We are committed to keeping your personal data secure and be transparent about our practices.
We adhere to the industry standard practices to secure information collected from You.

I. SCOPE OF THIS POLICY

13416755 CANADA INC (“Company” or “we” or “us” or “Our” or “Globalogy”), owns, operates and manages a website having domain https://globalogy.in/ (referred as “Platform”). Globalogy provides certain Services to end-users and customers who visit the Platform and/or access the information on the Platform and/or avail Services (defined below) through the Platform who are registered with Globalogy (“users”, “You” or “Your”) which can be accessed, used and availed in accordance with Our terms and conditions of use available at https://globalogy.in/terms-services/ (“Terms of Use”). The Company is engaged in the business of offering a comprehensive job search service wherein the Company assists individuals in applying and pursuing suitable employment opportunities (“Services”) operating under the trade name of ‘Globalogy’. This notice describes how Globalogy and its affiliates collect and use data. This notice applies to all Globalogy users globally. This notice specifically applies to jobseekers those who are seeking a job in a foreign country and looking for courses, work visa and job support services from us.
This notice also governs Globalogy’s other collections of data in connection with its Services. For example, we may collect contact information of job seekers; or data of those who start but do not complete their registrations on our website.
Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

In addition, please note the following:

• If you are an European Territory resident (including UK users), you may have certain additional privacy rights. Visit Appendix 1 for more information.
•  If you are a California resident, you may have certain additional privacy rights. Visit Appendix 2 for more information.
•  If you are a Canada resident, you may have certain additional privacy rights. Visit Appendix 3 for more information.
•  If you are a Quebec resident, you may have certain additional privacy rights. Visit Appendix 4 for more information.
•  If you are an Australian resident, you may have certain additional privacy rights. Visit Appendix 5 for more information.
•  If you are an Indian resident, you may have certain additional privacy rights. Visit Appendix 6 for more information.
•  If you are UAE resident, you may have certain additional privacy rights. Visit Appendix 7 for more information.
•  If you are African resident, you may have certain additional privacy rights. Visit Appendix 8 for more information.

II. GENERAL

This privacy policy (“Policy”) explains how Globalogy and its affiliates collect, use, and disclose
your personal information.

Information We Collect: We collect personal information from you in various ways, including when you:

• Use our websites.
• Use our Services, such as immigration, finance, education, or career assistance.
•  Participate in our webinars or events.
•  Subscribe to receive news or marketing communications.
•  Apply for a job with us.
•  Visit websites operated by our clients. (This applies if we collect your information on those sites.)
•  Fill your information on our lead generation page.
•  Ask us a query
•  Use our immigration calculator.

Purposes of Collection: We use your personal information for legitimate business purposes, such as:

•  Providing our Services to you.
•  Facilitating your immigration, finance, education, or career needs.
•  Sending you news and marketing communications (with your consent).
•  Helping process job applications.
•  Improving our websites and Services.

Legal Basis for Collection: We collect and process your personal information based on various legal grounds, including:

•  Your consent.
•  The need to fulfill a contract with you.
•  Our legitimate interests in operating our business.
•  Dispute Resolution: Your use of our websites and Services, and any privacy-related disputes, are
  governed by this Policy and our Terms and Conditions.

We recommend that you read this Policy carefully to understand how we handle your personal information.

III. WHO WE ARE?

Globalogy is engaged in the business of offering a comprehensive job search service wherein the Company assists individuals in applying and pursuing suitable employment opportunities. This Policy applies to users of Globalogy with headquarters in Canada and its offices around the world. When you visit our Platform or use our Services, your information is controlled by Globalogy.

IV. WHAT WE DO?

Globalogy’s mission is to serve interesting recommendations to you based on what we believe are your educational interests and aspirations, for a global career, better salary, life abroad, and all the other things to help you achieve your goals and dreams. To achieve our mission, we enter into agreements with:

•  Clients
•  Third party vendors/ contractors.
•  Affiliates

V. HOW, WHEN, AND WHAT GLOBALOGY COLLECT?

A. Globalogy gathers your personal information in several ways as follows:

Directly from you during account application and use of Services: This includes any information
you provide when signing up for a Globalogy account and using our Services:

•  such as your Name (first, middle and last names)
•  Profile Name
•  Username
•  Resume
•  Education Details
•  Work Experience
•  Personal Preferences
•  Email
•  Gender
•  Mobile Number
•  Password.

From other users and clients: In some cases, Globalogy may receive limited data about you from other users or clients they interact with on the platform. This could be for purposes like facilitating immigration, finance, education, career assistance, or customer referral programs.

Customer inquiries: When you contact Globalogy for support or with questions, they may collect your contact details and any information related to your inquiry.

Voluntarily provided information: Any personal information you choose to share with Globalogy beyond what's required for the above purposes will also be collected.

Third-party verification sources: To verify your identity, assess risk, and prevent fraud, Globalogy may obtain information from background check companies, credit bureaus, and similar Services.

B. Globalogy also collects automatic data through websites and mobile applications (with your consent where applicable):
Device and browsing information: This includes your device type, operating system, browsing history, IP address, and time spent on Globalogy platforms.
Mobile app data (if applicable): For users with the Globalogy mobile app, additional information like device ID, app activity, and location data (with permission) may be collected.

For more details on how Globalogy uses cookies and similar tracking technologies, please refer to our
Cookies Policy on [●] (“Cookies Policy”).

