Privacy Policy

This privacy policy has been adopted by the Globus Company regarding the collection and distribution of information (the “Privacy Policy”).

The Privacy Policy sets forth the types of personal information and other information that the Globus Company collects about users of the Services (as defined hereafter), how the Globus Company collects the information and what use it makes of the information, including storing the information, processing it, transferring it to third parties, etc.

This privacy policy statement refers to the male gender for convenience only, but it is intended for both women and men.

The Globus Company collects personal information and other information (as defined hereafter) through:

• Websites operated by the Globus Company where the privacy policy is displayed
• Through the applications that the Company makes available for use on computers or mobile devices (hereinafter: the “Applications”);
• Through social media pages owned and controlled by the Globus Company (hereinafter collectively: “Social Media Pages”);
• The application websites and social media pages will be referred to collectively as the “Online Services” and together with the offline channels – the “Services”
• The Globus Company serves as the Data Controller of the personal information about the data subjects or those who contact one of the communication means set forth above.

The information that is or will be provided to the Globus Company, whether orally or in writing, depends on the consent and will of the data subjects, and does not arise from a legal obligation. However, if the information is not provided to the Globus Company or if the Globus Company is not allowed to collect such information, the Globus Company will not be able to provide the services to those interested.

 

Definitions

Personal information – Data that identifies individuals or relates to a specific person. Globus may collect personal data such as:

Contact information (name, email address, mailing address, phone number, fax number, passport number, ID number)

Payment method – Credit card: digits and expiration date according to PCI DSS rules, billing address and bank account number

Demographic data (age, gender, residential address, citizenship, and preferred language)

Information about family members and dependents, such as names and ages of children or spouse

Information based on geographic or other location

Images, video and audio collected via security cameras located in public areas at the Globus Company, such as in the hallways and lobbies of the Globus Company (CCTV systems and electronic card keys).

 

Other information – Data that does not allow for personal and specific identification and does not refer to a specific person.

The Globus Company collects other information such as browser and mobile device data, including IP address and data collected by “cookies” and other technologies, aggregate data regarding the presence of the data subjects at the Globus Company, as well as responses to promotional offers and surveys.

 

Method

Collection of personal and other information

The Globus Company may collect personal information as defined hereafter.

The Globus Company may collect other information, as defined hereafter.

In certain cases, the Globus Company combines personal information with other information. In such a case, the Globus Company will treat the combined information as personal information as long as the information is combined.

If information is provided to the Globus Company and/or to the Globus Company’s service providers that includes personal information about third parties who contact the information collection tools (for example, in the event that you are placing an order for another person), they will declare that the third party’s consent to provide the information as aforesaid has been received and the applicants are authorized to do so and that the third party allows the Globus Company to use the information in accordance with the provisions of this Privacy Policy.

Means of collecting personal or other information

Online services : When placing an order, purchasing goods or services, contacting the company and its representatives in any way, advertising on social media pages, joining a mailing list or participating in surveys, feedback, contests or marketing offers, as well as when applying for a job at the Globus Company.

Other sources : Personal information is also received from third parties, including information from agents, credit card companies, survey companies, and the Globus Company’s service providers.

 Automatic information : When you use the websites and/or use the applications as defined above, the Globus Company receives and stores information in connection with the activity on the said websites and applications, and additional automatic information is collected from the browser and mobile device. For example, as customary on other websites, we receive certain information when the browser through which you access the website, including information regarding IP address, browser type, operating system, mobile network data, pages viewed, and browsing times. This information is used by us in the engagement and in the provision of services to customers.

Customer service centers : When placing an order by phone, contact is made with the Globus Company via email, fax, online chat or through customer service. This communication may be recorded for the purpose of ensuring quality of the service and training.

Aggregated information: Information that does not personally identify the surfer or any other user.

Use of personal and other information:

The Globus Company uses personal information and other information for one or more of the following purposes:

Placing orders and purchasing services and products: the Globus Company processes information relating to transactions you have entered into with the Globus Company, including through the websites (hereinafter: “Transaction Data”). Transaction data will be processed for the purpose of completing the order, providing products and services, adapting services provided by the Globus Company to your preferences, receiving feedback about the service at the Globus Company, and maintaining records of such transactions.

