Global-e
Privacy
Policy
Last
updated: July
15, 2021
This
Privacy Policy (“Policy”) governs how we, Global-e
or any of
our affiliated
companies (Global-e U.K. Ltd., Global-e US
Inc,
Global-e NL
B.V., Global-e France SAS, Global-e Spain S.L., Global-e Canada E-commerce Ltd.,
Globale
Hong
Kong
Limited,
Global-e
CH AG, Global-e Australia Pty Ltd., Global-e Japan KK, Global-e (Beijing)
Technology
Co., Ltd.,
Global-e
Online
Pte. Ltd.,
Olami E-commerce Solutions Ireland Limited, in each case) (together with our
respective
affiliates
and
subsidiaries,
“Global-e”,
“we”, “our” or “us
”), collect, receive, use, store and disclose Information (defined
below)
about
individuals in
connection with the use of our online order processing and fulfilment services
for the
sale of products
to
you
(“Service”)͘
We make
great
efforts ascertaining that we secure your Information and use it properly.
This
policy
explains our privacy practices for processing Information regarding our
Services. We
will collect, use
or disclose
your
Information
only in accordance with the terms of this policy.
For
Canadian
residents: Please note that the Information we
collect from
you may be
transferred to Israel, the United
Kingdom
(UK), the
European Union and the United States. By agreeing to this Policy, you consent to
your
Information
being
transferred
and collected, used, and disclosed in accordance with this Policy.
For
Brazilian
residents: Please note that the Information we
collect from
you may be
transferred to Israel, the UK, the
European
Union
and the United States. By agreeing to this Policy, you agree to your Information
being
transferred
and
collected, used,
and disclosed in accordance with this Policy.
For
residents of
the China Mainland: Please note that the
Information we
collect from you
may be transferred to Israel,
the UK,
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.
For
Australian
residents: Please note that the Information we
collect from
you may be
transferred to Israel, the UK,
European
Union
and the United States. By agreeing to this Policy, you consent to your
Information being
transferred
and
collected, used,
and disclosed in accordance with 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. We will not be liable
to you
for breaches of
the
Australian
Privacy Principles committed by the overseas recipient.
For users
in
Singapore: Please note that the Information we
collect from
you may be
transferred to Israel, the UK, 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.
The below
summary
of this Policy will give you an overview of our practices. Please also take the
time to
read our
full
Policy
for
further detail in each area.
If you do
not
wish us to collect your Information, please do not submit it to us. However,
please bear
in mind that
we
will not
be able
to process your order without receiving your details.
Global-e
may
change and update the terms of this Policy from time to time. If we decide to
change our
Privacy
Policy
materially, we
will post the revised Policy here with an updated effective date and we will
inform you
of such changes
by
any
appropriate
means.
Global-e
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Policy V20 July 2021
Summary
of
Global-e Privacy Policy
The
Information
You Provide Us and We Collect
If you
use the
Service, we will need your Information (such as your name, email address and
physical
address) to
process
the
transaction
and deliver the purchased products. We will need your payment details to process
your
payment. We
will
also
receive any
Information that you provide us when you contact our customer support.
We
automatically
log ‘traffic/session’ information including IP addresses and your user agent. We
also
collect
session
durations
and
additional activity information.
Cookies - We use cookies to make it easier
for you to
log-in and to facilitate Service activities. We use standard analytics
tools.
The
privacy practices of these tools are subject to their own privacy policies and
cookies.
What Do
We Do
with Your Information? - We use your Information
for
performing the
contract with you and for our
related
legitimate interests. We maintain the Service, make it better, and continue
developing
it, and protect
us and the
Service
from
misuse and law violations.
Sharing
Information with Others - We will share Information
that we
collect with
the specific Retailer who owns or
operates
the
website from which you made your purchase. We will provide the Retailer with
your
Information for
Retailer’s
marketing purposes, if you provided your specific consent.
If you do
not
agree with the disclosure of your Information to a third-party retailer, you
will not be
able to use the
Service.
By
agreeing to
this Policy, you agree to the disclosure of your Information to third-party
retailers.
You will also
need to
read and
understand the privacy policies of those retailers.
We will
share
your Information with service providers and other third parties, including those
who
provide us
standard
analytics
tools,
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.
Sharing
Information in case of a Structural Change - a
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.
Anonymous,
Aggregated and Analytical Information - We may take
steps
to de-identify
and make anonymous some 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 may use Anonymous Data in a number of
ways to
improve our
Services
or share
it with third parties. In those case, we will do so without notice to
you.
Your
Choice - You may terminate your use of the Service.
Our
Service does not
respond to Do Not Track (DNT) signals.
Specific
Provisions for California Residents and Consumers Privacy Rights - If you
are a California resident, further terms
apply to
our
processing in relation to your rights as a consumer under the CCPA.
Specific
Provisions for Brazilian Residents - if you are a
Brazilian
resident,
further terms apply to our processing in relation
to your
rights as
a data subject under the Brazilian Data Protection Law - (“LGPD”)͘
Other
Sites and
Services - The Service contains links to third
party
websites and services
that are subject to their own
privacy
policies.
Please read these policies and make sure you understand them.
Children’s
Privacy - 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.
Security
and Data
Retention - 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,
to
provide the Service and for legitimate and lawful purposes.
Global-e
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Accessing
and
Correcting Your Information - At any time you can
request
access to your
Information by contacting us.
You may
also
request that your information be corrected should it be inaccurate.
Your EU
and UK
Data Subject Rights - If we process your
Information when
you are in the EU
or where UK data protection
laws
apply,
further terms apply to our processing in relation to your rights as a data
subject under
EU and UK
data
protection
laws.
Transfer
of Data
Outside your Territory - If we transfer your
Information
outside your
territory, it will be in accordance
with
applicable
law and this Policy.
Dispute
Resolution - Contact us at:
[email protected]
or write us for specific requests or complaints. We
will
make
good-faith
efforts to resolve any existing or potential dispute with you.
Additional
Information for Users of Other Jurisdictions - If
you are a
user in certain
other jurisdictions, we have some
clarifications
and further information for you in relation to the applicable local law.
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,
art-27-rep-global-
1.
How We
Collect
Your Information
We
receive and
collect Information from you in the following ways:
1.1
Purchases. The Service enables you
to
purchase online
merchandise from retailers in certain jurisdictions that do
not
normally
provide order processing and fulfilment services (“Retailers”)͘
If you
choose to
make a purchase, payment or place an order via the Service we will require
sufficient
information,
including Information, from or about you in order to process and complete the
transaction, as
well
as to
provide
subsequent notification and support services.