C. There are a few other specific instances where Globalogy may collect your information:

•  Globalogy affiliates' network registration
•  Providing Services to Globalogy as a contractor
•  Job application process

Types of Information we collect:

VI. WHY WE USE YOUR INFORMATION?

We collect your information to:

Verify your identity and access: This includes confirming your ownership of account with Globalogy through methods like SMS or voice calls (where available).
Provide Services and manage payments: This covers registering you, offering our Services, facilitating payments on our platforms through 3 rd party payment gateway, and keeping you informed about changes or updates. We may communicate through SMS, messaging apps, or push notifications (for mobile app users).
Respond to inquiries and offer support: We use your information to answer your questions, provide requested details, and offer customer assistance (including via SMS or messaging apps, if applicable). Personalize your experience: This allows us to tailor content and information, offer location-based features (where legal), and personalize your experience with our websites and Services. This might involve developing and suggesting new Services or features based on your eligibility.

Send marketing communications (with your consent): We may use your email, phone number (including SMS or messaging apps, if applicable), or mailing address to send newsletters, special offers, or event invitations. We'll only do this if you haven't opted out or haven't chosen to receive such communications. This may also include running contests and delivering prizes.
Advertise our Services (with your consent): Where permitted by law, we may use your information for advertising purposes. This could include promotional emails, online ads, direct mail, or telemarketing (with your consent, if applicable).
Improve our Services: We analyze how users access and use our websites and Services to improve them. This can be done in aggregate or on an individual basis and may involve internal research or online surveys (see our Cookies Policy for more details).
Protect everyone involved: We use your information to prevent fraud, unauthorized activity, abuse, harassment, or other illegal actions involving us or our partners. This also helps us enforce this policy and our Terms and Conditions.
Manage recruitment: We process information from job applications to evaluate candidates, communicate about applications, and explore future opportunities.

VII. WHEN DO WE DISCLOSE YOUR INFORMATION?

We share your personal information with various third parties, such as service providers, regulated institutions like financial entities, affiliated companies, and business associates. The table below outlines both the recipients of this information and the purposes for which it is disclosed.

If you prefer not to have your information utilized for marketing endeavours, or shared with third parties for collaborative marketing efforts, please reach out to us. You can reach to us through various communication channels as specified in the “CONTACT US FOR UPDATING YOUR
INFORMATION, QUESTIONS, OPTING OUT” section below. Additionally, you can opt out of receiving marketing emails from Globalogy by following the unsubscribe link provided in such emails.
If you prefer to prevent your information from being shared with our service providers for their machine-learning algorithm purposes, please reach out to us using the contact details provided in the “CONTACT US FOR UPDATING YOUR INFORMATION, QUESTIONS, OPTING OUT” section below.

VIII. WHERE DO WE STORE YOUR DATA?

All information provided to us is securely stored on our servers or those of our trusted third-party cloud service providers. Payment transactions are encrypted using SSL technology to ensure their confidentiality. If you've been provided with or have chosen a password to access specific parts of our site, it's your responsibility to maintain its confidentiality and refrain from sharing it with others.
While we endeavor to safeguard your personal data to the best of our ability, it's important to note that transmitting information over the internet carries inherent risks. We cannot guarantee the absolute security of data transmitted to our websites; therefore, any transmission is undertaken at your own discretion. Upon receipt of your information, we employ stringent procedures and security measures to mitigate unauthorized access.

IX. CHILDREN’S PRIVACY

Our Services are not directed to children, and you may not use our Services if you are under the age of 16. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

X. CHANGES TO OUR PRIVACY POLICY

We consistently review and update this Policy periodically. Any changes made to this Policy will be communicated to the user by posting an updated version of same on our Platform. These changes will take effect as of the date when the revised Policy is published on our Platform. It’s advisable to check for updates or alterations to our Policy regularly and review it whenever you visit our Platform. We won’t significantly diminish your rights under this Policy without ensuring you are aware of such changes.

XI. CONTACT US FOR UPDATING YOUR INFORMATION, QUESTIONS, OPTING
OUT

If you’re a customer of Globalogy Services and need to revise your personal details, kindly access your “Globalogy Account” to make the necessary updates. Alternatively, you can reach out to us using the contact details provided below. If you’re not a Globalogy Services customer but have shared personal information with us, either directly or through third parties, and wish to make changes, please contact us via the phone number or email address provided. Occasionally, we may reach out to you with special offers via email or other means. If you prefer not to receive such offers, you can opt out by accessing the notification settings page in your “Globalogy Account”, using the unsubscribe link in the email, or contacting us using the information below: 

13416755 CANADA INC

Address: 586 Deerhurst Drive, Burlington, Ontario, Canada

Email: support@globalogy.in 

Web: www.globalogy.in

Privacy Concerns:

If you wish to request the deletion or obtain a copy of your personal data, you can reach out to us anytime on support@globalogy.in.

For further inquiries regarding privacy and personal data, you can also contact our Data Protection Officer at aditya@globalogy.in.

XII. GOVERNING LAW AND JURISDICTION

This Policy will be governed solely by and construed in accordance with the laws of the laws of the Province of Ontario, Canada to the extent mandated by applicable laws or regulations. Any disputes arising from this Policy shall be exclusively resolved in the courts of Ontario, Canada, unless prohibited by law.