Responses to inquiries: the Globus Company processes information in connection with inquiries from users of the services (hereinafter: “Data in Connection with the Inquiry”). Data related to the inquiry includes the content of the inquiry and the metadata related to the inquiry (such as groups, meetings, and events). Data in connection with the inquiry will be processed for the purpose of communicating with the data subjects and maintaining records.

Business purposes: the Globus Company processes the information for business purposes, including developing new products, improving the website, improving our services, identifying usage trends and visitation patterns of the data subjects, determining the effectiveness of sales promotions, evaluating the performance of third parties (such as agents), the expected return of the Globus Company, and meeting obligations.

Administrative and other communications: Sending you information regarding the website, changes that have occurred in the terms of use, changes that have occurred in the privacy policy or other administrative information (for example – information about orders that have been placed, such as order confirmation emails, etc.).

Marketing and sales promotion: Sending marketing and sales promotion notices regarding the Globus Company and products and services that we think will interest the data subject;

Our legal obligations: To comply with the provisions of the law, including statutes, regulations, directives and legal proceedings.

The Globus Company may use personal information and other information, in whole or in part, to perform certain statistical calculations, some of which will be displayed in applications, websites and/or other services; provided that these do not include identifying information.

The legal basis for processing personal information is one or more:

Consent.

Provision of the services.

Compliance with all laws, including statutes, regulations, orders, directives, court judgments, and more.

A legitimate and business interest of the Globus Company.

Disclosure and transfer of personal and other information:

The Globus Company may disclose and transfer personal information and other information as set forth hereafter:

• To a representative or agent who provided us with personal information about the data subjects (for example, an agent, escort, employer or spouse).
• To service providers to the Globus Company. Examples of service providers are IT service providers, legal advisors, accountants, payment service providers, and more.
• To the Globus Company’s business partners in the field of marketing and advertising, in order to publish relevant advertisements to users of the website and encourage users to revisit the website. These partners will not use personal information for any other purpose except for the purpose of direct marketing as stated, and in any case, you will always have the right to object to the aforementioned use.
• The Globus Company may disclose personal information and other information if it is found necessary:

(a) To comply with the provisions of the law;

(b) To comply with court orders in the framework of legal proceedings;

(c) For the purpose of responding to requests and inquiries from public or government authorities;

(d) To enforce the Terms of Use;

(e) To protect the business of the Globus Company;

(f) To protect the rights, privacy, safety, or property of the Globus Company, the data subjects, users of the services, and others.

(g) In order to enable the Globus Company to act to obtain remedies to which it is entitled under law and/or agreement, as well as to mitigate its damages.

Transferring information beyond the borders

As a general rule, information processing is carried out within the borders of the State of Israel. Information processing that is carried out by third parties or cloud services can and does take place on servers around the world, such as Azure servers or Microsoft 365 servers, etc.

However, some of the information may be held in a cloud outside the borders of the State of Israel or the European Union. The operator of these services has committed to complying with the provisions of the GDPR. In the specific case mentioned above, the Globus Company ensures that appropriate measures are taken to secure personal information with an adequate level of protection.

The options for the data subject to access, change or limit the use of the personal information provided:

If they are domiciled in the Union, the following provisions will apply to them:

The right to receive information about the processing of personal information: We strive to provide concise, transparent, clear, simple and easy-to-access information about the conditions of the processing of personal information.

The right to access, correct or delete personal information: We allow data subjects to receive from us details regarding the personal information processed, details about the conditions of information processing, to receive an electronic copy of the information, as well as the right to correct personal data.

