Privacy Policy Statement
Last Updated: March 1, 2024
This Privacy Policy
describes how GlobalVATCo collects, uses, shares, and secures your Personal
Data when you access our Website (globalvatco.com,) use
our Services (defined below), or otherwise interact with us. This Privacy
Policy contains an explanation of your rights regarding GlobalVATCo’s use of
your Personal Data and how we communicate with you.
GlobalVATCo attaches
great importance to ensuring that your personal data is collected, used,
stored, and erased in accordance with the current applicable regulations as
stipulated by local, state, national, federal, and other data protection
legislation. Protecting your data is a matter of great importance to our
company. If you have requests concerning your personal information or any
questions, please contact us at privacy@globalvatco.com.
GlobalVATCo makes
available this Privacy Policy in compliance with its role as a data controller,
as that role is defined by relevant legislation. This means that it applies to
when GlobalVATCo collects, uses, shares, and processes data. While this Privacy
Policy is provided under the GlobalVATCo brand, it applies to local GlobalVATCo
Member Firms with whom a User interacts or has an Engagement and may not apply
to all GlobalVATCo Member Firms, depending on their location and affected data
subjects.
We base our corporate
definition of “data controller” and “data processor” on those set forth in the
Regulation 2016/679 of the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to
the processing of personal data and on the free movement of such data and
repealing Directive 95/46/EC (General Data Protection Regulation (“GDPR”)). We
use the GDPR framework as our standard as GlobalVATCo provides Value Added Tax
(“VAT”) consultancy services primarily for the European market. For United
States’ privacy compliance, see our “Notice at Collection” below.
1. Definitions
For purposes of this
Privacy Policy the following definitions are applied:
References to “Client”
means the Client identified in the Engagement Letter (as defined in our General
Terms and Conditions) in place between a GlobalVATCo Member Firm and Client.
References to a “Data
Subject” mean a User on whom we have collected, used, processed, shared, or
otherwise received and handled Personal Data as the term “data subject” is
defined by the GDPR.
References to
“Personal Data” mean any data that could, directly or indirectly, be used to
identify a User as personal data, personal information, or personally
identifiable data or information may be defined by relevant law.
References to the
“Services” means those Services for which we have an Engagement (as defined by
our General Terms and Conditions.)
References to “us,”
“we,” “our,” and/or “GlobalVATCo,” GlobalVATCo refers to the GlobalVATCo member
network and/or one or more of its Member Firms that may process personal
information. Each GlobalVATCo Member Firm (as defined in the General Terms and
Conditions) is a separate legal entity and may have specific data protection
regulations that apply to it. The data controller of a User’s Personal
Information will be the GlobalVATCo Member Firm with whom that User (or Client,
as applicable) interacts or otherwise has an Engagement (as defined in the
General Terms and Conditions.) GlobalVATCo Member Firms are independently
operating.
References to the “Website” means the website globalvatco.com.
References to “you,”
and/or “User,” mean a user of the Website, representative of a Client, or an individual who has interacted with GlobalVATCo,
such as by signing up for our mailing list, attending a GlobalVATCo webinar, or
emailing GlobalVATCo.
2. Agreement to be Bound
By accessing the
Website, engaging us for our Services, or otherwise interacting with us, you
represent that you have read and understood the Privacy Policy and that you
agree to be bound by it.
This Privacy Policy
may be additionally subject to our Agreement (including an Engagement Letter
and General Terms and Conditions) for Clients with whom we have an Engagement
and our Website Terms and Conditions for Users of our Website.
3. Modifications And Changes To The
Privacy Policy
We may modify, add to,
suspend, or delete the Privacy Policy, in whole or in part, at our sole
discretion at any time, with such modifications, additions, or deletions being
effective thirty (30) calendar days following their posting to the Website and
emailing of a notice to Users for whom we have an email address. Your access of
the Website or continued interaction with us after such modification, addition,
or deletion of the Privacy Policy shall be deemed to constitute acceptance by
you of such changes.
4. The Personal Data We Collect: Purpose Of
Collection; Data Collected; & Our Lawful Basis For Processing
We collect both
personally identifiable data and non-personally identifiable data. Often, you
choose what information to provide to us, but, sometimes, we may require
certain information for you to use and for us to provide the Services, the
Website, the content you have requested from us, or to otherwise interact with
us. We collect Personal Data directly from Users, from our Clients,
automatically from Users (such as through interactions with our Website,) and
from lead sources (where allowed by relevant law). More details can be found
below on the source of Personal Data, why Personal Data is collected, what is
collected, and our basis for processing Personal Data.
We believe in the
principle of data minimization and so always try to collect the minimal amount
of Personal Data necessary to make our Services, Website, and business
function.