Despite the aforementioned provisions, for customers residing in different countries or jurisdictions, this Policy will be subject to and interpreted in accordance with the laws of their respective country or jurisdiction. Any disputes arising from this Policy will be exclusively adjudicated in the courts of the relevant jurisdiction.

XIII. DATA RETENTION

We keep your personal data for the duration necessary to fulfill our legal obligations as required by applicable laws or regulations. Additionally, we may retain it for an extended period, in accordance with our internal policies and procedures, for purposes such as preventing fraudulent activities, managing risks, and enhancing security, to the extent permitted by law.

XIV. DISCLAIMER

All content presented on our websites concerning our Services or any other matter, including links to external sites, is solely for informational purposes and should not be construed as advice, endorsement, or endorsement of such content or websites. While Globalogy strives to furnish authentic and precise content on its websites, it does not guarantee, either explicitly or implicitly, the accuracy, comprehensiveness, timeliness, or suitability of such content. Globalogy assumes no responsibility and disclaims all liability related to the information provided on its websites, including but not limited to any liability for errors, inaccuracies, or omissions.

APPENDIX 1

ADDITIONAL TERMS FOR EUROPEAN CUSTOMERS

[INCLUDING RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”) AND THE UNITED KINGDOM (“UK”)]

In compliance with certain privacy laws, in particular the European General Data Protection Regulation (“GDPR”), Globalogy provides specific additional rights, in addition to the terms outlined in the remainder of the Policy, for individuals who interact with Globalogy such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically and under certain circumstances:

• the right to request information about whether and which personal data is processed by us, and the right to demand that personal data is rectified or amended.
• the right to request that personal data should be deleted.
• the right to demand that the processing of personal data should be restricted.
• withdraw your consent to the processing and use of your data completely or partially at any time with future application.
• have the right to obtain your personal data in a common, structured and mechanically readable format. *
• contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data.
• the right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation.

*Note: There is no fee for obtaining a copy of your personal information, unless your request is unfounded, excessive, or repetitive, in which case we may charge a reasonable fee. We will inform you of any charges before proceeding with your request.

In addition to the above, we reference certain rights for European Territory citizens throughout the main Privacy Policy. Pursuant to the GDPR, citizens from “European Territories” mean the European Economic Area (EEA), the European Free Trade Area (EFTA) and Switzerland. For the purpose of this Privacy Policy, the term “European Territories” shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit. If you are in the UK, or the European Economic Areas, the controller of your data is the authorized representative of Globalogy at Canada.

It is a company established in Canada and regulated for data protection matters by the Office of the Privacy Commissioner (OPC), Canada and for data protection matters please reach out to our Data Protection Officer (DPO) at aditya@globalogy.in with any questions about exercising any of the above rights.

If you are dissatisfied with our handling of your data or our response to a request or concern, you have the option to lodge a complaint with the Office of the Privacy Commissioner (OPC), Canada or your respective local supervisory authority. For further guidance on contacting the Office of the Privacy Commissioner (OPC), Canada, please refer to their website for additional information.

A. WHEN WE SHARE YOUR PERSONAL INFORMATION:

The section titled “How and Why We Share Your Information” within the main body of the Policy under the heading “WHEN DO WE disclose YOUR INFORMATION?” clarifies who we might share your information with, ensuring legal compliance and enabling us to provide you with our Services effectively.

It’s important to note that when you disclose your information, it may be transferred to and stored in countries outside the European Economic Area (EEA), such as the USA and Canada (limited to commercial organizations subject to the Personal Information Protection and Electronic Documents Act (PIPEDA)).

Please be aware that when data is transferred outside the EEA, these countries may not offer the same level of protection for personal data as available in the EEA. To ensure the security of your data, Globalogy implements various measures, including but not limited to:

• Assessing the security measures at any location where your personal data is transferred.
• Implementing suitable contract terms obliging data processors to process data only as instructed.
• Establishing monitoring, reporting, and resolution procedures for ongoing security.
• Employing appropriate safeguards as described in Article 46 of the GDPR, including the use of Standard Contractual Clauses adopted by the European Commission (Article 46.2).
• It’s worth noting that the European Commission has assessed the USA and Canada as providing an adequate level of data protection. 

For further elaboration on the international transfer of your personal data and the protective measures implemented, please reach out to us at support@globalogy.in.

B. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We process your personal information according to the following legal bases, in adherence to applicable data protection laws:

Contractual Necessity: Processing is necessary to fulfill our contractual obligations with you, such as those outlined in the applicable Terms and Conditions for our Services, or to take steps requested by you before entering into such agreements. You may be required to provide personal data to enter into or perform our contractual agreements. Failure to provide such data may result in our inability to fulfill our contractual obligations.

Legitimate Interests: Processing is based on Globalogy’s or another party’s legitimate interests, provided that these interests are not overridden by your interests or rights in safeguarding your personal data. This may include identifying or preventing suspicious or high-risk transactions, conducting internal research and analytics, communicating with you, and informing you about new products and Services. Before processing your personal data for these purposes, we assess the necessity and impact of such processing on your fundamental rights and freedoms, ensuring that it aligns with our legitimate interests without adversely affecting your rights.

Consent: Processing is based on your explicit consent, which you have freely given. As mentioned above, you have the right to withdraw your consent at any time by contacting our Data Protection Officer (DPO) at aditya@globalogy.in.

Legal Obligation: Processing is necessary to comply with a legal obligation applicable to Globalogy.