The right to request the deletion of personal information, subject to the provisions of any law and subject to the following conditions:

The personal information is no longer necessary for the purpose for which it was collected, stored and processed;

A request to revoke the consent on the basis of which the personal information was processed and there is no longer a basis justifying the processing of the personal information as mentioned;

The information providers believe and can substantiate the claim that personal information has been processed illegally;

The personal information will be deleted in accordance with Globus Company’s obligation in accordance with the provisions of the law;

The right to restrict the processing of personal information: This right will apply to you in a number of cases, in particular in the following cases:

• In the event of a dispute regarding the accuracy of personal information;
• To the extent that you believe and can substantiate the claim that the processing of personal information is unlawful but oppose the deletion of personal information and instead demand the restriction of the processing;
• When the Company no longer needs the personal information but needs the personal information to exercise, establish or protect your rights;
• When the decision regarding Globus Company’s legitimate interest outweighs your interests as the data subject.

The right to transfer information:

If the basis for processing personal information is consent or agreement, data subjects are entitled to receive the personal information they provided to the Globus Company in an acceptable format and to transfer this information to another data controller.

The right to withdraw consent:

When the basis for processing personal information is consent, applicants may withdraw their consent at any time by the means provided for that purpose (as set forth in this Privacy Policy hereafter). We note that such withdrawal of consent applies only to the future and does not apply to information processed prior to the withdrawal of consent. For the avoidance of doubt, it is clarified that the withdrawal of consent will not call into question the legality of the processing of personal information that was carried out prior to the withdrawal of consent as mentioned.

The right to file a complaint with the relevant privacy protection authority: 

If, despite the Globus Company’s efforts to maintain the confidentiality and privacy of personal information, data subjects feel that their rights have been violated, they have the right to file a complaint with the relevant privacy protection authority. A list of authorities is available on the European Commission website.

If the data subject is domiciled outside the EU (including Israel), they have the right to review and correct the information stored in the Globus Company’s databases in accordance with the provisions of Israeli law, including the provisions of the Privacy Protection Law 5741 – 1981.

Information security
The Globus Company takes reasonable organizational and technical measures to protect personal information from unauthorized access, disclosure, deletion or alteration of information, accidental loss of information, misuse or damage. The Globus Company conducts review and monitoring activities at an appropriate frequency of the aforementioned protection and security measures.

When required to disclose or transfer personal information to third parties and authorized accesses, the Globus Company will ensure that those third parties commit to an adequate and appropriate level of data protection. The Globus Company requires contractual commitments from third parties to ensure that personal information will be processed only for the purposes to which you have consented and in accordance with the required level of confidentiality and security.

If there is reason to believe that communication with the Globus Company is not secure, contact should be made immediately as set forth in the “Contact Us” section hereafter.

Information retention period

Subject to the provisions of any law, the Globus Company will retain personal information for the period required to realize and implement the following:

• The purposes for which the personal information was disclosed;
• The Globus Company’s business interest, including data retention;
• A requirement to retain information that may be relevant to regulatory investigations or legal proceedings;
• Compliance with the provisions of any law, regulation, legal process, including court orders and/or disclosure required by governmental and other authorities;
• To fulfill a legitimate interest of the Globus Company and third parties, including defense against legal proceedings and more.

Sensitive information

Unless specifically requested, the Globus Company Company requests not to provide or disclose any sensitive personal information during the use of the services or in any other way (for example, social security numbers, data concerning race or ethnicity, political opinions, religion, ideology or other beliefs, health, biometric data or genetic data, criminal history, administrative or criminal proceedings and sanctions imposed in connection with the aforesaid).

 

Use of services by minors

The Globus Company does not knowingly collect personal data from anyone under the age of 18.

Updates

The Company may change and update this Privacy Policy from time to time at its sole discretion without notice. The responsibility for being aware of the changes, if any, that will be made to the privacy policy lies solely with the users.

Cookies

Like many other websites, and in order to improve the user experience on the website and web pages, the Globus Company Company uses “cookies”. “Cookies”, by themselves, do not provide the Globus Company with personally identifiable information unless the user chooses to provide such information (for example, by registering for one of the services). However, if you choose to provide personally identifiable information on the website, this information will be linked to the data stored in a “cookie”.