A. Personal Data You Provide To Us
We collect the
Personal Data you directly provide to us and use it in the following ways:
|
Purpose |
Data Collected |
Lawful Basis for Processing |
|
Marketing Communications |
Name, Job Title, Company Email,
Company Phone Number, Company Address, Affiliated Client Organization, Other
information you may provide to us, such as that which may be found in your
corporate email signature (such as a picture or gender). |
GlobalVATCo’s and our Clients’
legitimate interests: Collection and processing of Users’ Personal Data is
necessary to communicate with our Clients and their
designated representatives regarding company and other marketing related
news. Consent: Collection and processing of Users’ Personal Data may also be
based on consent, when such consent is explicitly requested by us. |
|
Engagement |
Name, Job Title, Company Email,
Company Phone Number, Company Address, Affiliated Client Organization, Personal
Address of Client Representative; Passport or other Photo Identification
Document of Client Representative, Other information you may provide to us,
such as that which may be found in your corporate email signature (such as a
picture or gender). |
GlobalVATCo’s and our Clients’
legitimate interests: Collection and processing of Users’ Personal Data is
necessary for Engagement (as defined by the General Terms and Conditions for
provision of our Services). Consent: Collection and processing of Users’
Personal Data may also be based on consent, when such consent is given by you.
This includes where calls are recorded for GlobalVATCo’s information purposes
and data collection (GlobalVATCo’s legitimate interest) and where such a
recording may require consent under applicable law. |
|
Events, in person and online |
Name, Job Title, Company Email,
Company Phone Number, Company Address, Affiliated Client Organization. For
virtual events, we may also collect a video or voice recording, depending on
the type of virtual event. |
GlobalVATCo’s and our Clients’
legitimate interests: Collection and processing of Users’ Personal Data is
necessary for inclusion of a User in an event, event follow up, and further
communication with participants. Consent: Where a User
voice or video is recorded as part of an event, consent will be obtained in
advance of such recording, where required by relevant law. |
B. Personal Data We Collect In
Connection With Our Engagement
We collect Personal
Data in connection with our Engagement and use such Personal Data in the below
ways. GlobalVATCo does not offer its Services to consumers, and, therefore, to
the extent that it collects a User’s Personal Data from a Client or a
representative of a Client, GlobalVATCo relies on the representations of the Client
that the Client has the lawful authority to have collected and provided such
Personal Data to GlobalVATCo, for example, pursuant to an employment contract
between the User and Client.
|
Purpose |
Data Collected |
Lawful Basis for Processing |
|
Client Onboarding & Account
Management |
Name, Job Title, Company Email,
Company Phone Number, Company Address, Affiliated Client Organization,
Personal Address of Client Representative; Passport or other Photo
Identification Document of Client Representative |
GlobalVATCo’s and our Clients’
legitimate interests: Collection and processing of Users’ Personal Data is
necessary for the provision of onboarding and account management, including
KYC. Contract: We collect and process Personal Data for the purpose of
onboarding Clients as required under our contractual obligation. |
|
Legal & Compliance |
Name, Job Title, Company Email,
Company Phone Number, Company Address, Affiliated Client Organization,
Personal Address of Client Representative; Passport or other Photo
Identification Document of Client Representative, Other information you may
provide to us, such as that which may be found in your corporate email
signature (such as a photo or gender). |
GlobalVATCo’s and our Clients’
legitimate interests: Collection and processing of Users’ Personal Data is
necessary for the administration of contracts. Contract: We collect and
process Personal Data for the purpose of administering our Client
contracts, including for VAT registration purposes. |
|
Cookies and First-Party Tracking |
Cookies and cookieless
tracking technologies. |
Consent: Collection and processing
of Users’ Personal Data is based on User consent, where required by law. |
C. Personal Data We Automatically Collect From
Users Of Our Website
We collect Personal
Data automatically from Users of our Website. We use this Personal Data in the
below ways:
|
Purpose |
Data Collected |
Lawful Basis for Processing |
|
Cookies and First-Party
Tracking Technologies |
Cookies and cookieless
tracking technologies. Please refer to our Cookie Policy. |
Consent: Collection and processing
of Users’ Personal Data is based on User consent, where required by law. GlobalVATCo’s and User’s
legitimate interests, unless prohibited by law: Collection and processing of
Users’ Personal Data is used by GlobalVATCo to obtain analytics regarding
usage of our Website and tailor our Website to
Users’ preferences as well as to ensure the Website runs smoothly and without
interruption. |
|
Metadata |
Links a User interacts with,
Features or content accessed, and other similar contextual information
regarding usage. |
Consent: Collection and processing
of Users’ Personal Data is based on User consent, where required by law. GlobalVATCo’s legitimate
interests: Collection and processing of Users’ Personal Data is used by
GlobalVATCo to obtain contextual information regarding usage of our Website. |
|
Log Data |
IP address (masked), Address of
websites visited before using the Website, Browser type and settings, Data
and time of access, Browser configurations and plugins, Language preferences. |
Consent: Collection and processing
of Users’ Personal Data is based on User consent, where required by law. GlobalVATCo’s and Client’s
legitimate interests, unless prohibited by law: Collection and processing of
Users’ Personal Data is used by GlobalVATCo for security, analytics, and
troubleshooting. |
|
Device Information |
Type of device, Operating system
used, Device settings, Application IDs, Unique device identifiers, Crash
data. |
Consent: Collection and processing