For data falling within special categories as defined by law, we rely on the following grounds:

• Legal claims require processing to ensure their proper initiation, execution, and protection within the legal system.
• You have provided informed, specific consent for the processing.
• Processing is necessary for reasons of substantial public interest, as stipulated by applicable law.

If you require further information regarding the legal bases for processing your information or the legitimate interests mentioned above, please feel free to reach out to us at support@globalogy.in.

APPENDIX 2

ADDITIONAL TERMS FOR CUSTOMERS OF STATE OF CALIFORNIA 

This Appendix applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

        a) Your California privacy rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information: You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.
• Access: You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion: You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales: If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
• Opt-in: We contractually prohibit our publishing and advertising clients from placing our technology on pages that target individuals younger than 16 years old. If we learn that you are younger than 16 years old, we will be asking for your permission (or if you are younger than 13 years old, your parent or guardian’s permission) to sell your Personal Information before we do so.
• Non-discrimination: You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you Services; increasing the price/rate of Services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

         b) How to exercise your rights

You may exercise your California privacy rights described above as follows:

• Right to information, access and deletion: You can request to exercise your information, access and deletion rights by:
  • calling us on +91 79082 82546
  • emailing us at support@globalogy.in.
• Right to opt-out of the “sale” of your Personal Information: We do not sell your Personal Information in the conventional sense (i.e., for money). However, like many companies, we use Services that help deliver interest-based ads to you. California law classifies our use of these Services as a “sale” of your Personal Information to the companies that provide the Services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you. 

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

         c) Personal information that we collect, use and share

Types of Personal Data Collected and Shared

Our approach to gathering personal data varies depending on our relationship and engagements with you. We outline, in broad terms, the types of personal data (as outlined by the CCPA) we have gathered from California residents, along with the categories of third parties with whom we might share this data for business or commercial purposes. The particulars of which can be found in the sections titled “HOW, WHEN AND WHAT WE COLLECT?” and “How and Why We Disclose Your Information with third parties” outlined in the primary section of the Privacy Policy, titled as “WHEN DO WE DISCLOSE YOUR INFORMATION?”. 

Furthermore, when we utilize, reveal, or handle de-identified data (information that cannot reasonably be linked or connected to an identified or identifiable individual, household, or personal or household device), we will uphold and utilize the data in its de-identified state and refrain from attempting to re-identify it, except for the purpose of assessing the reasonableness and adequacy of our de-identification processes as required by relevant privacy laws.

Origins of Personal Data

Broadly, we might gather personal data directly from you, from other consumers and users of our Services, from advertising networks, and from data analytics providers.

Purposes of Collecting, Using, and Disclosing Information

As outlined in greater detail in the section titled “How and Why We Share Your Information” within the main body of the Policy under the heading “WHEN DO WE DISCLOSE YOUR INFORMATION?”, we gather, utilize, reveal, and otherwise handle personal information for the following business and commercial objectives, as well as per your specific directives:

• Providing Services and support.
• Conducting analytics and enhancing Services.
• Tailoring experiences and personalizing interactions.
• Carrying out marketing and advertising activities.
• Organizing and overseeing events.
• Conducting research and surveys.
• Safeguarding and upholding rights.
• Managing legal proceedings and fulfilling obligations.
• Processing job applications.
• Assisting in business transfers (e.g., during acquisition by another entity).

However, it is important to note that sensitive personal information is only utilized and disclosed when reasonably necessary for the following purposes:

1.  to fulfill requested Services,
2.  to ensure security and integrity, including the prevention, detection, and investigation of security incidents,
3.  to address malicious, fraudulent, deceptive, or illegal activities,
4.  to uphold the quality and safety standards of our Services,
5.  to comply with legal obligations,
6.  to engage service providers acting on our behalf, and
7.  for purposes unrelated to drawing inferences about you. 

We adhere strictly to the CCPA guidelines regarding the use and disclosure of sensitive personal information.

APPENDIX 3

ADDITIONAL TERMS FOR RESIDENTS OF CANADA

In addition to the privacy policy, to earn your trust, we follow ten privacy principles. The principles are based on the federal government’s Personal Information Protection and Electronic Documents Act. 

The following information is necessary according to Personal Information Protection and Electronic Documents Act (PIPEDA) respecting the Protection of Personal Information. It is applicable to Canada customers and website visitors of Globalogy. 

Should you be dissatisfied with how we handle your personal information or our response to a request or complaint, you retain the right to lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC). Further information on how to contact the OPC can be found on their website.

Should you have any inquiries regarding this Policy, please reach out to our Data Protection Officer (DPO) at aditya@globalogy.in .

At Globalogy, we follow the Ten Privacy Principles of the PIPEDA compliance standards as below:

1. Accountability: We are responsible for the personal information under our control. We have specific people who make sure that we stay compliant with the privacy principles. Our Privacy Officer oversees our privacy program, designed to build and maintain trust in our information-handling practices. Protecting the personal information you share with us is vital to our business.
2. Identifying purposes: We explain why we collect the personal information we ask for. When we authorize other parties to collect information on our behalf, they do the same. Please refer the “Why we use your Information?” section of the Privacy policy.
3. Consent: We need your permission to collect, use, and disclose personal information, with some exceptions. The exceptions are determined by law and can include times where legal, medical, or security reasons make it impossible or impractical to seek consent. You can give consent in writing, as well as verbally, electronically, or through authorized representatives. In certain circumstances, it’s also implied.

