Privacy Policy

This privacy policy (“Privacy Policy“) explains how information about you is collected, used and disclosed by us. This Privacy Policy applies to information we collect when (i) you access to and use of our Sites, (ii) your access to and use of our Applications, or (iii) your access to and use of our services that link to or reference our Globalcitizen Terms. The Site, Application and other Globalcitizen services together are hereinafter collectively referred to as the “Globalcitizen Digital Platform“. The Privacy Policy is intended to meet our duties of transparency under the “General Data Protection Regulation” or “GDPR“.

By downloading, accessing, using and/or interacting with our Globalcitizen Digital Platform®, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the terms of service available at www.globalcitizengital.com/policy (our “Globalcitizen Terms Policy“) and is subject to the provisions of the Globalcitizen Terms. Capitalized terms (including “Globalcitizen“, “us“, “we” and “our“) used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our Globalcitizen Terms. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy, you should not use our Globalcitizen Digital Platform®.

Modifications

Because we are always looking for new and innovative ways to help you achieve your goals in connection with the use of our Globalcitizen Digital Platform®, this Privacy Policy may change over time, so please review it frequently. The effective date at the top indicates the last time this Privacy Policy was modified. If we are required by applicable data protection laws to give you enhanced notice or seek your consent for any such changes, we will do so. You can see when this policy was last updated by checking the “last updated” date displayed at the top of this policy. Any revised Privacy Policy will supersede all previous privacy policies.

1. How We Collect Information

We collect information: (i) that you choose to provide to us; and (ii) automatically through your use of the Globalcitizen Digital Platform. If you are a resident of the European Economic Area (the “EEA“), we rely on one of the following legal grounds to process information about you: (i) where we have your consent, (ii) where we have a legitimate interest to do so, (iii) where the processing is necessary for the performance of a contract with you, and (iv) where we need to comply with a legal or regulatory obligation.

2. Information We Collect That You Choose To Provide To Us

We collect information that you choose to provide to us, for example, when you create an account, manage your user profile, participate in any interactive features of the Globalcitizen Digital Platform, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The type of information we may collect includes your name, user name, country, telephone number, email address, postal address, photograph, avatar, password, security questions and answers, details about our products you use, details you provide in respond to surveys about our products and services, information you provide when seeking help from us, billing information, payment card number and account details, forum posts and comments and other contact or identifying information you choose to provide directly.

For your information, the Company has collected, both directly and through third parties, the following categories of personal information about consumers during the preceding twelve (12) month period:

  • Identifiers, such as a real name, postal address, Internet Protocol address, account name, or other similar identifier;
  • Audio – Visual, electronic, visual, thermal, olfactory, or other similar information of a living person;
  • Professional or employment-related information; and
  • Educational information;

3. What Information We Collect Automatically When You Use the Globalcitizen Digital Platform

We automatically collect information about you including:

Device Information. We collect device-specific information when you access the Globalcitizen Digital Platform from a computer, mobile, and/or other device, including your hardware model, operating system and version, unique device identifiers, mobile network information, country of access, crash reports, request and referral URL’s and system activity details.

Academic – Educational Information. We collect course-specific information about your use of the Globalcitizen Digital Platform® during your study, such as login sessions, attendance, live sessions – Lessons video recordings, preview of materials (text, audio and visual) assignment submissions, etc. Through this process you can track your progress and get reports. In case of minors, parents/guardians can track their children’s attendance and performance on the platform.

Use Information. We collect information about your use of the Globalcitizen Digital Platform, including the type of browser you use, the language you prefer, access times, pages viewed, user activity, interactions with other users, your internet protocol address and the page you visited before navigating to the Globalcitizen Digital Platform.

Information Collected by Cookies and Other Tracking TechnologiesWe use various technologies to collect information, and this may include sending cookies, web beacons, Flash Cookies (as defined below), or other tracking technologies.

  • Cookies. Cookies are small data files stored on your hard drive or in device memory that helps us to improve the Globalcitizen Digital Platform and your experience, see which areas and features of the Globalcitizen Digital Platform are popular and count visits. For more information about cookies, and how to disable them, please see Section 11 (Your Choices and Controls) below.
  • Web Beacons. We may also collect information using web beacons (also known as “tracking pixels“). Web beacons are electronic images that may be used in the Globalcitizen Digital Platform or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

4. Information Provided to Us by Third Parties

In addition to the information that we collect directly from you, we also collect certain of your information from following third party sources.