of Users’ Personal Data is based on User consent, where required by law. GlobalVATCo’s and Client’s
legitimate interests, unless prohibited by law: Collection and processing of
Users’ Personal Data is used by GlobalVATCo for security, analytics, and
troubleshooting. |
|
Location Information |
Company address, IP addressed
(masked), Browser information (including referrers), Device information (such
as iOS IDFA, IDFV for limited, non-advertising purposes). |
Consent: Collection and processing
of Users’ Personal Data is based on User consent, where required by law. GlobalVATCo’s and Client’s
legitimate interests, unless prohibited by law: Collection and processing of
Users’ Personal Data is used by GlobalVATCo for localization, compliance, and
security. |
D. Personal Data We Collect From Third
Parties
We may collect
Personal Data regarding Users from third parties and other websites, depending
on local rules and regulations regarding collection of Personal Data from third
parties. Depending on the jurisdiction where a User is located, the following
may or may not be applicable as we seek to ensure compliance with all relevant
regulations that affect our Users. We use this Personal Data in the below ways:
|
Purpose |
Data Collected |
Lawful Basis for Processing |
|
Clients may provide us with Users’
Personal Data as a designated point of contact for a Client, Legal and
Compliance, and Events. |
Name, Job Title, Company Email,
Company Phone Number, Company Address, Affiliated Client Organization, Other
information the Client may provide to us. |
Consent: Collection and processing
of Users’ Personal Data is based on User consent, where required by law. GlobalVATCo’s and User’s
legitimate interests, unless prohibited by law: Collection and processing of
Users’ Personal Data is used by GlobalVATCo to obtain analytics regarding
usage of our Website and tailor our Website to
Users’ preferences as well as to ensure the Website runs smoothly and without
interruption. |
|
Sales; Marketing |
Name, Job Title, Company Email,
Company Phone Number, Company Address, Affiliated Client Organization, and Other information that may be provided to us by
third-party lead services. |
GlobalVATCo’s legitimate
interests, unless prohibited by law: Collection and processing of Users’
Personal Data is used by GlobalVATCo to connect with prospective Clients for
sales and marketing purposes. |
5. The Personal Data We DO NOT Collect
GlobalVATCo does not
collect any special category or sensitive data, for example, we do not collect
health data, financial data, racial identity data, religious data, or any other
data attributable to a single User that may be considered sensitive unless it
is provided by a Client, in which event it is processed solely for purpose of
the Engagement and based on the lawful basis of contract with the Client.
6. With Whom We Share Your Personal Data
GlobalVATCo may share
your Personal Data with GlobalVATCo Member Firms (as defined in our General
Terms and Conditions) and GlobalVATCo-Subcontracts (as defined in our General
Terms and Conditions.) We may also share your Personal Data with third parties
in the ways described below. We will never sell Personal Data of our
Users. For more information regarding how we comply with US state laws on
the selling and sharing of User Personal Data, please see our Notice at Collection.
|
When you have given us consent |
We may share your Personal Data
where you have given us consent to share it. |
|
To our third-party vendors and
services providers |
As a data controller, we engage
third-party vendors and service providers to process data on our behalf.
Where required, we have in place contracts with these third parties that
limit the processing of the Personal Data to the extent necessary to provide
the services and which include reasonable assurances regarding appropriately
safeguarding the Personal Data. |
|
For legal and compliance purposes |
We may share Personal Data if we
believe we are compelled to do so by applicable law, regulation, process, or
a government request. Where we are legally permitted to do so, Users will be
notified in advance of disclosure and given any legally permitted time to
object to such a disclosure. To the extent permitted by
applicable law, we may also share Personal data to enforce our own agreements
or policies, to protect the integrity of our Services, to protect ourselves,
Clients, Users, or the public from harm or illegality, or to respond to an
emergency where we believe a vital interest requires us to do so. |
|
Corporate matters |
In the event of a corporate sale,
merger, dissolution, reorganization, change in control, or similar corporate
event, we may transfer Personal Data in a way that constitutes a sale of
Personal Data. We will endeavour to notify Users
ahead of such a sale, where possible. |
7. Your Rights And How To Exercise Them
You have certain
rights regarding your Personal Data, depending on your country of residence.
Below is a summary of those rights. California Users are directed to GlobalVATCo’s Statement at Collection for a summary of their
rights under state law, which may differ from those set forth below.
Sometimes, your rights
may be limited, such as when honoring a request would reveal information about
another person or if you request we delete Personal
Data that we are permitted by law or our legitimate interests to keep.
We are required to
verify the identity of any User exercising a Personal Data right. This
identification process may require providing us with a signed declaration
confirming your identity. If a request is made on behalf of a User by a third
party, we require a certification from the User that we can provide such third
party the User’s Personal Data. We reserve the right to deny any request where
we do not reasonably believe the identity of the User or authorization for such
a request has been provided to us.
We will respond to any
request in a timely manner, which in most instances will be thirty (30) days.
The time to respond to requests is set out in relevant law and may differ,
depending on where the User resides.
- Right to be Informed.
You have the right to be informed about GlobalVATCo’s data collection
processes. We fulfill this right by providing you with this Privacy
Policy, including at the time of Personal Data collection.