• Your consent may be given in writing, verbally, electronically, or through authorized representative(s)
• Your consent is also implied or inferred from certain actions. 
• You may withhold or withdraw your consent if there are no legal or contractual reasons to stop you. In some cases, withdrawing your consent impacts our ability to provide you with products and Services. 

4. Limiting collection: We only collect your personal information in fair and legal ways. The information we collect is limited to identified purposes as explained in section II “General” of the Privacy policy.
5. Limiting use, disclosure, and retention: We only use or disclose your personal information for the reasons it’s collected. We use it for other purposes you consent to, or when it is required or allowed by law. We keep the information only for aslong as we need to, or as required or allowed by law. Refer the privacy policy sections VI, VII and XIII.
6. Accuracy: Any personal information that we collect, use, or disclose should be as correct, complete, and up to date as possible for the reasons it is used.

   If your contact information changes, please contact us right away. We make all reasonable efforts to make sure that the personal information we collect and keep in your file is as correct, complete, and up to date as it needs to be for the identified purposes. We will rely on you to give us accurate information and to let us know about any changes.

7. Safeguards: To protect your personal information from intrusion, release, or misuse, we use security safeguards that match the sensitivity level of the information.

   Globalogy commits to protecting your personal information from unauthorized access and use. We use physical, organizational, and technological safeguards that are appropriate for sensitivity of the information.

   Personal information is protected:

   • Physically, by building security measures and physical barriers.
   • Organizationally, by our policies, practices, and access levels
   • Technologically, by using passwords, encryption, firewalls, anti-virus, and anonymizing software.
8. Openness: We make information about our privacy policies and how we manage your personal information available to you.

    

9. Individual access: If you send us a request in writing, we tell you what personal information about you we have, and how we use and disclose it. We give you access to the information, with certain exceptions allowed by law. You may verify the accuracy and completeness of your information and request changes, if appropriate.
   You have the right to access and verify the personal information we keep in our files. You may also request corrections to information, if appropriate.

Depending on the circumstances, we can’t always give you access to all the information. There might be a charge for the personal information you request. If this happens, we let you know. Please refer the Privacy policy for more details.

• Inquiries and concerns: Contact us if you have any questions or concerns about our privacy policies and practices.
  Send a written request to Data Protection Officer (DPO) at aditya@globalogy.in, if you:

• Have any questions or concerns.
• Want more information about who has access to your information.
• Want to know more about our privacy policies and practices.
• Want to review your personal information in our files.

If you have a privacy-related complaint, please visit the Resolve a Complaint page on our website or contact us using the information provided below. We respond to privacy-related complaints in accordance with our complaint resolution process.

APPENDIX 4

ADDITIONAL TERMS FOR RESIDENTS OF PROVICE OF QUEBEC CANADA

The following information is necessary according to Quebec’s Act respecting the Protection of Personal Information in the Private Sector (Law 25) regulations concerning privacy and data protection. It is applicable to Qubec customers of Globalogy as well as website visitors. This information supplements the rest of our Policy.

Should you be dissatisfied with how we handle your personal information or our response to a request or complaint, you retain the right to lodge a complaint with the Commission d’accès à l’information du Québec (CAI). Further information on how to contact the CAI can be found on their website.

Should you have any inquiries regarding this Policy, please reach out to our Data Protection Officer (DPO) at aditya@globalogy.in.

A. INFORMATION COLLECTION, USE AND DISCLOSURE

Types of Personal Data Collected and Shared

Our approach to collecting personal data varies based on our interactions and relationships with individuals. We provide an overview of the types of personal data gathered from Quebec residents, as defined by Quebec’s Act respecting the Protection of Personal Information in the Private Sector (Law 25). Details regarding the categories of third parties with whom we may share this data for business or commercial purposes can be found in the sections titled “HOW, WHEN AND WHAT WE COLLECT?” and “How and Why We Disclose Your Information with third parties” within the main section of our Privacy Policy, titled “WHEN DO WE DISCLOSE YOUR INFORMATION?”

In certain situations, we may collect sensitive personal information, such as health information or financial information, only with your explicit and express consent.

Purposes of Collecting, Using, and Disclosing Information

In the main section of our Policy titled “WHEN DO WE DISCLOSE YOUR INFORMATION?”, we provide detailed insights into how and why we share your information. We gather, utilize, disclose, and manage personal information for various business and commercial objectives, as well as according to your specific instructions:

• Providing Services and support.
• Conducting analytics to enhance Services.
• Personalizing experiences and interactions.
• Conducting marketing and advertising activities.
• Organizing and overseeing events.
• Conducting research and surveys.
• Safeguarding and upholding rights.
• Managing legal proceedings and fulfilling obligations.
• Processing job applications.
• Assisting in business transfers, such as during acquisitions by other entities.
   

Sensitive personal information is only utilized and disclosed when reasonably necessary for specific purposes, including:

1.  Fulfilling requested Services,
2.  Ensuring security and integrity,
3.  Addressing malicious or fraudulent activities,
4.  Upholding quality and safety standards,
5.  Complying with legal obligations,
6.  Engaging service providers acting on our behalf, and
7.  For purposes unrelated to drawing inferences about you.

We strictly adhere to the guidelines set forth by the Law 25 regarding the use and disclosure of sensitive personal information.