This
information
will be provided by you to us directly or in certain cases (where you are
pre-registered
with the
Retailer)
specific information will be provided by the Retailer to pre-populate
transaction forms
for ease
of
completion by
you.
1.2
Transaction. We collect information
about
the item(s)
purchased and about you - the purchaser, in particular:
first
name, last
name, email, phone number and postal address and payment information including
the
payment
method
and
payment details (with expiration dates) and any payment voucher details that you
provide
us.
1.3
Delivery. We collect information
about the
preferred
shipping and delivery details relevant to the specific
transaction and
contact details to send notification of the placement shipping and fulfilment of
the
order.
1.4
Enquiries. When you contact us, or
when we
contact you, we
will receive and process any Information that you
provide
us.
1.5
Log
Files. We use log files that we collect
automatically from
your computer or
device when you interact with
the
Service. The
information contained in log files includes internet protocol (IP) (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 your browser sends
to
us.
“Information”
means any information relating to an
identified or identifiable individual including a first and last
name an
email
address, a home or other physical address, or other contact information. It also
includes
indirect
identifiers such
as credit card information or online identifiers. Subject to applicable law,
Information
we
process
may
include types
of information which your jurisdiction may regard as sensitive, such as forms of
financial or
Global-e
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Policy V20 July 2021
payment
information. We will follow applicable law in the processing of such Information
for the
purposes
mentioned
under
this Policy.
2.
Cookies
We use
cookies
and similar tracking technologies to make sure that our Service is continuously
improved
and
meets
your
needs.
Please
view our
Cookies Policy for more information on our use of cookies.
3.
What Do
We Do
with the Information?
Your
Information
will be used in the following ways:
3.1
Performance of
our contract with you. We will use your Information
to
provide you with the
Service under the
Service
Terms and
Conditions, engage with customer service inquiries and administer and provide
customer
support.
3.2
In order
to be
responsive to you and to maintain our business relationship, as a matter of
legitimate
business
interests
(where
applicable). We will use your Information to
improve our
Service, to
prevent or detect fraud or
abuse, to
personalize your user experience and to ensure our content and Services is
presented in
the most
effective
manner
for you and your device, to administer the Services and for internal operations,
in
order to
conduct
troubleshooting, data analysis, testing, research, statistical and survey
analysis, to
contact you
in
connection with
the Service and any transactions that you have initiated or completed or in
relation to
security,
privacy
or
administrative related communications (these are not marketing orientated
communications
so we
do not
rely on
consent for these), to identify and authenticate your access to the parts of the
Service
that you
are
authorized to
access and maintain the safety and security of you and our customers, Services
and
businesses.
In
addition, we
may use the Information set out in Section 1 to comply with any applicable legal
obligations, to
enforce
any
applicable terms of service and to protect or defend the Services, our rights,
the
rights of our
users/customers
or others.
Where
your
Information is needed to fulfil the Service under the Service Terms and
Conditions, a
failure to
provide
that
information will prevent us from completing the transaction and we will refer
you back
to the
specific
Retailer.
4.
Sharing
Your
Information with Others.
4.1
Transferring
Information to Retailers. In connection with using
our
Service to make
purchases we will share the
Information that
we collect from you (but except for payment data such as credit card number
details)
with the
specific
Retailer
who owns or operates the website from 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 policy͘
For
instance, the
Retailer needs to know that you have made a purchase in order to process
delivery of
your
purchase,
to
handle any requests by you to return or replace a product and it needs to know
if you
are already
a
subscriber or
member of its services so that you can take advantage of any loyalty scheme that
it
administers.
If you do
not
agree with the disclosure of your Information to a third-party retailer, you
will not be
able to
use
the
Service.
4.2
Marketing. We do not use your
Information
for marketing
purposes. Your information may be used for direct
marketing
by the
Retailer who owns or operates the website from which you made your purchase. You
will
be
offered
the
ability to provide your specific consent via our Service to receive such direct
marketing
materials
directly
from the
Retailer by either email, telephone, text message or post, relating to consumer
goods
and
services
generally available via our Service, and from which you may have previously
purchased
through us
or
which may
be of
interest to you. We will provide the Retailers with
your
name, email
address, phone number
Global-e
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and
indication of
consent (or the lack of) if you so agree and no additional information will be
shared in
that
regard.
You may
indicate your consent on the Checkout page here.
In order
to
understand how the Retailer uses your Information you should read, understand
and agree
to its
privacy
notice
and policies; we neither control nor are responsible for the policies of these
retailers.
We do not
ask, or
receive, any valuable consideration in exchange of the share of your
Information.
4.3
Using
Affiliates
to Store/Process Data. We will share your
Information with
our subsidiaries
(including, but not
limited
to,
Global-e Australia Pty. Ltd. if purchases are made from Australia) or 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 or their servers
and
systems are located,
as
described
in the
Data Transfer section below. Where you use our Services from Europe to make
purchases,
your
data is
stored on
servers within the European Economic Area (“EEA”). We require that these
parties agree to
process
such
information in compliance with Global-e policies and procedures.
Our
website and
Services are operated via servers situated in the EU. If we transfer Information
outside
the EEA,
UK or
Brazil we
will comply with applicable laws relating to data transfers outside the EEA, UK
and
Brazil as
described
in the
Data Transfer section below. It is important to note, however, that our website
and
Services are
operated
via
servers situated in the EU.
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.
4.4
Using
Third Party
Service Providers. We will share (in so far as such
sharing
is necessary)
your Information with
our
third-party
service providers (such as hosting providers, payment processors, anti-fraud
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 use
commercially reasonable efforts to ensure that such third-party service
providers will
only process
your
Information as
part of providing the Service. Such third-party service providers are located in
jurisdictions
outside
of the
jurisdiction in which you are located and if there is a transfer of Information
outside
of your
jurisdiction,
we will
comply
with the applicable laws relating to data transfers and as further described in
the Data
Transfer
sections
below.
We do not
sell
your information.
4.5
Necessary
Disclosure. We will disclose your Information or
any
information you
submitted via the Services if we
have a
good faith
belief that disclosure of such information is helpful or reasonably necessary
to:
a)
comply
with any
applicable law, regulation, legal process or governmental request;
b)
enforce
the
Terms and Conditions, including investigations of potential violations
thereof;
c)
detect,
prevent,
or otherwise address fraud or security issues; or,
d)
protect
against
harm to the rights, property or safety of Global-e, its users, yourself or the
public.