- Right of Access.
You have the right to access what Personal Data GlobalVATCo has collected
about you. You can exercise this right by making a Data Subject Access
Request via email at privacy@globalvatco.com.
- Right
to Rectification. You have the right to ask
GlobalVATCo to correct any Personal Data it holds about you so as to ensure your Personal Data is accurate. You
also have the right to ask GlobalVATCo to complete incomplete Personal
Data held about you. You can correct any incorrect Personal Data by
emailing us at privacy@globalvatco.com.
- Right
to Restrict Processing. You have the right to
restrict GlobalVATCo’s processing of your Personal Data where: you have
contested the accuracy of the Personal Data; you have objected to the
processing and GlobalVATCo is considering whether it has a legitimate
ground which overrides this objection; the processing is unlawful; or
GlobalVATCo no longer requires the Personal Data but you require that
GlobalVATCo does not delete it so as to establish, exercise or defend a
legal claim you may have. To exercise your right to restrict processing,
please email us at privacy@globalvatco.com. A User may also contact
the User’s relevant Client, where User is a representative of a Client, to discuss the User’s desire to restrict
processing where such processing relates to Personal Data provided by said
Client or processed on the basis of contract with said Client.
- Right to Erasure.
In some circumstances, you have the right to ask that your Personal Data
be deleted: your Personal Data is no longer necessary in relation to the
purpose for which it was collected/processed by GlobalVATCo; you withdraw
your consent or object to the processing and there is no overriding
legitimate interest to continue processing; you object to the processing
and there are no overriding legitimate grounds for the processing; you
object to the processing and your Personal Data was processed for direct
marketing purposes; or your Personal Data was unlawfully processed or
should be erased to comply with a legal obligation.
- Please
note, that GlobalVATCo may refuse your request to delete your Personal
Data if an exception applies: to comply with a legal obligation or for the
performance of a task of public interest; for the exercise or defense of
legal claims; or for purposes relating to public health, archiving in the
public interest, scientific/historic research or statistics.
If your Personal Data has been disclosed to a third party, GlobalVATCo will ask it to erase that data, unless this proves impossible or involves disproportionate effort. You may ask who those third parties are by making a Data Subject Access Request by emailing us at privacy@globalvatco.com, and GlobalVATCo or the relevant Client, as applicable, will inform you accordingly. A User who is a Client representative may also contact the User’s relevant Client to discuss the User’s desire to be forgotten where such processing relates to Personal Data provided by said Client or processed on the basis of contract with said Client. - Right to Data Portability.
You have the right to move, copy, or transfer your Personal Data from one
IT environment to another in a safe and secure way, without hindrance to
usability. This enables you to obtain and reuse your Personal Data across
different services. This being noted, due to the nature of the Services GlobalVATCo
provides and the types of data it collects, the right to data portability,
although it exists, any Personal Data we provide to you in response to
your exercise of this right may be limited in its utility. This right
applies to Personal Data that you have personally provided to GlobalVATCo
(see above section “The Personal Data You Provide to Us”); where our
processing is based on consent or the performance of a contract; and where
processing is carried out by automated means. You may make a request for
data portability by making a Data Subject Access Request by emailing us at
privacy@globalvatco.com.
- Right
to Object. You have the right to object
to GlobalVATCo’s processing of your Personal Data in certain
circumstances. You also have the right to stop your Personal Data being
used for direct marketing. You can also object to GlobalVATCo’s processing
of your Personal Data if the processing is for: a task carried out in the
public interest; is done in the exercise of an official authority vested
in GlobalVATCo; or is done for GlobalVATCo’s legitimate interests (or
those of a third party). However, in these circumstances the right to
object is not absolute, and you must give specific reasons why you are
objecting to the processing of your Personal Data. Even if an objection is
made, GlobalVATCo will continue to process your Personal Data if:
GlobalVATCo can demonstrate compelling legitimate grounds for the
processing, which override the interests, rights and freedoms of the
objecting User; or the processing is for the establishment, exercise or defense
of legal claims. To exercise your right to object to processing, please
email us at privacy@globalvatco.com. A User who is a representative
of a Client
may also contact the User’s relevant Client to discuss the User’s
objection where such processing relates to Personal Data provided by said
Client or processed on the basis of contract
with said Client.
- Right
Not to Be Subject to Automated Decision Making or Profiling.
You have the right not to be subject to fully automatic decisions (those
without human intervention in the decision-making process) that may have
legal effects or which would significantly
affect you. You also have the right not to be profiled, which is any form
of automated processing of your Personal Data consisting of the use of
Personal Data to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning
your performance at work, economic situation, health, personal
preferences, interests, reliability, behavior, location, or movements. At
present, GlobalVATCo does not use any fully-automated decision making or profiling
systems, and, therefore, this right cannot be exercised. However,
GlobalVATCo may use such automated decision-making in the following
circumstances: where we have notified you of the decision and given you 21 days to request a reconsideration; or where it
is necessary to perform the contract and appropriate measures are in place
to safeguard your rights.