Retention

We retain your personal information for at least the duration required to meet obligations under applicable laws or regulations. Additionally, we may retain such information for an extended period, as permitted by applicable law, to prevent fraudulent activities, manage risks, and ensure security, following our internal policies and procedures.

B. Law 25 REQUESTS

The Law 25 affords residents of Quebec specific rights concerning the collection, usage, and disclosure of their personal data, within defined parameters and exceptions.

Exercising Your Rights Under Quebec for Information Requests

You or an authorized representative have the option to lodge requests with us using the methods outlined below: either by calling our hotline at +91 79082 82546  (within Canada) or by utilizing the online form accessible on our websites.

To ensure the validity of your request, we will take measures to authenticate it by cross-referencing the provided information with our records. It is imperative to complete all mandatory fields in our web form to validate your request. 

Subsequently, we will proceed with processing your request based on the personal data within our records that is directly associated or reasonably connected to the information furnished in your request. 

If necessary, we may request additional details to verify or facilitate processing your request. In instances where we encounter challenges in adequately verifying a request, we will promptly notify the requester. 

Authorized representatives are permitted to act on behalf of another individual; however, they must furnish evidence of their authorization. Additionally, we may require the relevant consumer to directly confirm their identity and authorize the designated representative.

Under Quebec’s Act respecting the Protection of Personal Information in the Private Sector (Law 25), residents of Quebec are entitled to the following rights, subject to certain limitations and exemptions:

1. Right to Information/Access: You can request information concerning the collection and utilization of your personal data, including:

• Categories of personal data collected.
• Sources of the collected personal data (e.g., cookies, third parties).
• Business purposes for collecting, selling, or sharing personal data.
• Categories of third parties with whom personal data has been shared.
• Specific pieces of personal data collected (also known as a data portability request).
• We assure you that we do not sell your personal data. If your personal data hasn’t been disclosed for business purposes, we will inform you. If it has been disclosed for business purposes, we’ll provide a list specifying the personal data categories obtained by each recipient category.

2. Opt-out of Sales and Sharing: You have the right to opt-out of the sale or/and sharing of your personal data (information and details). Similarly, we will inform you if your personal data hasn’t been disclosed for business purposes. If it has been disclosed for business purposes, including direct marketing, we’ll provide a list specifying the personal data categories obtained by each recipient category.

3. Limitation of Uses and Disclosure of Sensitive Personal Information: Quebec residents can restrict our use or disclosure of sensitive personal information to those authorized by the Law 25.

4. Deletion: You can request the deletion of any personal information collected and retained, subject to certain exceptions and verification. Your request may be denied if retaining your information is necessary under one or more exceptions listed in the Law 25.

5. Correction: You have the right to rectify any inaccurate personal information we hold about you.

6. Non-discrimination: You are entitled not to face discriminatory treatment for exercising your rights under the Law 25.

C. WE DO NOT SELL OR SHARE YOUR PERSONAL DATA (INFORMATION & DETAILS)

We refrain from trading or distributing personal information or sensitive personal information as per the definitions outlined in Law 25. However, we do allow third parties to collect certain details about your activities if you consent to accepting cookies. Your personal information may be disclosed to our service providers or as instructed by you to facilitate our Services, as elaborated in the section titled “WHEN DO WE SHARE YOUR INFORMATION?”

In this context, “sale” denotes the disclosure or provision of personal information to a third party in exchange for monetary or other valuable benefits, whereas “share” encompasses the disclosure of your personal information to a third party for cross-context behavioral marketing purposes.

For further insights into our privacy practices, please consult the “CONTACT US, QUESTIONS, UPDATING YOUR INFORMATION, OPTING OUT” section for information on how to get in touch with us.

APPENDIX 5

ADDITIONAL TERMS FOR AUSTRALIAN RESIDENTS

When we collect and use personal information about you, we may be subject to the applicable laws including the Privacy Act 1988 (Cth) (the Privacy Act). We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act. Below you will find the additional specific provisions applicable to you as a residents or data subject within Australia.

DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENT

We may disclose your personal information to a third-party service providers and related body corporates located outside Australia for the purposes indicated in the privacy notice. Please note that some of our third-party service providers may include cloud-based service provider who may store and process personal information in the cloud within or outside Australia. GLOBALOGY or its related body corporates may, for the purposes indicated in the privacy notice, store, process or use your personal information on the cloud located within or outside Australia. It is GLOBALOGY’s policy which requires GLOBALOGY to share your personal information overseas in a way that requires the strictest privacy and security standards, during transit and at the overseas location. We take reasonable steps to ensure that the overseas recipients of your personal information are bound by a substantially similar or comparable privacy standards.

SENSITIVE INFORMATION

If it is necessary to provide specific Services to you, we may collect and use an information about you which is sensitive information under the Privacy Act. Under the Privacy Act, “sensitive information” includes but is not limited to information or an opinion about an individual’s racial or ethnic origin, religious belief, or criminal record and also includes health information about an individual. However, we will only collect and use sensitive information from you if you agree to provide it to us, you authorize us to obtain it from a third party or where the collection of the information is required or authorized by or under an Australian law or a Court/Tribunal order or otherwise where the collection is not prohibited under the Privacy Act. We will only use sensitive information in accordance with the Privacy Act and for the purpose for which it is provided.