5.
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
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6.
Anonymous,
Aggregated and Analytical Information.
We may
take steps
to de-identify and make anonymous your Information. In doing so we take steps to
ensure
that this
data
cannot be re-identified. We may use Anonymous Data in a number of ways to
improve our
Services
or share
it with
third parties. In those case, 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 information
which does not enable
identification of an individual user so that
identification is
irreversibly prevented, such as aggregated information about the use of our
Service.
Therefore,
such
information
does not constitute “Information” and use and disclosure of same does not affect
any of
your
rights
under US,
EU, Canadian or other applicable privacy laws.
We use
standard
analytics tools such as of Google Analytics and Hotjar.
Further
information about how Google uses data when you use our service, is located
at
http://www.google.com/policies/privacy/partners/.
We may
use Hotjar
in order to better understand our users’ needs and to optimize our service and
experience͘
Hotjar is
a
technology service that helps us better understand our users’ experience (e͘g͘
how much
time they
spend on
which
pages, which links they choose to click, what users do and don’t like, etc͘) and
this
enables us
to
build and
maintain our service with user feedback. Hotjar uses cookies and other
technologies to
collect data
on
our
users’
behavior and their devices͘ This includes a device’s IP address (processed
during your
session
and
stored in
a
de-identified form), device screen size, device type (unique device
identifiers),
browser
information,
geographic
location (jurisdiction only), and the preferred language used to display our
website.
Hotjar stores
this
information on
our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to
sell
any of the
data
collected on
our behalf.
7.
Your
Choice.
7.1
We
request and
collect minimal personal details that we need for the purposes described in this
Policy.
At any
time, you
may opt
to terminate your use of the Service according to the Service Terms and
Conditions (see
section
8 -
Consumer
Cancellation Rights) if you live in the EEA or UK.
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
Security and
Data
Retention
section in this Policy.
7.2
Web
browsers
offer a “Do Not Track” (“DNT”)
signal͘ DNT
signal is a HTTP header field indicating your
preference for
tracking your activities on the Service or through cross-site user tracking. Our
Service
does not
respond
to DNT
signals.
8.
Specific
Provisions for California Residents.
This
section
applies solely to individuals who reside in the State of California. We adopted
this
section to
comply
with the
California Consumer Privacy ct of 2018 (‘CCP
’) and any terms defined in the CCPA have
the same
meaning
when used
in this section.
8.1
We have
collected
the following categories of Information from consumers within the last twelve
(12)
months:
a)
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.
b)
Commercial
information such as products or services purchased, obtained, or considered, or
other
purchasing or
consuming histories or tendencies.
c)
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 Service͘
Global-e
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d)
Geolocation data,
such as physical location.
e)
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.
8.2
We obtain
the
categories of Information listed above from the following categories of
sources:
a)
Directly
and
indirectly from you and your activity on our Service.
b)
Third
parties
such as our retailers.
8.3
We use
the
Information we collect for one or more of the following business
purposes:
a)
To
fulfill the
reason for which the Information is provided.
b)
To
provide you
with our products and services and to further develop and improve our products
and
services.
c)
To
enforce our
terms and as necessary to protect our rights.
d)
To
respond to
law enforcement requests and as required by applicable law, court order,
or
governmental
regulations.
8.4
We
disclose
Information to third parties for business purposes as described above under the
section
titled
“Sharing Your Information with
Others”͘
8.5
In the
preceding
twelve (12) months, We have disclosed the following categories of Information
for
business
purposes:
a)
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;
b)
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;
In the
preceding
twelve (12) months, We have not sold Information.
9.
Your
California
Rights
If you
are a
California resident, you may be entitled to the following specific rights under
the CCPA
regarding
your
Information:
9.1
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:
o The
categories of Information We collected about
you;
o The
categories of sources for the Information We
collected about you;
o Our
business or commercial purpose for collecting that
Information;
o The
categories of third parties with whom we share that
Information;
Global-e
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o 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;
o The
specific pieces of Information We collected about
you;
o If We
disclosed 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.
9.2
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.
9.3
Nondiscrimination
Right
You have
the
right not to be discriminated against for exercising any of the aforementioned
rights.
9.4
Exercising Your
Rights
9.4.1.
To
exercise the
access, data portability, and deletion rights described above, please submit
your
request
9.4.2.
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.
9.4.3.
A
request for
access can be made by you only twice within a 12-month period.
9.4.4.
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.
9.4.5.
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.
9.4.6.
Any
disclosures
we provide will only cover the 12-month period preceding receipt of your
request.
9.4.7.
The
response we
provide will also explain the reasons we cannot comply with a request, if
applicable.
9.4.8.
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.
9.4.9.
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.
10.
Specific
Provisions for Brazilian Residents.
If you
are a
Brazilian resident, you may be entitled to the following specific rights under
the LGPD
regarding
your
Information.
10.1
Your LGPD
Rights:
Global-e
Privacy
Policy V20 July 2021
10.1.1.
The right
to
anonymize, block or erase data that is unnecessary, excessive or processed in
violation
of
the
LGPD;
10.1.2.
The right to erase data that was processed
based on consent, unless an exception
applies;
10.1.3.
The
right to
confirm and access the Information we collect about you;
10.1.4.
The
right to port data to another
service
provider;
10.1.5.
The
right to
receive information about the public and private entities with whom the
controller
has
shared
data;
10.1.6.
The
right to
receive information about the possibility of not providing consent (when it is
required);
10.1.7.
The right to withdraw consent, when
applicable;
10.1.8.
The
right to
lodge a complaint with the Brazilian Data Protection Authority; and
10.1.9.
The right to object to a processing
activity when the processing activity violates the
LGPD
10.2
Exercising Your
Rights
10.2.1.
To
exercise the
rights described above, please submit your request to us by sending an email
to:
10.2.2.
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.
10.2.3.
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.
10.2.4.
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.
10.2.5.
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.
11.
Other
Sites and
Services.
11.1
The
Service will
contain 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.
12.
Children’s
Privacy.
12.1
The
Service is
not structured to attract or be directed to children under the age of 16 years
or the
Minimum Age
applicable in
each jurisdiction. Accordingly, we do not intend to collect Information from
anyone we
know to be
under 16
years or
the relevant Minimum Age.
