GLOBEKEEPER Privacy Policy

This Privacy Policy was last modified on April 16, 2021.

WELCOME

GlobeKeeper, Inc ("GlobeKeeper", "we", "our", or "us") is committed to protecting and respecting your privacy.

GlobeKeeper operates a service that allows you to communicate to and share your location with other users in your organization (your "Organization" or "Company"), which we make available through our apps and our website https://www.globekeeper.com (the "Service").

This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of information that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Service is available in many different countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

This Privacy Policy is therefore made up of two parts: Part 1 sets out information applicable to users outside the European Economic Area, Switzerland or the UK, and Part 2 sets out information applicable to users in the European Economic Area, Switzerland or the UK.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our Privacy Policy explains how we collect, use, disclose and protect information that is collected through our Service from users outside the European Economic Area,  Switzerland or the UK, as well as your choices regarding the collection and use of information.

This Part 1 of the Privacy Policy was last modified on April 16, 2021.

 

1. HOW WE COLLECT AND USE INFORMATION

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

We collect the following types of information about you:

Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number. We may collect a photo, if you or a Company member associate a photo with your account.

Data collected through use of the Service. After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your important Places and to provide alerts when organization members leave and arrive.

Geolocation. We collect your location information through your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. We collect and maintain location data to provide you the features and functionality of the Service.

Driving Event Data. We collect, and may use a third party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. Your mobile device provider may refer to this information as “Motion and Fitness” data (description may vary according to device and platform).

Messages and User Content. We collect information when you message other members of your Organization through use of the service. We may also retain any messages you send to us.

We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Organization members, crime alerts in your neighborhood, etc.

Social Media. When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to GlobeKeeper’s website or Service.

Information from third-party services. We collect information from third party services that you connect to your GlobeKeeper account. For example, if you link your GlobeKeeper account to a voice assistant platform to enable interaction with our service through voice commands, such as through the GlobeKeeper Google Action (“Action”) available on Google Assistant-enabled devices, we will collect the queries and commands applicable to GlobeKeeper that you make through the Action or other voice assistant platforms.

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.

 

2. SHARING OF YOUR INFORMATION

Personal Information:  We share your personal information with third parties outside the Company and its controlled subsidiaries and affiliates in some circumstances, as follows:

Other instances in which we may share your information: We may also share your information for business purposes, as follows:

De-Identified Information:  We may also share your information with third parties in a form that does not reasonably identify you directly.  These third parties may use the de-identified information for any purpose.

 

3.  HOW WE PROTECT YOUR INFORMATION

GlobeKeeper cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

 

4.  YOUR CHOICES ABOUT YOUR INFORMATION

You may, of course, decline to submit any personal information through the Service, in which case GlobeKeeper may not be able to provide its Services to you.

Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at privacy@globekeeper.com.

Close Your Account or Delete Personal Information: We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at privacy@globekeeper.com. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.

Emails and Notifications:  You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices).  

Location and Movement Data Collection and Sharing:  As described in Section 2, we collect precise location data and driving event and movement data (such as accelerometer data, magnetometer data, gyro data, etc.) from your device to provide the GlobeKeeper Services, and may share your personal information, including location and movement data, with other GlobeKeeper users in your Organization Company or other Company you belong to, and with third parties for crash detection, research, analytics and attribution. You have many options to control this data collection and sharing activity through the App Settings:

5.  LINKS TO OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

 

6.  CHANGES TO OUR PRIVACY POLICY

GlobeKeeper may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how GlobeKeeper will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

 

7.  YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to you if you are a resident of the state of California (a “consumer”). California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.

Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.

In the last 12 months, we have collected the following categories of personal information:

We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.

Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) third party businesses that provide features or services you may use in connection with our Service; (iv) marketing and strategic partners; (v) analytics providers; and (vi) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, California customer records, Commercial information, Internet/Network information, Geolocation data, Inferences, and Other personal information.

Your Rights and Choices.  As a California resident, you may be able to request to exercise the following rights:

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

To Submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account.  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

California’s “Shine the Light” Law. California's "Shine the Light" law (Civil Code Section § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes.  

8.   YOUR NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@globekeeper.com or visit www.globekeeper.com/opt-out.

9.  HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@globekeeper.com

Part 2 – Privacy Policy for EEA and Swiss users

This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access our Service from the European Economic Area, Switzerland or the UK.

This Part 2 of the Privacy Policy was last modified on April 16, 2021.

GlobeKeeper, Inc is the data controller of the personal information we hold about you.