Additionally, we may gather, use, and disclose certain sensitive personal information like financial and health information about you, including but not limited to:

• Identification details such as name, date of birth, addresses, employer, and driver’s license number;
• Credit application details, including the amount and type of credit applied for;
• Information about current and previous credit providers, defaults, court judgments, and insolvency status;
• Own assessments of your physical, mental, and financial health.

We may share some of this information with the third parties, who may in turn disclose it to other service or goods providers for their own assessments. The third parties may utilize and may also need to verify your identification documents through the Australia Document Verification Service (DVS).

If you believe we have breached your privacy rights or our policy, we will promptly address your concerns and provide details of the handling process within 30 days. 

YOUR RIGHTS

Changes to your personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information: You can contact us by email and request access to your personal information. In normal circumstances, we will give you full access to your personal information, however there may be some legal or administrative reason to deny you access (for example, where providing access would result in a serious threat to person’s safety or where the access would be unlawful) – in which case we will tell you our reason for the refusal.
• Request correction of your personal information: You may request amendments or corrections, if your personal information is inaccurate, irrelevant or outdated, or incomplete.
• Data portability: This enables you to ask us, in certain circumstances, to provide you with the personal information you have provided to us in a structured, commonly used and machine-readable format or to transmit the personal information that you have provided to us to another party. We will give access to the personal information in the manner requested by you if it is reasonable and practical to do so.

WHAT WE MAY NEED FROM YOU

If you exercise one of the above rights, we may need to request specific information from you to help us confirm your identity and that you are entitled to make such a request. This is to ensure that personal information is not disclosed to any person who has no right to receive it.

PRIVACY STATEMENT ENQUIRES AND COMPLAINTS

We have appointed Data Protection Officers (DPOs) to oversee compliance of GLOBALOGY with applicable data protection laws and with this privacy notice. If you want to exercise one of the above rights in connection to your personal information or if you have any queries or complaints about our privacy notice or how we handle your personal information, please contact our DPO by writing to us at aditya@globalogy.in.

If you believe we haven’t addressed your privacy concerns adequately, you can file a complaint with the Office of the Australian Information Commissioner (OAIC). Details for contacting the OAIC are provided below:

Website: https://www.oaic.gov.au/

Address: GPO Box 5218 Sydney NSW 2001 (Note: This is for postal mail only)

Fax: +61 2 9284 9666 (Note: Fax is not a common method of communication anymore)

Email: enquiries@oaic.gov.au (**Preferred method for general inquiries)

Additional Information: You can also use the OAIC’s online complaint form: https://www.oaic.gov.au/privacy/privacy-complaints

APPENDIX 6

ADDITIONAL TERMS FOR INDIAN RESIDENTS

This Policy shall apply to any person who visits, browses, uses or accesses the Platform or uses any Service on the Platform. This Policy is an electronic record in terms of the Information Technology Act, 2000 and rules made thereunder. Further, this electronic record is generated by a computer system and does not require any physical or digital signatures. This Policy is published in compliance with The Digital Personal Data Protection Act, 2023 and Section 43A of the Information Technology Act, 2000. Any new features and/or Services that are added to Our current service at any point in the future shall also be subject to the terms set out in this policy. All the Users who access the Platform will be bound by the Privacy policy to the extent applicable to them and by clicking on the “I Accept” button during registration in the Platform, You accept this Privacy Policy and agree to be legally bound by the same.

• INFORMATION COLLECTION, USE AND DISCLOSURE

1. Our approach to collecting personal data varies based on our interactions and relationships with individuals. Details regarding the categories of third parties with whom we may share this data for business or commercial purposes can be found in the sections titled “HOW, WHEN AND WHAT WE COLLECT?” and “How and Why We Disclose Your Information with third parties” within the main section of our Privacy Policy, titled “WHEN DO WE DISCLOSE YOUR INFORMATION?”
2. In certain situations, we may collect sensitive personal information, only with your explicit and express consent.

• YOUR RIGHTS

1. You can always choose not to provide the requested information to us for the purposes mentioned in this Privacy Policy, it may however result in You not availing certain features if, or the entirety, of our Services.
2. You have the following rights:

• access, confirm, and review Personal Data you may have provided;
• correct Personal Information that may be inaccurate or irrelevant;
• update and erasure of your Personal Data from the Platform;
• redress your grievances, if any;
• withdraw your consent, in which case we will cease processing your personal data obtained based on your consent
• right to appoint a nominee to exercise the rights on your behalf in the event of your death or incapacity to exercise your rights.

• In order to exercise these rights or raise your concerns (if any) related to our handling of your personal data, please contact us at the email address provided in Clause 3.3 above. 
• If you withdraw/object your consent, our use of your information before you withdrew/objected shall continue to be lawful.

• DISCREPANCIES AND GRIEVANCES WITH COMPANY:  In case of any discrepancy or grievance with respect to all or any Information shared with Company, please feel free to contact our Data Protection Officer:

1. Name: Aditya Kumar Khetan
2. Designation: Director
3. Email ID: aditya@globalogy.in 

Please feel free to reach out to us by e-mail at support@globalogy.in in case of any concerns, grievances, or questions relating to our privacy or data related practices.

APPENDIX 7

ADDITIONAL TERMS FOR UAE RESIDENTS

This Policy outlines how we collect, use, disclose, and protect your personal information in accordance with the applicable data protection laws of the United Arab Emirates (UAE) (“State”), including the Dubai International Financial Centre (DIFC) Data Protection Law and the Abu Dhabi Global Market (ADGM) Data Protection Regulations.