12.2
The
Minimum Age
for individuals in Canada, Brazil, Hong Kong and Singapore is 18.
12.3
If we
learn that
we have collected Information from a child under 16 years or an applicable
Minimum Age,
we
will
delete that
information quickly. If you believe that we have any such information, please
contact us
at:
Global-e
Privacy
Policy V20 July 2021
13.
Security
and data
retention.
13.1
The
security of
Information is important to us. We follow generally accepted industry standards,
including the
use of
appropriate administrative, physical and technical safeguards, to protect
Information.
13.2
For
example,
certain sensitive Information (such as data relating to fraud) that we receive
is
processed over
a
Secure
Sockets
Layer channel and is encrypted; and our payment gateway is Payment Card Industry
compliant.
However,
no
method of transmission over the Internet, or method of electronic storage, is
100%
secure.
13.3
Therefore, 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
13.4
We will
retain
your Information as follows:
a) Purchases,
Transaction and Delivery Information (see
section 1.1-1.3 above). We will keep your
purchases,
transaction and delivery information for the duration of the
business/commercial
relationship and
thereafter for the length of the applicable statute of limitations in your
jurisdiction
(in
the UK,
for
example, the statute of limitations is generally 6 years);
b) Enquiries
Information (see section 1.4
above). If you contact us, we will keep your
enquiries
information for
12 months after you contact us;
c) Log files
(see section 1.5 above). We retain log files
information
for 12 months after the date it was
collected.
13.5
For the
avoidance
of doubt, your Information will also be retained by us as necessary to and
relevant to
our
Service
Terms and
Conditions and our legitimate operations, including time necessary to identify,
issue or
resolve
legal
proceedings, enforce our Service Terms and Conditions, to meet our reporting
requirements and as
otherwise
required in accordance with applicable law obligations.
13.6
We will
take
appropriate steps to delete or permanently de-identify Information at the point
this
information
is
no longer
needed
by us for our legitimate business or legal obligations.
14.
Accessing
and
Correcting Your Information.
14.1
At any
time, you
can contact us at:
[email protected]
and request to access the Information that we
keep
about you.
We will ask you to provide us certain credentials to make sure that you are who
you
claim to be
and to
the extent
required under the applicable law, 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.
14.2
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, so that you could:
a)
verify
its
accuracy and the lawfulness of its processing;
b)
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.
14.3
We will
use
judgement and due care to redact from the data which we will make available to
you,
Information
related
to
others.
15.
Your EU
and UK
Data Subject Rights.
15.1
If EU
and/or UK
data protection law applies to the processing of your Information that can
directly or
indirectly
identify
you, by
Global-e, then the following terms apply.
Global-e
Privacy
Policy V20 July 2021
15.2
For the
purpose of
the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”)
and the
UK
General
Data
Protection Regulation and the UK Data Protection ct 2018 (together the “UK
DP
”),
Global-e
is
the data
controller. If you are located in the EEA, you may contact our EU-GDPR
representative
according to
Art.
27 GDPR,
Rickert
Rechtsanwaltsgesellschaft mbH, Colmantstraße
15,
[email protected]. If UK data
protection law
applies to the
processing of your Information, you may contact our UK
15.3
When we
process
your Information, the processing is based on the legal basis set out in Section
3 above
for each
processing
activity.
15.4
Access
the
Information that we keep about you. You have the right to obtain (i)
confirmation as to
whether
Information
concerning you is processed or not and, if processed, to obtain (ii) access to
such data
and a
copy
thereof.
We may
need to ask you to provide us certain credentials to make sure that you are who
you
claim you
are.
15.5
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.
15.6
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.
15.7
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.
15.8
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.
15.9
Object to
processing of your Information. Information You have the right to object, on
grounds
relating to
your
particular
situation, at any time to processing of Information concerning you when such
processing
is based
on
the
legitimate
interest of Global-e. Global-e may, however, invoke compelling legitimate
grounds for
continued
processing which
override the your interests, rights and freedoms or for the establishment,
exercise or
defense
of legal
claims.
15.10
Object to
the
processing of your Information specifically for direct marketing purposes. We do
not
conduct
direct
marketing. When
your Information is processed for direct marketing purposes by Retailers, you
have the
right to
object at
any
time to the processing of the Information for such direct marketing purpose.
Please
contact the
relevant
Retailer
directly to opt out of their marketing activities.
15.11
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.
15.12
If you
are
located in 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
Office͘
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.
Global-e
Privacy
Policy V20 July 2021
If we need
to
delete data following your request, it will take time until we completely delete
residual copies
of
the data
from our
active servers and from our backup systems.
If you
exercise
one (or more) of the above-mentioned rights, in accordance with the provisions
of
applicable law,
you can
request
to be informed that third parties that hold your Information, in accordance with
this
policy,
will
act
accordingly.
15.13
To
protect your
Information and handle complaints relating to your Information, we have
appointed a
Data
Protection
Officer, responsible for the management and safety of your Information. If you
have any
concerns
about the
way we
process your Information, you are welcome to contact our Data Protection Officer
at:
[email protected]. We
will
investigate your
inquiry and make good-faith efforts to respond
promptly.
16.
Transfer
of Data
Outside your Territory.
16.1
We may
transfer
your Information to the UK, United States, Israel and countries within the
European
Economic
Area
(EEA).
16.2
We make
sure that
our data hosting service providers, or any other third party, provide us with
adequate
confidentiality
and security commitments.
16.3
If you
are
resident in a jurisdiction where transfer of your Information to another
jurisdiction
requires
your
consent,
then you
provide us your express and unambiguous consent to such transfer.
16.4
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.
16.5
If the
transfer
of your Information is governed by the GDPR or UK GDPR, we transfer your
Information
outside
the EEA
and UK
(including your name, email address, physical address and telephone number) to
shipping
service
providers, the
retailer of the merchandise your purchased from us, the payment services
providers,
customs/clearance
brokers and logistics providers who fulfil the order you placed with us which
may have
their
place of
business
in the U.S., only where the transfer is necessary for the performance of the
contract
between
you and
us (i.e.
for the purpose of fulfilment of your order and/or where we have implemented the
European
Commission’s
model contracts for the transfer of Information to third jurisdictions (i.e.
standard
contractual
clauses)
unless
the data transfer is to a jurisdiction that has been determined by the European
Commission (for
transfers
from
the EE
) 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.