8. Revoking Consent
Where we collect or
process your Personal Data based upon consent, you may revoke consent. Please
note, if you revoke your consent for the processing of Personal Data, we may no
longer be able to provide Services under our Engagement with a Client.
9. Communications From GlobalVATCo
You may control the
receipt of certain types of communications from GlobalVATCo. GlobalVATCo may
contact you by phone or email about the Services. Some of these communications
are required, such as transactional communications or legal notices. Other
communications are not required, such as newsletters and direct marketing, as
discussed below. We will never share your email with a third party for its own
marketing purposes, unless you have given us your consent to do so.
10. Our Newsletter and How to Opt-Out
We might operate an
email newsletter program, used to inform subscribers about products and
services supplied by us or our third-party affiliates, including other
GlobalVATCo Member Firms, news that may affect our Clients and Users, and
upcoming event announcements. Subscription to our newsletter is opt-in. Users
can opt-out of receiving our newsletter at any time by following the
unsubscribe link contained in the footer of any newsletter or by emailing us at privacy@globalvatco.com.
Please note that for representatives of current Clients, your consent to
receive direct marketing from GlobalVATCo is assumed; however, you may opt- out
of receiving such direct marketing at any time, and such opt-out will be
respected.
Email marketing
campaigns published by us may contain tracking facilities within the actual
email. Subscriber activity is tracked and stored in a database for future
analysis and evaluation. Such tracked activity may include the opening of
emails, forwarding of emails, the clicking of links within the email content,
times, dates, and frequency of activity. This information is used for GlobalVATCo’s
and the User’s legitimate interest to refine future email campaigns and supply
the User with more relevant content based around the User’s activity. If you do
not agree with the use of such tracking, please unsubscribe from our newsletter
or otherwise withdraw consent using one of the methods set out in this Privacy
Policy.
11. Do Not Track (DNT) Disclosure
Please note that while you may have the opportunity to opt-out
of our marketing email list as discussed in the “How to Opt-Out” section above,
and you may be able to control the use of cookies through your Web browser as
described in the “Use of Cookies” section below, some Web browsers may also
give you the ability to enable a “do not track” setting. This setting sends a
special signal to the websites you encounter while Web browsing. This “do not
track” signal is different from disabling certain forms of tracking by
declining cookies in your browser settings, as browsers with the “do not track”
setting enabled still have the ability to accept cookies. We do not respond to
Web browser “do not track” signals at this time. If we do so in the future, we will
describe how we do so in this Privacy Policy. For more information about “do
not track,” visit http://www.allaboutdnt.org/.
12. Other Web Sites
Our Website
may contain links to other websites, including GlobalVATCo Member Firms, which
are outside our control and are not covered by this Privacy Policy. If you
access other websites using the links provided, the operators of these websites
may collect Personal Data from you, which will be used by them in accordance
with their privacy policies. These policies may differ from ours.
13. Cookies and Other Tracking Technologies
To enhance your online
experience, we may use “cookies” or similar technologies. Please see our Cookie
Policy, available online at https://GlobalVATCo.com/cookie-policy/ regarding our use of cookies and how to opt-out of online
tracking. Please note that if you change browsers or computers, or if you clear
your browser’s cache, you may need to click the link again to apply your
preferences.
14. Privacy Protection for Children Using the Internet; Notice
to Minors
Protecting children’s privacy is important to us. For that reason, we do not collect or maintain Personal
Data of those persons we actually
know are under the age
of thirteen (13) nor is any part of the Website, or our Services targeted to
attract anyone under the age of thirteen (13). We request that all users
of the Website and our Services who are under the age of thirteen (13) not
disclose or provide any Personal Data. If we discover that a child under
thirteen (13) has provided us with Personal Data, we will delete that child’s
Personal Data from our records. You are responsible for
any and all account activity conducted by a minor under
your account.
In addition to protecting the privacy of children under the age
of thirteen (13), we are committed to protecting the privacy of minors. Though
our Website and Services are not targeted to minors, nor are they intended to
be used by minors, if for any reason a minor has shared Personal Data with us,
said minor may request and obtain removal of such information by contacting us
at privacy@globalvatco.com.
15. Retention
GlobalVATCo will
retain your Personal Data only for as long as is necessary for the purposes set
out in this Privacy Policy. This may include for the term of Engagement where
you are a designated representative of a Client, for
those other purposes as described in this Privacy Policy, or in alignment with
our regulatory obligations. If you no longer want GlobalVATCo to use your
Personal Data, you may exercise your right of deletion; however, as Engagements
are conducted in accordance with our contract with a Client, Users who wish to be
removed as Client representatives should first speak with the relevant Client
regarding their desires to be removed as
a Client point of contact for the Engagement, marketing, legal, and/or
compliance purposes. GlobalVATCo will retain and use your information to the
extent necessary to comply with our legal obligations (for example, if we are
required to retain your information to comply with applicable tax/revenue
laws), resolve disputes, and enforce our agreements. The period for which are
required to retain Personal Data for these purposes is set by law and is
jurisdictionally dependent. We also retain log files for internal analysis
purposes. These log files are generally retained for a brief period of time,
except in cases where they are used for the safety and security of our Website, to improve the functionality of our Website or we
are legally obligated to retain them for longer time periods.