App Stores or Distribution Channels. The Globalcitizen Digital Platform that are distributed through app stores or distribution channels, such as the Apple App Store, Google Play and other Globalcitizen Associates Worldwide, may also request permission to automatically collect other information from your mobile or other device. The Globalcitizen Digital Platform may only collect such information with your authorization in accordance with your device operating system’s permission process.

Mobile Platforms. If you use or access the Globalcitizen Digital Platform on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, your precise location or contact list, and we will collect this information only if you give us your explicit consent.

Third Party Services and User Information. We may allow third parties to serve advertisements in connection with the Globalcitizen Digital Platform, to provide analytics services and provide you with other services, such as social media, rewards programs and tournaments. These third parties may use cookies, web beacons and other technologies to collect information about you on the Globalcitizen Digital Platform and other websites and online services, such as your name, profile picture, email address, your internet protocol addresses, identifiers associated with your mobile device or applications on the device, pages viewed, time spent on pages, links clicked and conversion information. Some of such third party analytics and advertising services may offer you a choice to opt-out of the collection and/or sharing of this information. This Privacy Policy does not apply to and we are not responsible for, third party cookies, web beacons or other tracking technologies. In addition, we may also receive information about you when other users choose to share their contact lists with us. For example, (i) if you create or log into your account through a social media site (such as Facebook and Wechat), we might have access to certain information from that site, such as your name, profile picture, phone number and/or email address in accordance with the authorization procedures determined by such social media site; and (ii) our services utilize the YouTube application programming interfacing services (API Services) as a third party services, and you are agreeing to be bound by the YouTube’s Terms of Service(https://www.youtube.com/t/terms) and Privacy Policy(http://www.google.com/policies/privacy), and API Services Terms of Service(https://developers.google.com/youtube/terms/api-services-terms-of-service) when engaging YouTube content and services through our service.

We have identified the provider names of some of the third-party analytics and advertising services we use. We take no responsibility for the content or privacy practices of any third party services. We encourage you to carefully review the privacy policies of any third party services you access. Please see the links below to learn more about the data practices of our third-party service providers:

  • Google Analytics: google.com/analytics

5. How We Use Your Information

We may use information about you for various purposes, including to:

  • Provide, maintain and improve the Globalcitizen Digital Platform;
  • Provide and deliver the products and/or services you order and send you related information, including confirmations and invoices;
  • Send you communications about products, services, offers, promotions, rewards or events offered by us and other companies and provide news and information we think will be of interest to you;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Respond to your comments, questions, requests and provide customer service;
  • Monitor and analyze trends, usage and activities in connection with the Globalcitizen Digital Platform;
  • Personalize and improve the Globalcitizen Digital Platform and provide advertisements, content, suggested connections and features that match user profiles or activities;
  • Process and deliver contest entries and rewards; and
  • Link or combine with information we receive from others to help understand your needs and provide you with better service.

We retain your data only for as long as necessary to provide the service you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods: (i) mandated by law, contract or similar obligations applicable to our business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records.

NOTE: About Live Sessions (Lessons) Recordings between Teachers and Students
Live sessions are recorded and available for students and teachers within their private Digital Learning Space for (i) Academic, (ii) Quality Control, and (iii) Dispute resolution purposes.

i. Academic Purposes: Both Students and Teachers benefit greatly from the video recordings of their sessions. Students are able to review their past sessions as many times as they want which allows them to remember and fully understand all academic material covered during one or more completed sessions (new vocabulary, grammar, exam techniques etc). Teachers can also and at any time have a clear picture of all materials that have already been taught by them in the past and in what detail, and be sure of what remains to be taught in the future. Teachers can also inform their students for specific sessions they might have to review in order to move on with the course without having to constantly repeat specific topics and fall back on course syllabus, usually at the expense their fellow-students (in case of group lessons)

ii) Quality Control Purposes: Live session video recordings are also sporadically being monitored by Globalcitizen academic advisors and technical staff, in order for them to be able to ensure the highest quality of the Educational Services that are bought from the Students and provided by the Teachers in terms of the application of its unique educational system (Globalcitizen methodology®) as well as the correct use of the educational and other digital tools necessary for the correct conduct of the lessons (procedure for which all Teachers have been fully informed about, trained upon and have accepted to use during their lessons with their students).

iii) Dispute resolution purposes: Students and Teachers can get in various types of dispute between each other and ask for Globalcitizen for intervention on a specific matter. Through the Lesson video recordings that the Globalcitizen admin team will have access to, a number of disputes can easily be resolved eg whether a lesson has been conducted on a specific date and time and for the its total duration as agreed upon, whether the material taught is relevant and up to Globalcitizen standards, plus any dispute for either Teacher of Student ill behavior during lessons.