16.6
At this
time, the
U.S. is not recognized by the European Commission or the UK Information
Commissioner’s
Office
as a
jurisdiction
which offers an adequate level of data protection. Your Information, which is
transferred to the
U.S., can
be
processed by U.S. law enforcement agencies, or any other entities under the
applicable
U.S. law.
If
you are
an EU
citizen or resident, or if UK data protection laws apply to you, please note
that U.S.
laws place
limitations on
remedies in respect of the processing of your Information by the U.S.
authorities,
including
limitations on
the right or ability to bring a legal action to a court of law, or to appear in
a
court.
17.
Dispute
Resolution.
17.1
We do
periodical
assessments of our data processing and privacy practices, to make sure that we
comply
with
this
policy, to
update the policy when we believe that we need to, and to verify that we display
the
policy
properly
and in an
accessible manner. If you have any concerns about the way we process your
Information,
you are
welcome
to
contact our privacy team at: [email protected]. We
will
investigate your query and make
good-faith
efforts to resolve any existing or potential dispute with you. If you remain
unhappy
with the
response
you
received, you
can also refer the matter to the UK Information Commissioner or the applicable
data
protection
authority
in your
jurisdiction.
Global-e
Privacy
Policy V20 July 2021
18.
Additional
information for residents of the following jurisdictions:
18.1
Australia
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. We may disclose your information to overseas receptions as
described in
this Policy,
including
to
recipients located in the countries set out above in the section on ‘Transfer of
Data
Outside
your
Territory’͘ 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/..
18.2
China
Mainland
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. 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 to request access to, and correction or deletion of, your
Information, or
withdrawal of you
consent to the processing of your Information, or cancellation of your account.
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”), 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”).
18.3
Hong
Kong
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).
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]. A
fee may be chargeable by us for complying with
a data
access
request.
18.4
India
Global-e
Privacy
Policy V20 July 2021
Where we
permit
any third parties to collect and use sensitive Information (such as bank account
or
credit card
information), we
shall take reasonable measures to ensure that the third parties do not further
disclose
such
information.
To the
extent
provided by applicable laws and regulations, you may withdraw any consent you
previously
provided
to us
for certain processing activities by contacting us at [email protected]. Where
consent
is
required to
process your Information, if you do not consent to the processing or if you
withdraw
your consent
we may
not be
able to deliver the expected service.
18.5
Indonesia
If you
are under
the age of 21, you undertake that you have the consent of your parent or legal
guardian
to
register
an
account on and use the Service.
You are
responsible for making sure that any personal details which you provide to us
are
accurate and
current.
In order
to
confirm the accuracy of the information, we may also verify the information
provided to
us, at
any
time. You
hereby
represent that you have secured all necessary consent(s) before providing us
with any
other
person’s
Information (for example, for referral promotions), in which case we will always
assume
that you
have
already
obtained
prior consent, and as such, you will be responsible for any claims whatsoever
from any
party
arising
as a
result of the absence of such consent(s).
18.6
Japan
By
clicking
“accept”, you consent to the cross-border transfer of your information to any
jurisdiction where
we
have
databases or
affiliates and, in particular, to Ireland and Germany.
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
18.7
Malaysia
In the
event of
any discrepancy or inconsistency between the English version and Bahasa Melayu
version
of this
Policy,
the
English version shall prevail.
In the
event you
are agreeing to this Policy in order for a minor to access and use the Service,
you
hereby
consent
to the
provision
of Information of the minor to be processed in accordance with this Policy and
you
personally
accept
and agree
to be bound by the terms in this Policy. Further, you hereby agree to take
responsibility for the
actions
of such
minor, and that minor’s compliance with this Policy͘
To
protect your
Information and handle complaints relating to your Information, we have
appointed
the
following
department responsible for managing and protecting your Information. Our data
protection
officer,
18.8
New
Zealand
We take
reasonable steps to ensure that third party recipients of your Information
located
outside New
Zealand
handle
your
Information in a manner that is consistent with New Zealand privacy laws.
However,
you
acknowledge that
we do not control, or accept liability for, the acts and omissions of these
third party
recipients.
If you
are under
the age of 16, you undertake that you have the consent of your parent or legal
guardian
to
register
an
account on and use the Service.
If you
are
dissatisfied with our response to your request for access to, or correction of,
your
Information or
your
privacy
complaint
in respect of your Information, you may contact the Office of the New Zealand
Privacy
Global-e
Privacy
Policy V20 July 2021
While we
take
reasonable steps to ensure that third party recipients of your Information
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.
18.9
Philippines
We will
not
implement any material changes to the way we process your Information, as
described in
the
Policy,
unless we
have
notified you and have obtained your consent to such material changes.
By
consenting to
this Policy, you consent to us:
•
collecting and processing your Information as described in
this
Policy and for the
purposes stated herein;
•
sharing your Information with third parties, companies
within our
group, and a third
party that acquires
substantially
all or substantially all of us or our business, as described in this Policy and
for the
purposes
stated
herein;
and
•
transferring or storing your Information in destinations
outside
the Philippines when
the processing shall
need to
occur
outside the Philippines, such as in servers located in Ireland and
Germany.
18.10
Singapore
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.
18.11
South
Korea
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.
Global-e
Privacy
Policy V20 July 2021
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
Records
of
contracts or cancellation of orders shall be retained for
Protection
Act
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
Records
of
electronic document distribution via certified electronic
Documents
and
Transactions
address
shall be
retained for a period of ten (10) years.
Protection
of
Sign-in
records
shall be retained for a period of three (3) months.
Communications
Secrets Act
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:
Personal
Information Protection Officer
Name:
Oded
Griffel
Position:
DPO
18.12
Taiwan
We do not
knowingly collect or solicit Information from anyone under the age of 7 or
knowingly
allow such
persons
to
register on the Service. If you are under 7, please do not attempt to use or
register
for our Service
or
send any
Information about yourself to us. No one under the age of 7 may provide any
Information
to us
while
using the
Service. In the case of users located in Taiwan, persons under the age of 20 are
required to
obtain
parental/guardian
consent prior to using the Service.
18.13
Thailand
By
clicking
“accept”, you acknowledge that you have read, understood, and agree to this
Policy͘ If
you do not
agree
with this
Policy, you must not use the Service.
You may
request
us to discontinue, to restrict the use or provision of, and/or to request for
data
portability of
any and
all of
your Information which is stored by us, to the extent provided by the Act on the
applicable data
privacy
laws and
regulations in Thailand, including the Thai Personal Data Protection Act. When
you wish
to make
We will
give you
notice by email of any changes to this Policy, and give you an opportunity to
reject
such
changes,
failing
which the
changes will become effective as stated in the notice.