16. Data Security
We take steps to
maintain the security of the Personal Data that we collect, including having
implemented additional safeguards for the Personal Data of our EEA/UK/Swiss Clients.
We also closely evaluate our third-party processors and those companies with
whom we share Personal Data to ensure compliance with relevant data processing
laws.
Please note that no
service is completely secure. While we strive to protect your Personal Data, we
cannot guarantee that unauthorized access, hacking, data loss, or a data breach
will never occur. If we are required by law to inform you of a breach to your
information, we may notify you electronically, in writing, or by telephone. For
Users who are Client authorized contact points, such notification may come from
the relevant Client.
17. International Data Transfers
GlobalVATCo Member
Firms operate in their respective jurisdictions, which include Switzerland and the
United States, and which comply with their jurisdictional-relevant data
protection laws. Where a GlobalVATCo Member Firm must transfer Personal Data to
a different GlobalVATCo Member Firm or GlobalVATCo Subcontractor, it will rely
on appropriate safeguards to ensure Personal Data remains protected and
otherwise comply with relevant data transfer regulations.
19. Right To Non-Discrimination
We will not
discriminate against individuals who exercise their privacy rights under
applicable law. However, the exercise of some rights may result in our
inability to provide a User with access to the Website or to otherwise continue
rendering Services under an Engagement.
20. Accessibility.
This Privacy Policy
can be accessed using your browser’s audio reader capabilities. Please see
our Accessibility Statement for more information.
21. Testimonials, Feedback, Case Studies.
We may display
personal testimonials from satisfied Clients who have given us their permission
to do so and other endorsements on our Website. If you
are the authorized representative of a Client, where a
Client has given us permission, we may post a User’s photograph, name, and
title together with a testimonial. Where we do so, we base our processing on
the representation from our Clients that they have
your consent to do so and have given us this consent. If you wish us to update
or delete your testimonial, please contact us at privacy@globalvatco.com.
We consider answers to
surveys, comments, ideas, and suggestions to be non-personal and do not
classify them as Personal Data. Except as otherwise provided by applicable
contracts with our Clients or a third party, we are
free to disclose and use such data or information without any obligation.
22. How to Contact Us
If you have any
questions or concerns about our Privacy Policy or its implementation you may
contact us: at privacy@globalvatco.com.
Or you may write to the
GlobalVATCo Member Firm with whom you have an Engagement.
Without prejudice to
any other rights you may have, if you have retained
GlobalVATCo Member Firm GlobalVATCo GmbH, you also have the right to file a
complaint against GlobalVATCo with the Swiss Data Protection Commissioner
(“FDPIC,”) which is GlobalVATCo GmbH’s Lead Supervisory Authority. The FDPIC’s
contact details are:
Federal Data Protection and Information
Commissioner
Feldeggweg 1
CH-3003 Bern
Phone: +410584624395
Digital post: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html
If you live in the
EEA/UK/Switzerland, you may also file a complaint with your local data
protection regulator.
23. Key Changes
This Privacy Policy
was last updated on the date first written above to include more detailed
information about from where we collect Personal Data, our bases of processing,
our commitment to U.S. state laws regarding privacy policy, among other
changes.
24. U.S. CCPA & State Privacy Notice - Notice at Collection
We provide the
following U.S. CCPA & State Privacy Notice – Notice at Collection for Users
located in California and other states which may have privacy regulations. To
the extent of a disagreement between the main terms of the forgoing Privacy
Policy and this Notice at Collection, this Notice at Collection will control.
GlobalVATCo Member Firms adhere to the requirements of state
privacy law, including the California Consumer Privacy Act of 2018 (“CCPA,”)
which became effective on January 1, 2020, and its November 2020 amendment,
effective January 1, 2023. In addition to the CCPA, we adhere to the
requirements of other state privacy laws, including Virginia, Colorado,
Connecticut, and Utah. We provide this U.S. CCPA & State Law Privacy Notice
in compliance with those state laws. Please note that some states have not yet
finalized their implementation rules; however, in an effort
to be fully transparent and compliant, we make this privacy notice at
this time and will update it as required when the rules are finalized.
GlobalVATCo’s U.S.
CCPA & State Privacy Notice is based on the principles of:
- Accountability so that you know
GlobalVATCo holds itself accountable to its Clients and Users who entrust
it with Personal Information
- Transparency so that you know
what Personal Information we collect, use, disclose, share, and sell
- Control so that you can
contract how your Personal Information is accessed, corrected, and deleted
Introduction
“Personal Information” is information that identifies, relates to, or could
reasonably be linked directly or indirectly with a particular resident and
includes certain categories of Personal Information set out in this Notice at
Collection. Personal Information can also include “Sensitive Personal
Information.”
GlobalVATCo takes data
protection seriously and has implemented various physical, technical,
electronic, procedural, and organizational safeguards and security measures to
protect Personal Data against unlawful, accidental, and unauthorized
destruction, loss, alteration, disclosure, or access.