 

1.  PERSONAL INFORMATION WE COLLECT ABOUT YOU

1.1  We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service.

1.2  We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

1.3  The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.

1.4  We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.

1.5  The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

1.6  We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

1.7  We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.

1.8  We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

 

2.  RECIPIENTS OF PERSONAL INFORMATION

2.1  We may share your personal information with the following:

(a) Others in your GlobeKeeper Organization or other GlobeKeeper Company: we may share your personal information, including your name, location and driving event data, with other users of our Service at your request and in accordance with your settings and preferences.

(b) Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, bot detection, web hosting, or providing analytic services.

(c) Third parties that provide features you use in connection with the Services: With your consent or on your instruction, we share personal information, including contact information and location data, with third-party partners that provide certain features and services you elect to use through or in connection with our Service. For example, we may provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. Similarly, we may share personal information with third parties that you have connected to your GlobeKeeper account to facilitate the features or services, such as Google if you have enabled the GlobeKeeper Action on any Google Assistant-enabled device. Any information provided to these third parties will be governed by that third party’s own privacy policy.

(e) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(f) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of GlobeKeeper, its users or others.

2.2  Annex 1 and Annex 2 contain further information about some of the parties with which we may share your personal information.

3.  YOUR LOCATION

3.1 We collect information about your location in order to provide you certain functionalities of the Service.

3.2 We will collect your location where it is necessary for the purposes of providing you with the location-based services features of the app as well as for the legitimate interests of GlobeKeeper or our business partners, such as for data analytics into safe driving modelling. Where you have given us your consent to do so, we may also sell your location data to third parties for marketing and research purposes.

3.3 You can turn off location sharing in one or more of your Companys – if you do so, we will continue to collect your location information in order to provide you the Service.

3.4 You can also stop sharing your location with us at any time by updating the settings on your mobile device to limit the app's access to your location information. Please note, however, that we may not be able to provide all of the functionalities of our Services to you if you disable access to location data.

3.5 If you no longer want to continue using the Service, uninstalling the GlobeKeeper app or logging out from the Service will also stop us from collecting your location.

4.  MARKETING MESSAGES AND NOTIFICATIONS

4.1 From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

4.2 We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.

4.3 You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

4.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.

5.  STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

5.1  Security. We implement appropriate, commercially reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

5.2  International Transfers of your Personal Information. As we are located in the USA, any information we collect from you will initially be collected and stored in the USA. If you are in the EEA, Switzerland or the UK, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with applicable EEA and UK privacy law and this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.

5.3  Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union countries (including Lichtenstein, Norway and Iceland) and Switzerland transferred to the United States pursuant to the Privacy Shield ("Privacy Shield"). We have certified that we adhere to the Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement and liability ("Principles") with respect to such data. If there is any conflict between the policies in this policy and the Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. As of September 2020, the E.U.-U.S. Privacy Shield has been invalidated. Nonetheless, we have committed to adhere to these Principles with respect to the protection of personal data to ensure that your personal information is treated securely and in accordance with applicable laws.

5.4  Onward Transfer. Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage. In certain situations, we may also be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

6.  USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

6.1  In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

6.2 If you wish to exercise one of these rights, please submit your request through the GDPR Rights for EU Users section of your in-App Settings and click on the option to “Download all data,” “Erase account,” respectively.

6.3 You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection and sharing of your driving event data and movement data, by updating your in-App Privacy Settings. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of motion data or driving event data.

6.4 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

7.  CONSENT

7.1 We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.

7.2 We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.

7.3 If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.

7.4 Where we share your personal information with your consent with third parties for marketing and related purposes, you may withdraw consent at any time via our in-app Privacy Centre.

8.  COOKIES AND SIMILAR TECHNOLOGIES

8.1 Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.

8.2 Please see our for more information about the cookies we use on our website, and how to manage cookies.

8.3 Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

9.  JURISDICTION AND ENFORCEMENT

9.1 As part of our participation in the Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

9.2 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

10. CONTACT GLOBEKEEPER AND RECOURSE

10.1 In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at privacy@globekeeper.com.

10.2 In the event that you are concerned about how personal information you have provided to GlobeKeeper has been used, please address your inquiry or complaint first to us at the address listed above. GlobeKeeper takes all concerns about privacy and use of personal information very seriously, and shall endeavour to reply to you within 45 days of receiving a complaint.

10.3 We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism provided by JAMS. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information and to file a complaint. This service is provided free of charge to you.

10.4 If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshieldfiling.html for more information and to file a complaint.

11.  LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

12.  CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

13.  NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

14.  CONTACTING US

14.1 Please contact privacy@globekeeper.com if you have any questions, comments and requests regarding this Privacy Policy.