18.14
Vietnam
By
accepting this
Policy, you expressly agree and authorize us to collect, use, store, and process
your
Information,
including,
lawfully disclosing and transferring it to third parties, as described in this
Policy.
Global-e
Privacy
Policy V20 July 2021
19.
Changes to
this
Privacy Policy.
19.1
From time
to time,
we will update this policy. If the updates have minor if any consequences, they
will
take effect
7 days
after we
post a notice on the Service’s website͘ Substantial changes will be effective 30
days
after we
initially
posted
the notice.
19.2
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.
20.
Contact
Us.
Please
contact us
at:
[email protected]
for further information. You can contact our DPO
at:
Global-e
Privacy
Policy V20 July 2021
Cookies
Policy
Global-e
(“Global-e” or
“we”) wants to ensure
that your use of our
Service is
smooth, reliable and as useful to you as
possible.
To help
us do this, we use cookies and similar technologies, such as tags/beacons and
javascripts (“cookies”),
to
make our
Service
relevant to your interests and needs.
1.
What are
cookies?
Cookies
are small
text files that are automatically placed on your computer or mobile device when
you use
our
Service.
They are
stored by your internet browser. Cookies contain basic information about your
internet
use.
Your
browser
sends these cookies back to our Service every time you revisit it, so it can
recognize
your
computer
or mobile
device
and personalize and improve your browsing experience.
2.
What re
‘Session’
and ‘Persistent’ Cookies?
“Session Cookies” are removed from
your computer once you
close your browser session͘
“Persistent Cookies” last for longer
periods on your
computer - after you close your browser session.
A user
can delete
previously set persistent cookies manually or configure the browser settings to
delete
cookies,
as
further
described below.
3.
What re
‘First-party’ and ‘Third-party’ Cookies?
First-party
cookies are set directly by the website that the user is visiting. For the
purpose of
this policy,
these
are
cookies that
are set directly by our Service.
Third-party
cookies are set by a domain other than the one visited by the user. For the
purpose of
this
policy,
these are
cookies
that are set by Service on the checkout page.
4.
What re
‘Similar
Technologies’?
Functions
usually
performed by a cookie can be achieved by other means. This could include, for
example,
using
certain
characteristics to identify devices so that visits to a website can be
analyzed.
ny
technology
that stores or accesses information on a user’s device is relevant for this
purpose, and
therefore
it
includes, for
example, HTML5 local storage, Local Shared Objects and fingerprinting
techniques.
Additionally,
technologies like scripts, tracking pixels and plugins, wherever these are used
- are
also
considered
as
similar
technologies. For example, the retailers may, conduct electronic marketing and
incorporate a
tracking
pixel in
email
messages. The pixels record information including the time, location and
operating
system of the
device
used to
read the email.
5.
What type
of
cookies do we use?
We use
both
Session Cookies and Persistent Cookies as part of your experience on our Service
so that
we can
facilitate the
use of the data’s features and tools, keep track of your preferences as well as
improve
our
service
by
creating
better designs for you. Some cookies are strictly essential for the operation of
our
Service while
other
cookies
help to
improve. The same rule goes for all the tracking technologies that we use. We
have
created a
detailed
tracking
technologies table page, which is attached as an Appendix A to this policy and
is
available here.
The table
will
provide you with a clear and comprehensive image of the tracking technologies
that we
use.
When a
tracking
technology contains Information, as indicated in Appendix A, then our Privacy
Policy
applies as
well.
The
cookies we
use fall into 3 categories. These categories are described below:
Global-e
Privacy
Policy V20 July 2021
Essential
and
functional cookies
Essential
cookies
are necessary to help you access and
move
around our
Service and use all its features. We also
use
functional
cookies, for example to remember your
language
preferences to save you the trouble of having to
change
every
time you enter our Service. Without these
cookies,
our
Service would not work properly, and you
would
not be
able to use certain important features.
Analytics
cookies
We use
cookies
to help us understand how visitors arrived
at our
Service,
how and how long they use it and how we
can
improve
their experience. This type of so-called
“analytics”
cookies can provide us with anonymous
information to
help us understand which parts of our
Service
interest
our visitors and if they experience any
errors.
We use
these cookies to test different designs and
features
for our
sites and we also use them to help us
monitor
how our
visitors reach our sites.
To place
these
cookies, we use Google Analytics. We have
set our
Google
Analytics to protect your privacy to the
maximum
extent.
For example, we have concluded a data
processing
agreement with Google to protect your data.
We have
also
made sure that the last octet of your IP-
address
is
invisible and have turned off the setting which
allows
sharing
data with Google. We are also not using any
other
Google
Analytics related cookie services which are
offered
by
Google
Advertising,
marketing and social
We only
place
advertising, marketing and social media
media
cookies
cookies
if you
have given us your permission to do this.
Advertisement
and marketing cookies collect information
about
your
browsing habits in order to make our content
and
advertising
as relevant to you and your interests as
possible. These
cookies are also used to help us measure
the
effectiveness of our advertising campaigns by tracking
the
number of
clicks. The cookies are usually placed by
third
party
advertising networks. They remember the
websites
you
visit and use this information to give you
access
to
interesting and exciting content on our Service
and to
show you
more personalized adverts when you
visit
other
websites. These cookies also help improve your
browsing
experience, for example by helping to prevent
the same
advertisement from continuously reappearing
to
you.
Additionally,
social media platforms such as Facebook and
Twitter
can use
cookies to see if you are logged in and
allow
you to
“like” content or forward it to your friends͘
Depending on
your settings, these third parties may use
your
information
for their own purposes, such as
advertising. If
you would like to know more how these
social
media
platforms use data, please refer to the
privacy
notices
of these platforms
6.
Obtaining
your
consent for using tracking technologies
Global-e
Privacy
Policy V20 July 2021
We need
your
consent to use tracking technologies that are not essential and functional, as
indicated
above.
If
you do not
agree
to accept our cookies or other tracking technologies that are not essential and
functional for
the
operation of
our website, we will make commercially reasonable efforts to provide you with
the same
level
of
services
without using such cookies or other tracking technologies.
7.
Withdrawing your
consent
You can
withdraw
your consent to advertising, marketing and social media cookies by
contacting
8.