A “cookie” is a small text file containing small amounts of information that a website places on your computer or mobile device. “Cookies” are designed to help the computer or device remember something the user did on a website, for example remembering that the user logged in or which and how many buttons were pressed.

The Globus Company uses “cookies” as a tool to understand the use of the website and to improve the content and offers on the website. This use is made to personalize the user experience on Globus Company’s web pages, to offer relevant products, programs and services, as well as targeted advertising.

Disabling cookies – The browser used by the data subject may allow control over “cookies”; some browsers may allow settings that prevent the collection of “cookies”. If you do not consent to the use of “cookies”, you must disable the use of “cookies” according to the browser settings instructions as set forth here.  Please note that after disabling cookies, certain features on the website may not function properly.

There are third parties that operate certain types of “cookies” that provide tools for automatically disabling their “cookies”. You can see a list of “cookies” operated by third parties and a link to automatically disable them. In other cases, you can disable cookies using a third-party management tool like here.

The company uses various types of “cookies”:

• “Session cookies” – These “cookies” are stored temporarily during browsing activity and are deleted from the mobile device after the browser is closed. We use temporary cookies to support the functioning of the website and to understand your use of the website, for example the pages you viewed, which links you used and how long you spent on each page.
• Essential cookies – “cookies” that are necessary for the operation of the website
• Functional cookies – We use functional “cookies” to save website settings – settings such as the preferred currency when checking the prices of services on the website. The Globus Company also uses functional “cookies” to store data so that this data can be easily found the next time you visit the website. Certain functional cookies are essential for viewing maps or videos on the website.  The company uses Flash “cookies” for certain animated content.
• Persistent cookies – These “cookies” are not deleted when the browser is closed but are stored on the device for a fixed period or until they are deleted. Each time you visit the website, the server that set the cookie will recognize the persistent cookie that was saved on your personal device. The Company uses persistent “cookies” to store your preferences so that they are available to data subjects on their next visit. For example, if there has already been a login, these “cookies” will skip the login step for the user on their next visit to the website.
• Targeting and advertising cookies – The use of these “cookies” is for the purpose of collecting information in order to help the Globus Company improve its products and services, as well as to display targeted ads that the Globus Company believes will be relevant to the user. The Globus Company uses targeting “cookies” on its websites for various marketing initiatives and campaigns. The Globus Company also uses “Analytics Cookies” (see hereafter) and other technologies to promote advertising.
• Analytics cookies – These “cookies” collect information about the use of the website and allow the Globus Company to improve the website’s operations. – These “cookies” provide the Globus Company with aggregate information that the Globus Company uses to monitor the website’s performance, count visits to each page, detect technical errors, check how users reach the website, and measure the effectiveness of advertising and targeted ads.
• The website uses third-party cookies:

Google Analytics cookies – “Google Analytics cookies” are used to collect information about how users use the website. The Globus Company uses information to create reports and improve the website. These “cookies” collect information anonymously, for example determining the number of visitors, where users came to the website from, and which buttons the user clicked on. You can read Google’s privacy policy regarding Google Analytics on Google’s websites. In order to disable Google Analytics cookies, you must request this from Google separately. “Google Cookies” include Google AdWords & DoubleClick cookies for marketing, advertising and remarketing. These enable us to identify visitors to our advertising partners’ websites and target them with interest-based ads and information.

Facebook cookies – The use of these “cookies” is for advertising based on the user’s interest, in other words, ads that the user may be interested in based on their activity on websites other than “Facebook”. These “cookies” collect information from visits to the website and enable ad promotion through “Facebook” platforms.

To disable Facebook’s interest-based ads, follow Facebook’s instructions.

More information about Facebook’s privacy policy can be found on the official Facebook website

Microsoft Cookies – “Microsoft cookies” are used to collect information about how visitors use the company’s website as well as for marketing, advertising, or remarketing. These “cookies” make it possible to identify visitors to our advertising partners’ websites and target them with interest-based information or ads.

 

Contact us

If you have any questions regarding this Privacy Policy or the privacy practices of the Globus Company, please contact the Data Protection Officer via email. dataprotectionofficer@globus-intr.co.il