The Video recordings are available for viewing (for any of the above mentioned purposes) for a total period of 12 months.

6. What Kinds of Information We Share

We will share personal information outside of the Company when we have your consent. We’ll ask for your explicit consent to share any sensitive personal information. We do not share your personal information with companies, organizations, or individuals outside of the Company except the following cases:

  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf, based on our instructions and in compliance with our Privacy Policy and other appropriate confidentiality and security measures;
  • With the Teachers (Globalcitizen Specialists®) of the Globalcitizen Digital Platform in connection with providing Teaching Services to the Students;
  • With other users of Globalcitizen Digital Platform in connection with the social features of the Globalcitizen Digital Platform (for example, your username and profile picture, you have accumulated in the Globalcitizen Digital Platform that may be visible to other users of the Globalcitizen Digital Platform, or information that you provide in your account registration for forum use and your forum comments may be visible to other forum users);
  • In response to a request for information if we believe disclosure is required by or otherwise in accordance with any applicable law, regulation or legal process;
  • To protect the rights, property and safety of the Company or others;
  • Subject to applicable laws, in connection with any merger, sale of company assets or acquisition of all or a portion of our business; or
  • With your consent or at your direction, including if we notify you through the Globalcitizen Digital Platform that the information you provide will be shared in a particular manner and you provide such information.

For your information, the Company has disclosed to third parties or service providers for business purposes the following categories of personal information about consumers during the preceding twelve (12) month period:

  • Identifiers, such as an Internet Protocol address, account name, or other similar identifier;
  • Audio, electronic, visual, thermal, olfactory, or other similar information;
  • Professional or employment-related information;
  • Educational – Academic information; and
  • Consumer profiles based on inferences drawn from the information provided above.

We do not sell any personal information about consumers. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. When we provide this information, we perform appropriate procedures so that the information does not identify you and we contractually prohibit recipients of the data from re-identifying this information to associate the information with you.

7. How We Keep Your Information Safe

We take commercially reasonable security measures to help protect information we collect about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. These security measures may include practices such as keeping your sensitive data on a secured server behind a firewall, and transmitting sensitive information (such as a credit card number) entered while using the Globalcitizen Digital Platform using secure socket layer technology (“SSL“).Unfortunately, however, no security system is 100% secure, and we cannot guarantee that the information we collect from you will be free from unauthorized access by third parties. Unauthorized entry or use, hardware or software failure and other factors may compromise the security of user information. Your password is an important component of our security system, and as a result it is your responsibility to protect your password. Do not share your password with any third parties. If your password has been compromised for any reason, you should change your password immediately.

8. Where We Store Your Information

Your information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United Kingdom, Europe or any other country in which the Company, its subsidiaries, or third party agents operate. If you are a resident of the EEA, we may transfer your information to affiliated entities or third parties to jurisdictions outside the EEA. Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place to allow the transfer of your information across borders outside of the EEA.

9. Our Policies Regarding Children

In case of minors (students under 18), parents/guardians will have to accept the terms of the Globalcitizen Digital Platform® on their behalf through their “Parent account” that is generated upon course enrollment.

Parents/Guardians can also accept terms via email if they don’t want to have a “Parent account” assigned to them (please contact support for details: support@globalcitizendigital.com

10. Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of your information. To easily access, view, update, correct, delete or port your personal data, or to update your subscription preferences, please sign into your account and visit “Account Settings“. Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any of the Globalcitizen Digital Platform purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Globalcitizen Digital Platform.

Push Notifications. We may send push notifications or “alerts” to your device to provide information regarding the Globalcitizen Digital Platform, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications. You may opt-out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you administrative, transactional, or relationship messages, such as those about your account or our ongoing business relations including but not limited to administrative confirmations, order confirmations, important updates regarding the Globalcitizen Digital Platform and notices regarding this Privacy Policy and our Globalcitizen Digital Terms.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us as follows:

  1. For Members that access and use of the Globalcitizen Services:

Online Support: https://support.globalcitizendigital.com/

Email: support@globalcitizendigital.com

12. Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority. Contact details for Data Protection Authorities in the EEA are available here.


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