The Personal Information We Collect; How We Collect Personal Information; Our
Purpose of Collection; and With Whom We Share Personal Information
Individuals should
know what Personal Information companies collect, use, process, and sell their
Personal Data as well as the reason for such collection, use, and processing.
We detail below the categories of Personal Information we collect, where we get
that data, why we process it, and who we give the data to.
General Personal Data
Collected, used, and Processed
|
Category of Personal Information |
Sources of Personal
Information |
Purpose of Processing |
Recipients |
|
A. User Identifiers: Name, Title,
Company Email, Company Address, Company Phone Number, Affiliated Client
Organization, IP address |
Prospect leads; Client
Representatives; Clients; Interactions with affected Users |
Marketing: Communicate with our
Clients and Users regarding company, Services, and other marketing related
news Events: Inclusion of a User in an
event, event follow up, and further communication with participants |
Service providers; GlobalVATCo
Member Firms; GlobalVATCo Subcontractors |
|
B. Client Records: Name,
Signature, Company Address, Company Phone Number |
Prospect leads; Clients; Client
Representatives; Interactions with affected Users |
Marketing: Communicate with our
Clients and Users regarding company, Services, and other marketing related
news; Events: Inclusion of a User in an
event, event follow up, and further communication with participants |
Service providers; GlobalVATCo
Member Firms; GlobalVATCo Subcontractors |
|
C. Characteristics of Protected
Classifications Under California or Federal Law: Gender identity if provided
in a Users’ email signature |
Interactions with affected Users |
GlobalVATCo does not categorize or
make use of this Personal Information. However, to the extent it is provided
by a User through an interaction with a GlobalVATCo Member Firm, e.g., via an
email to GlobalVATCo sales, marketing, or support services. |
Email provider; GlobalVATCo Member
Firms; GlobalVATCo Subcontractors |
|
D. Commercial Information: Engagement
of a GlobalVATCo Member Firm |
Clients and Users |
Engagements: Engagements with
GlobalVATCo Member Firms Services |
Service providers; GlobalVATCo
Member Firms; GlobalVATCo Subcontractors |
|
E. Biometric Data: GlobalVATCo
does not collect biometric data for identity verification |
N/A |
N/A |
N/A |
|
F. Internet or other Electric
Network Activity Information: Information regarding Users’ use of the
GlobalVATCo Website; Cookies and cookieless
tracking technologies |
Users’ interactions with the
Website |
Personalization: Provision and
personalization of use of the Website |
Service providers |
|
G. Geolocation Data: IP address |
Users’ interactions with the
Website |
Engagements: Engagements with
GlobalVATCo Member Firms Services |
Service providers; |
|
H. Audio, electronic, visual,
thermal, olfactory, or similar information: Audio and video |
Interactions with affected Users |
Marketing: Recording of webinars
for general marketing purposes |
Service providers; GlobalVATCo
Member Firms; GlobalVATCo Subcontractors |
|
I. Professional or
Employment-Related Information: Name, Title, Company Email, Company Address,
Company Phone Number, Affiliated Client Organization |
Prospect leads; Clients;
Interactions with affected Users |
Marketing: Communicate with our
Clients and Users regarding company, Services, and other marketing related
news Events: Inclusion of a User in an
event, event follow up, and further communication with participants |
Service providers; GlobalVATCo
Member Firms; GlobalVATCo Subcontractors |
|
J. Education Information: Not
collected |
N/A |
N/A |
N/A |
|
K. Inferences: Not collected |
N/A |
N/A |
N/A |
|
Sensitive Personal Data Collected,
Used, and Processed |
|||
|
|
|
||||||
|
Category of Sensitive Personal
Information |
Sources of Sensitive Personal
Information |
Purpose of Processing |
Recipients |
||||
|
Account Log-In, Financial Account,
Debit or Credit Card Number, and the Means to Access the Account (Security or
Access Code, Password, Credentials, etc.): Account log-in information;
Credentials |
Clients and Users |
Engagements: Engagements with
GlobalVATCo Member Firms Services |
Service providers; GlobalVATCo
Member Firms; GlobalVATCo Subcontractors |
||||
|
Precise Geo-Location Information:
IP Address |
Users’ interactions with the
Website |
A Engagements: Engagements with GlobalVATCo Member Firms
Services Personalization: Provision and
personalization of use of the Website |
Service providers; GlobalVATCo
Member Firms; GlobalVATCo Subcontractors |
||||
|
Is any sensitive data processed? |
No, unless it is provided by a
Client under an Engagement with a GlobalVATCo Member Firm |
No, unless it is provided by a
Client under an Engagement with a GlobalVATCo Member Firm |
No. |
||||
|
Racial or Ethnic Origin, Religious
or Philosophical Beliefs, or Union Membership: Not collected |
N/A |
N/A |
N/A |
||||
|
Medical or Mental Health, Sex
Life, or Sexual Orientation: Not collected |
N/A |
N/A |
N/A |
||||
|
Biometric Data: GlobalVATCo does
not collect biometric data for identity verification |
N/A |
N/A |
N/A |
||||
|
Contents of your Mail, Email, or
Text Messages (where GlobalVATCo is not the intended recipient of the
communication): Not collected |
N/A |
N/A |
N/A |
||||
|
Personal Data Collected from a
Known Child Under 13 Years of Age: Not collected |
N/A |
N/A |
N/A |
||||
|
|
|
||||||
We may also use your
Personal Information for the following purposes:
·
As necessary or
appropriate to protect the rights, property or safety of us, our Clients,
Users, or others;
·
To respond to law
enforcement requests and as required by applicable law, court order, or
governmental regulations; or
·
To evaluate or conduct
a merger, divestiture, restructuring, reorganization, dissolution, or other
sale or transfer of some or all of our assets, whether
as a going concern or as part of bankruptcy, liquidation, or similar
proceeding, in which personal information held by us is among the assets
transferred.