Managing
your
cookie settings and deleting cookies
As
explained
above, we only place advertising and targeting cookies (including tracking
cookies) if
you have
given
us your
consent
for doing this. If you have given us your consent but would like the cookies
that we
have placed
to be
removed,
you can do this by deleting them via your browser͘ Search for “cookies” under
your web
browser’s
“Help
menu” or
“Setting” section͘
Here are
some
links to some commonly used web browsers: (a) Google Chrome; (b) Microsoft Edge;
(c)
Mozilla
Firefox;
(d)
Microsoft Internet Explorer; (e) Opera; (f) Apple Safari.
In
addition, you
can turn off certain third party targeting or advertising cookies by visiting
the
following
links:
To find
out more
about cookies, including how to see what cookies have been set, you can visit
the
following
Please
note that,
if you choose to delete Global-e cookies, your access to some functionality and
areas of
our
Service
may be
degraded or restricted.
Some web
browsers
offer a “Do Not Track” (“DNT”) signal͘ DNT signal is an HTTP header field
indicating
your
preference for
tracking your activities on our services or through cross-site user tracking.
This
Service does
not
respond
to DNT
signals.
9.
Questions,
comments or in need of help?
If you
have any
questions or if we can help you with something, we would be happy to assist if
you
contact us at:
10.
Changes
to this
policy
We update
this
policy, where needed. Every time we change this policy, we either send you an
email
about it or
post a
notice on
our Service. We will post a notice on our Service if our policy update includes
substantial
changes
and
obtain your
consent once again, where required under applicable laws.
This
policy was
last updated in July 2020.
Global-e
Privacy
Policy V20 July 2021
Appendix
A:
Tracking Technologies Table
Essential
and
functional cookies
These
cookies are
strictly essential for enabling your movement around our Service and providing
access to
features
such
as your
profile
and purchases, member-only services, and other secure areas of our Service. This
category of
cookies
cannot be
disabled.
Global-e
Privacy
Policy V20 July 2021
Name
Purpose &
Expiration Date
First/Third Party
Cookie
Main
cookie used
by both the Global-e
GlobalE_Data
First +
Third
Party
extensions and
client libraries, this cookie
holds
the
browsing information of the
customer.
Exp. 72
Hours
GlobalE_Tags_Data
Cookie
for
analytics and statistics of the
First
client
behavior
on the website.
Exp. End
of
Session
GlobalE_CT_Data
This
cookie
holds a unique client identifier
First +
Third
Party
for a
customer
(per browser), which helps
Global-e
to
provide information about the
client
behavior
on a Global-e enabled
website.
Exp. 72
Hours
GlobalE_Welcome_Data
This
cookie is
placed in order to determine
First
whether
the
customer should be
presented with
the Global-e welcome
popup.
Exp. 72
Hours
GE_CART_TOKEN
This
cookie
holds the card details, in case
First
the need
to
recreate the cart.
Exp. 72
Hours
GlobalE_GECT_Data
This
cookie is
used to distinguish unique
Third
Party
users by
assigning a randomly generated
number
as a
client identifier.
Exp. 2
Years
GloablEIsOperated
This
cookie
determine whether the
First
territory is
operated.
Exp. 72
Hours
_cfduid
CloudFlare
cookie, used to speed up load
Third
Party
time.
used to
override any security
restrictions
based on the IP address the
visitor
is
coming from. It does not contain
any user
identification information.
Exp. 8
Month
forterToken
This
cookie
stores the Forter-generated
Third
Party
device
identifier. It identifies the browser
between
browsing
sessions
Exp.5
years
Global-e
Privacy
Policy V20 July 2021
Name
Purpose &
Expiration Date
First/Third Party
Cookie
Ftr_ncd
a flag
used to
make sure data is not sent
Third
Party
more
than once
per predefined timeframe
Exp. 5
Years
Analytics
Cookies
Analytics
cookies
collect information about how visitors use our Service. Our service providers
can
transfer
relevant
information to
third parties where required by law or where such third parties process such
information
on their
behalf.
Name
Purpose
&
Expiration Date and Opt-Out
First/Third
Party Cookie
_ga
This
cookie is
used to distinguish unique
Third
Party
users by
assigning a randomly generated
number
as a
client identifier.
Exp. 2
years
_gcl_au
Used by
Google
AdSense for
Third
Party
experimenting
with advertisement
efficiency
across websites using their
services.
Exp. 10
Days
_gid
This
cookie name
is associated with
Third
Party
Google
Universal
Analytics. store and
update a
unique
value for each page
visited.
Exp. 24
Hours
cid
This
cookie is
used to improve advertising
Third
Party
for
website
visitors. It can redirect more
relevant
advertisements to the visitor, and
helps
improve
reports on campaign
performance.
Exp. 1
Year
_fbp
Used by
Facebook
to deliver a series of
Third
Party
advertisement
products such as real time
bidding
from
third party advertisers.
Exp. 3
Months
Special
provisions regarding Hotjar Cookies -
Global-e
uses the
services of Hotjar. To function properly, Hotjar stores first-party cookies on
your
browser. Cookies
are
either
set by the
Hotjar script, or by visiting Hotjar’s
website. When Global-e uses the Hotjar script on
the website, Hotjar
cookies
are
responsible for displaying the correct content to you without personally
identifying
anyone.
If you
are
looking to not be tracked by Hotjar or any site that uses Hotjar, you may do so
by
following the steps
on
Do Not
Track
page.
Global-e
Privacy
Policy V20 July 2021
Cookies
set by the
Hotjar script (not all are used by Global-e)
Name
Description
Duration
Hotjar
cookie
that is set once a visitor interacts
with an
External
Link Survey invitation modal. It is
_hjClosedSurveyInvites
365
days
used to
ensure
that the same invite does not
reappear
if it
has already been shown.
Hotjar
cookie
that is set once a visitor completes
a survey
using
the On-site Survey widget. It is
_hjDonePolls
365
days
used to
ensure
that the same survey does not
reappear
if it
has already been filled in.
Hotjar
cookie
that is set once a visitor minimizes
an On-
site
Survey widget. It is used to ensure
_hjMinimizedPolls
365
days
that the
widget
stays minimized when the visitor
navigates
through your site.
Hotjar
cookie
that is set when a visitor minimizes
or
completes
Incoming Feedback. This is done so
_hjShownFeedbackMessage
that the
Incoming Feedback will load as
365
days
minimized
immediately if the visitor navigates to
another
page
where it is set to show.
