our”) collects, uses, shares, and protects personal information. This policy applies to our website globalstratos.network and all its sub-domains, our mobile applications, and all related services (collectively, our “Services”).

We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) in the European Economic Area (EEA) and the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) in California.

2. Data Controller and Representative

For GDPR purposes, the data controller is:
Globalstratos Management Corporation
Raleigh, NC USA
privacy@globalstratos.network

3. Information We Collect

We collect and process the following categories of personal information:

  • Identifiers (e.g., name, email address, postal address, phone number, IP address)
  • Customer Records Information (e.g., payment information, purchase history)
  • Protected Classifications (e.g., age, gender)
  • Commercial Information (e.g., products or services purchased)
  • Internet Activity (e.g., browsing history, search history)
  • Geolocation Data
  • Audio, Electronic, Visual, or Similar Information
  • Professional or Employment-Related Information
  • Inferences drawn from other personal information
  • And other information that is applicable to the business we do or product or services we provide to you.

4. Sources of Personal Information

We collect personal information from:

  • Direct interactions with you
  • Automated technologies or interactions (e.g., cookies)
  • Third parties (e.g., analytics providers, advertising networks)

5. Purposes and Legal Bases for Processing

We process your personal information for the following purposes and legal bases:

  • Perform our contract with you (e.g., process payments, deliver products)
  • Comply with legal obligations
  • For our legitimate interests (e.g., improve our Services, prevent fraud)
  • With your consent (e.g., marketing communications)

For each purpose, we will rely on one or more legal bases, depending on the circumstances.

6. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

7. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

  • Right to access
  • Right to rectification
  • Right to erasure (“right to be forgotten”)
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Rights related to automated decision-making and profiling
  • Right to withdraw consent
  • Right to opt-out of the sale of personal information (California residents)
  • Right to non-discrimination for exercising your rights

To exercise your rights, please contact us using the information in the “Contact Us” section.

8. Data Sharing and Transfers

We may share your personal information with:

  • Service providers
  • Business partners
  • Affiliated companies
  • Legal and regulatory authorities

When we transfer personal data outside the EEA or California, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or binding corporate rules.

9. Sale of Personal Information

We are not in the business of selling personal information. However, if an instance arises, we will obtain your explicit consent.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies. You can manage your cookie preferences through our cookie consent tool or your browser settings.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal information. However, no method of transmission over the Internet or electronic storage is 100% secure.

12. Children’s Privacy

Our Services are not intended for children under 16. We do not knowingly collect personal information from children under 16 without parental consent.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date.

14. Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • By email: privacy@globalstratos.network
  • By phone: +1.919.910.2400

15. Complaints

You have the right to lodge a complaint with a supervisory authority. For the EU, you can find your national data protection authority here: https://edpb.europa.eu/about-edpb/board/members_en

For California residents, you can contact the California Attorney General’s office at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company

16. Additional Information for California Residents

Under the CCPA/CPRA, California residents have the right to request:

  • The categories and specific pieces of personal information we have collected about you
  • The categories of sources from which we collect personal information
  • The purposes for collecting or selling personal information
  • The categories of third parties with whom we share personal information
  • The categories of personal information we have sold or disclosed for a business purpose

To make such a request, please use the contact information provided in the “Contact Us” section.

17. Additional Information for EEA Residents

If we rely on consent as a legal basis for processing your information, you may withdraw consent at any time.

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on individuals.

18. Sensitive Personal Information

We collect and process sensitive personal information, such as health information and biometric data, only with your explicit consent or when necessary for specific legal purposes. We implement additional safeguards for this data.

19. Specific Processing Activities

We engage in the following specific processing activities:

  • Email marketing: You can opt-in or opt-out of our marketing emails at any time by clicking the “unsubscribe” link in any marketing email or contacting us directly.
  • Customer profiling: We analyze purchase history and website usage to provide personalized recommendations and improve our services.
  • Use of AI/machine learning: We use AI to enhance our customer support chatbot and to analyze customer feedback for service improvement.

20. Data Protection Impact Assessments (DPIAs)

We carry out Data Protection Impact Assessments for processing operations that are likely to result in a high risk to the rights and freedoms of individuals.

21. Privacy by Design and Default

We implement privacy by design and default principles in our data processing activities and systems.

22. Employee and Job Applicant Data

For information on how we handle employee and job applicant data, please refer to our separate Employee Privacy Notice.

23. Blockchain Technology

We utilize blockchain technology for secure transaction logging. This may impact your ability to exercise certain rights, such as the right to erasure, due to the immutable nature of blockchain.

24. Internet of Things (IoT) Devices

Our IoT devices collect usage data and environmental readings. This data is used for product improvement and shared with our cloud service providers. You can manage data collection settings through the device’s companion app.

25. Cross-Border Data Transfers

We transfer data to the following countries outside the EEA: United States, Canada, and Japan. We rely on Standard Contractual Clauses to safeguard these transfers.

26. Data Breach Notification

In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority without undue delay.

27. Data Portability Format

When you exercise your right to data portability, we will provide your data in a structured, commonly used, and machine-readable format (e.g., CSV files).

28. Privacy-Enhancing Technologies

We employ privacy-enhancing technologies such as encryption and pseudonymization to protect your personal data.

By using our websites, applications, services, etc., you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our services, websites, applications, etc.

29. Contact Us – Data Protection Officer (DPO)

Our Data Protection Officer can be contacted at:
Privacy in Global Governance, Risk, and Compliance Division
privacy@globalstratos.network
+1.919.910.2400