We will not collect
additional categories of Personal Information or use the Personal Information
we collected for materially different, unrelated, or incompatible purposes
without providing you notice.
Sharing of Personal Information
Users have the right
to know if their Personal Information is shared with third parties. We may
share with or otherwise disclose your Personal Information for the business
purposes outlined in this notice. When we disclose personal data to third
parties, we do so under a contract with the third party that describes the
purposes of the sharing of the data and the requirements for keeping Personal
Information confidential and limited.
In the preceding
twelve (12) months, we have disclosed the following categories of data for a
business purpose:
- Category A: User Identifiers
- Category B: Client Records
- Category C: Characteristics of
Protected Classifications Under California or Federal Law
- Category D: Commercial
Information
- Category F: Internet or other Electric
Network Activity Information
- Category G: Geolocation Data
- Category I: Professional or
Employment-Related Information
Disclosures to our
Service Providers. We may provide
Personal Information to our services providers, as defined by the CCPA, so that
they can perform services for us as specified in our contracts with such
service providers and for the purposes outlined above.
Disclosures to our Corporate Entities. We may share your Personal
Information with our related corporate entities.
Disclosures for Other
Purposes. In addition, we
may disclose personal information to third parties for other notified purposes,
as permitted by U.S. state data privacy laws.
"Sharing" and Personalized Advertising. We do not share
Personal Information with third parties for personalized advertising purposes,
as defined under applicable U.S. state laws.
We Do Not Sell Your Personal Information
Users have the right to know if their Personal Information is
being sold. Personal Information is sold when it is provided to a third party
for monetary or other valuable consideration for a purposes
that is not considered a business purpose as defined by the relevant state law.
This does not include where GlobalVATCo may share personal data where permitted by law or at a User’s or Client’s direction.
GlobalVATCo does not sell Personal Information.
In the preceding twelve (12) months, we have
not sold any Personal Information.
Right to Opt-out of “Sale” or “Sharing"
GlobalVATCo does not sell or share your personal information as
that is defined by relevant state law. Therefore, we do not offer an opt out.
User Rights Under
State Law
If you are a covered
User under relevant state law, you have the following rights:
1. Receive this Notice at Collection at or before collection of Personal
Information.
2. Request that we disclose to you the following information covering a twelve
(12) – month period prior to your request. Such disclosure is free of charge to
you:
- The categories of Personal
Information we have collected about you;
- The categories of the sources
from which the Personal Information was collected;
- The Categories of third parties
to whom we disclosed your Personal Information; the categories of Personal
Information that were disclosed; and the purpose for disclosing the
Personal Information; and
- The Personal Information we
collected about you.
3. Request that we
correct any Personal Information that we hold that is inaccurate.
4. Request that we
delete Personal Information unless a state law exception to deletion applies
(e.g. for our own tax reporting obligations).
5. Be free from
unlawful discrimination where you may exercise your rights.
How to Exercise Your
Rights Under State Law
Users can exercise their rights under state law by submitting a request to us
by:
1. Emailing us at privacy@globalvatco.com.
The responsible GlobalVATCo Member Firm will acknowledge your
request and advise you how long we expect it will take us to respond. We must
be able to verify your identity. Please note that requests for specific pieces
of Personal Information may require additional information for this
verification. Individuals or Clients who submit a request on behalf of another
person must provide us with proof of authorization and verification directly
from the person to whom the request relates.
We may not be able to honor all requests, in
some circumstances. For example, if we cannot verify a requestor’s identity or
authorization. We also will not honor requests where an exception applies.
Where we cannot honor a request, we will advise you.
We process all requests within 45 days for California residents.
If we need additional time, up to 45 additional days, we will provide you with
an explanation for the delay.
Questions or Concerns
You may contact us
with questions or concerns about this Notice at Collection and our state law
data collection practices by:
- Writing
us at: GlobalVATCo, LLC, 4275 Executive Square, Suite 200 #1097, La Jolla,
CA 92037, USA.
- Emailing us at privacy@globalvatco.com
Changes to this U.S.
CCPA & State Privacy Notice - Notice at Collection
We may change or
update this Notice at Collection from time to time by posting a notice to this
page and by emailing registered Users at the email address we have on file.
Where to Find the Notice of Collection
You can find this Notice at Collection at https://globalvatco.com/privacy-policy