Hotjar
cookie
that is set when the customer first
lands on
a page
with the Hotjar script. It is used to
persist
the
Hotjar User ID, unique to that site on
_hjid
365
days
the
browser.
This ensures that behavior in
subsequent
visits to the same site will be
attributed to
the same user ID.
This
should be
found in Session storage (as
opposed
to
cookies). This gets updated when a
_hjRecordingLastActivity
visitor
recording starts and when data is sent
Session
through
the
WebSocket (the visitor performs an
action
that
Hotjar records).
When the
Hotjar
script executes we try to
determine the
most generic cookie path we
should
use,
instead of the page hostname. This is
done so
that
cookies can be shared across
_hjTLDTest
Session
subdomains
(where applicable). To determine
this, we
try to
store the _hjTLDTest cookie for
different URL
substring alternatives until it fails.
After
this
check, the cookie is removed.
User
Attributes
sent through the Hotjar Identify
API are
cached
for the duration of the session in
_hjUserAttributesHash
Session
order to
know
when an attribute has changed and
needs to
be
updated.
This
cookie
stores User Attributes which are sent
_hjCachedUserAttributes
Session
through
the
Hotjar Identify API, whenever the
user is
not in
the sample. These attributes will
Global-e
Privacy
Policy V20 July 2021
only be
saved if
the user interacts with a Hotjar
Feedback
tool.
This
cookie is
used to check if the Hotjar Tracking
Script
can use
local storage. If it can, a value of 1
is set
in this
cookie. The data stored
_hjLocalStorageTest
Under
100ms
in_hjLocalStorageTest has no expiration time, but
it is
deleted
almost immediately after it is
created.
This
cookie is
set to let Hotjar know whether that
_hjIncludedInPageviewSample
visitor
is
included in the data sampling defined by
30
minutes
your
site’s
pageview limit͘
This
cookie is
set to let Hotjar know whether that
_hjIncludedInSessionSample
visitor
is
included in the data sampling defined by
30
minutes
your
site’s
daily session limit͘
This
cookie is
used to detect the first pageview
_hjAbsoluteSessionInProgress
session
of a
user. This is a True/False flag set by
30
Minutes
the
cookie.
Visitors
with
Disabled Cookies
Hotjar
does not
track or record visitors who have cookies disabled͘ In fact, the Hotjar script
doesn’t
properly load
its
different
components if it detects that cookies are disabled.
Learn more
Cookies
set can
be categorized into essential and non-essential cookies.
Essential
Cookies
Essential
cookies
serve to operate the Hotjar Website and its features in a workable
fashion.
Name
Description
Duration
This
cookie is
set for logged in users of Hotjar who
have
Admin Team
Member permissions. It is used
_hjptid
Session
during
pricing
experiments to show the Admin
consistent
pricing across the site.
This
cookie is
set when a page that supports
multiple
languages on hotjar.com is visited. This
hjSiteLang
365
days
allows
us to
always load the content in the
preferred
language when available.
Hotjar
Opt-Out
setting. More information can be
_hjOptOut
4
months
X-Access-Key
This
cookie
keeps your website session alive.
Session
Non-essential
Cookies
Global-e
Privacy
Policy V20 July 2021
With your
consent,
non-essential cookies are set when you visit the Hotjar’s
website. They serve to optimize the user
experience,
provide us with insights about how users use the Hotjar’s
website, or are used for marketing purposes.
To the
extent
Information is processed via these cookies, the respective legal basis is your
consent
in accordance
with
Article
6(1)(a)
GDPR. You may withdraw your consent at any time with future effect by adjusting
your
cookie
settings.
Name
Description
Duration
New
Relic cookie
which is used to monitor session
JSESSIONID
Session
New
Relic cookie
which is only created in
NREUM
browsers
that do
not support the Navigation
Session
New
Relic
cookie, created only when a token is
NRAGENT
handed
out to an
end-user by the New Relic
Session
This
cookie is
set by Optimizely to run tests on
Decided
by
optimizely*
Optimizley
This
cookie is
set by Mixpanel to run track usage
mp_*
Decided
by
Mixpanel
on
hotjar.com.
This
cookie is
created by Hotjar to create a unique
segment_id
ID for
users and
is used to consistently trigger
1
year
experiments for
example.
This
cookie is
set by Microsoft as a unique user ID.
MUID
(Microsoft
User ID)
The
cookie
enables user tracking by synchronizing
1
year
the ID
across
many Microsoft domains.
This
cookie is
set by LinkedIn Ads for ID syncing.
UserMatchHistory
30
days
This
cookie is
set by LinkedIn to keep track of the
bcookie
2
years
A secure
browser
cookie set by LinkedIn.
Read
bscookie
2
years
more.
This
cookie is
set by LinkedIn used for routing.
lidc
1
day
Read
more.
Used by
LinkedIn
for tracking the use of
lissc
1
year
embedded
services. Read more.
This
cookie is
set by LinkedIn to set default
lang
Session
locale/language.
Read more.
lang
This
cookie is
set by ads.likedin.com. Read more.
Decided
by
Linkedin
This
cookie is
set by Google used to check if the
test_cookie
1
day
user’s
browser
supports cookies͘
Global-e
Privacy
Policy V20 July 2021
Used by
Facebook
to deliver a series of
_fbp
advertisement
products such as real-time bidding
3
months
from
third-party
advertisers.
This
cookie is
set by Google Analytics used to
_gid
1
day
distinguish
users. Read more.
This
cookie is
set by Google Analytics used to
_ga
2
years
distinguish
users. Read more.
This
cookie is
set by Google Analytics used to
90 days
(typically,
determine a
user’s inclusion in an experiment and
_gaexp
depends
on
the
expiry of
experiments a user has been
experiment
length)
included
in.
Read more.
This
cookie is
set by Google Analytics to take
information in
advert clicks and store it in a 1st
_gcl_au
3
months
party
cookie so
that conversions can be attributed
outside
of the
landing page. Read more.
This
cookie is
set by Segment as a randomly
ajs_anonymous_id
365
days
generated ID for
anonymous visitors.
This
cookie is
set by Segment used to group visits
ajs_group_id
365
days
by
different
website users if logged in.
This
cookie is
set by Segment used for usage
ajs_user_id
365
days
analytics if
logged in.
This
cookie is
set by Segment to identify call is
ajs_user_traits
365
days
made on
hotjar.com.
Global-e
Privacy
Policy V20 July 2021