1. INFORMATION COLLECTION, USE AND DISCLOSURE

Our approach to collecting personal data varies based on our interactions and relationships with individuals. Details regarding the categories of third parties with whom we may share this data for business or commercial purposes can be found in the sections titled “HOW, WHEN AND WHAT WE COLLECT?” and “How and Why We Disclose Your Information with third parties” within the main section of our Privacy Policy, titled “WHEN DO WE DISCLOSE YOUR INFORMATION?”

2. YOUR RIGHTS

You have the following rights regarding your personal information:

1. Access: To request a copy of the personal information we hold about you.
2. Correction: To request correction of inaccurate or incomplete information.
3. Informed: To be informed about the purposes of processing, entities inside or outside the UAE with whom data will be shared, and safeguards for cross-border processing. 
4. Object automated decision-making: To object decisions made entirely by automated systems without human involvement.
5. Deletion: To request deletion of your personal information, subject to certain exceptions.
6. Restriction: To request restriction of processing your personal information.
7. Objection: To object to the processing of your personal information for certain purposes.
8. Data Portability: To request a copy of your personal information in a structured, commonly used, and machine-readable format.

To exercise any of these rights, please contact us at support@globalogy.in.

3. DATA BREACH NOTIFICATION

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant regulatory authority within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to your rights and freedoms, we will also inform you without undue delay.

4. INTERNATIONAL DATA TRANSFERS

We may transfer your personal data to countries outside the UAE, DIFC, and ADGM that may not have the same data protection laws as your jurisdiction. In such cases, we will ensure that appropriate safeguards are in place to protect your personal data, such as standard contractual clauses or other legal mechanisms recognized by the relevant data protection authorities.

Personal data may be transferred outside the state under specific conditions:

• Companies in countries lacking data protection laws can transfer data under contracts ensuring compliance with the decree by law’s measures, controls, and requirements.
• Transfer is allowed with explicit consent from the data subject, provided it doesn’t contradict the State’s public or security interests.
• Transfer is permitted when necessary for fulfilling legal obligations or establishing rights in judicial proceedings.
• Transfer is justified to execute contracts between the controller and data subjects or third parties, serving the data subject’s interests.
• Transfer is allowed for actions related to international judicial cooperation.
• Transfer is acceptable when necessary to protect the public interest.

5. CONTACT US

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Name: Aditya Kumar Khetan 

Designation: Director

Email ID: aditya@globalogy.in 

APPENDIX 8

ADDITIONAL TERMS FOR AFRICAN RESIDENTS

This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in accordance with the applicable data protection laws in various African jurisdictions, including but not limited to the Protection of Personal Information Act (“POPIA”) in South Africa and other relevant regulations.

1. INFORMATION COLLECTION, USE AND DISCLOSURE

Our approach to collecting personal data varies based on our interactions and relationships with individuals. Details regarding the categories of third parties with whom we may share this data for business or commercial purposes can be found in the sections titled “HOW, WHEN AND WHAT WE COLLECT?” and “How and Why We Disclose Your Information with third parties” within the main section of our Privacy Policy, titled “WHEN DO WE DISCLOSE YOUR INFORMATION?”

2. LENGTH OF TIME WE STORE YOUR PERSONAL INFORMATION 

In line with the POPIA, Globalogy will retain your personal information for as long as it is necessary and discard it once it has fulfilled the purpose of its collection. However, there are exceptional circumstances to this, and we may keep your information for a longer time in the following cases:​

1. When we are legally required to do so: We may continue to hold your personal information when required or authorised to do so by South African law.
2. When we are reasonably required to: We may need a record of your personal information for legal reasons relating to our activities and operations, depending on the situation.
3. When a contract requires it: There may be cases where, for example, we require clients’ personal details such as their contact information to fulfill the terms of their contract with us.
4. Consent: We may retain records of your personal information when you voluntarily give us informed consent.

3. YOUR RIGHTS 

You have the following rights regarding your personal information:

1. To be notified: when personal information about them is being collected.
2. Access: To establish whether a responsible party holds their personal information and request access to it 
3. Correction: To request the correction, destruction, or deletion of their personal information when necessary
4. Objection: To object, on reasonable grounds related to their particular situation, to the processing of their personal information at any time for purposes of direct marketing
5. Personal Information: Not to have their personal information processed for direct marketing through unsolicited electronic communications
6. Complaint: To submit a complaint to the regulator regarding interference with the protection of their personal information or a determination of an adjudicator
7. Institute Civil Proceedings: regarding alleged interference with the protection of their personal information.
8. Object automated decision-making: To object decisions made entirely by automated systems without human involvement.

To exercise any of these rights, please contact us at support@globalogy.in.

4. TRANSFER OF INFORMATION

We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.

The requirements for international data transfers, states that responsible parties cannot transfer personal data to a foreign country unless:

• The third-party recipient is subject to a law, binding corporate rule, or other agreement that upholds POPIA principles.
• The data subject consents to the data transfer.
• The transfer is necessary for the performance or conclusion of a contract.
• The transfer benefits the data subject, and it is impractical to obtain their consent, or they would likely give consent if asked.

5. PERSONAL DATA REMOVAL REQUEST

If you have any inquiries about this privacy policy notice, require further explanation about POPIA, wish to make changes or corrections to your personal information, or want to withdraw your consent, kindly contact Globalogy at support@globalogy.in or +91 79082 82546.