Who We Are

This Privacy Policy (“Policy”) applies to the services available on Globfone.com and the Globfone mobile applications, hereafter referred to as “Globfone.” Globfone, as the administrator of personal data, is operated by i-Trends Sp. z o.o., a company registered in Poland at ul. Druskiennicka 27, 81-533 Gdynia (“Administrator”). Globfone provides services such as text messaging, VoIP calls, text and video chat, and peer-to-peer file sharing.

Globfone is committed to fairness, transparency, and accountability in the collection and use of personal information. This Policy explains our approach to processing personal information in connection with Globfone.com (hereafter the “Site”) and the choices you can make to access and/or control your information.

By using our website and services, you confirm that you have read this Policy and our Terms of Use, including our use of cookies, and agree to be bound by them. If you disagree with how we process personal information, we advise you not to use the Site or Services.

This Policy is compliant with data protection obligations under the General Data Protection Regulation (EU-GPRD)) and the California Consumer Privacy Act (CCPA), and other international data protection regulations, ensuring robust privacy safeguards and rights tailored to local requirements.

Definitions

User – any person using the Globfone Services.

Services – services provided by the Administrator on the basis of the Regulations of the “Globfone.com” portal.

Cookies – information saved by the server on the User’s computer or other end device in a text file, described in detail in this Policy.

End User – recipient of the message/telephone conversation.

Personal Data – information relating to an identified or identifiable natural person, including but not limited to name, phone number, email address, IP address, and other identifiable information.

Data Controller – the entity determining the purposes and means of processing personal data (i-Trends Sp. z o.o., as the administrator of the Globfone platform).

Data Processor – an entity processing personal data on behalf of the Data Controller.

Third Parties – external entities or organizations that may receive personal data, including service providers, hosting companies, and payment processors, as outlined in this Policy.

Purpose and Scope of Personal Data Processing

The purpose and scope of processing, as well as the recipients of processed data, depend on the User’s actions via the Globfone.com website or the Globfone mobile applications. Personal data is processed solely to deliver requested services, handle complaints, and meet legal or regulatory obligations. No additional personal data is processed without explicit User consent.

Globfone endeavors to enter into additional data protection agreements with its partners wherever possible. However, due to the diverse and changing environment of service providers, it cannot guarantee that all partners will adhere to such agreements. The Administrator ensures that personal data is disclosed only to entities directly involved in service provision. These include:

• Hosting companies: Data is shared based on data processing agreements.
• Service providers: Partners assisting in operational tasks.
• Telecommunications operators: For communication-based services.
• Payment operators: To process payments securely.
• Authorized state authorities: When legally required.

The following personal data and categories may be processed:

Identification Data (processed based on user consent to enable identification and service provision):

• First and last name.
• Phone number.
• Email address.

Technical Data (processed based on the legitimate interest of ensuring platform and user security):

• IP address.
• Browser type and operating system.
• Device information (e.g., unique device identifiers).

Transactional Data (processed to fulfill contractual obligations and comply with legal requirements):

• Payment information provided by payment operator (e.g., PayPal).
• Transaction history and service usage.

Communication Data (processed based on user consent for communication and service delivery):

• Message content (e.g., chats, SMS).
• Phone number.
• Call history (e.g., numbers contacted, time, and duration of calls).

Location Data (to estimate the user’s geographic location, enabling tailored services like language settings, local content, or regional advertisements and to comply with region-specific legal and licensing requirements):

• Approximate location based on IP address.

Usage and Analytical Data (processed based on the legitimate interest in improving services and analyzing platform performance):

• User interaction with the application or website (e.g., pages visited, clicks).
• Anonymized information collected via tools like Google Analytics.

Providing this data is voluntary but necessary for the Complaint resolution, Globfone applications and services usage.

Processing and Storage of Data

The Administrator processes data necessary for the service, including transmission data (e.g., IP addresses, HTTP User Agent, and phone numbers of recipients). While these data points are not used to identify users directly, safeguards are implemented to ensure compliance with GDPR’s principles on data minimization and pseudonymization.

When users provide personal data for complaints or account creation, such data is processed solely for the intended purpose and deleted after resolution. Transmission data is retained in compliance with legal requirements, with retention periods clearly defined and limited to a maximum of six years, as necessary for operational and legal purposes.

User rights

Users have the right to:

• Access their personal data.
• Correct inaccurate or incomplete data.
• Request deletion of data when no longer necessary or if consent is withdrawn.
• Restrict data processing during rectification or objection procedures.
• Transfer data to another Administrator.
• Object to processing for specific purposes, including profiling.
• Withdraw consent for processing at any time.

Requests can be submitted via email or post, and the Administrator will respond within one month unless extraordinary circumstances arise.

Exceptions to the Right to Erasure (“Right to be Forgotten”):
Globfone reserves the right to retain certain personal data, notwithstanding a user’s request for deletion, in the following limited circumstances:

1. Compliance with Legal Obligations: Data may be retained to meet applicable legal requirements, including laws related to anti-money laundering, counter-terrorism financing, combating cybercrime, and maintaining accounting or tax records.
2. Defense Against Legal Claims: Data may be preserved to defend against legal claims or to establish, exercise, or defend legal rights.
3. Prevention of Fraud and Abuse: To protect users and the platform from fraud or abuse, transmission data and system logs may be retained. These records may assist in identifying and addressing suspicious activity, particularly in investigations conducted by law enforcement agencies.

4. Security: Certain data may be necessary to ensure system and user security, for example, to identify and block malware or hacking attempts.

Compliance with CCPA and GDPR

Under the CCPA, California residents have the right to:

• Know the categories of personal data collected, purposes of processing, and third parties receiving their data.
• Request deletion of their personal data.
• Opt out of the “sale” of personal data (not applicable as Globfone does not sell data).

Users can exercise these rights by contacting dpo@ globfone.com. Globfone also adheres to GDPR, ensuring users globally have rights to access, correct, delete, and restrict the processing of their personal data.

Globfone does not sell personal data to third parties. All collected data is used solely to provide and enhance our services, in accordance with GDPR and CCPA requirements.

Data Transfers to Third Countries

Users consent to their data being transferred to servers outside their jurisdiction, including the United States. Transfers are conducted with safeguards, such as:

• Cooperation with entities recognized as providing adequate protection.
• Use of standard contractual clauses approved by the European Commission.
• Application of binding corporate rules.

Globfone ensures data transfers comply with GDPR and CCPA standards.

 

Cookies and Usage Data

Cookies are small text files saved on users’ devices to enhance website functionality and personalize the user experience. The data collected may include IP addresses, browser types, operating systems, and information about website interactions (e.g., pages visited or forms completed). This information helps optimize the website and improve services.

Globfone processes cookie data for the following purposes:

• Remembering user activity: To ensure smooth navigation and retain preferences, such as language or layout settings.
• Enhancing user experience: By storing form or survey responses for future visits.
• Providing anonymous statistics: To monitor website usage and improve functionality.
• Ensuring security: To prevent fraud, errors, and unauthorized access.

Users can manage cookie settings in their browser to block or delete cookies. Disabling cookies may affect some website features. Learn more about managing cookies at www.allaboutcookies.org.

Types of Cookies Used:

1. Strictly Necessary Cookies: Essential for website operation and ensuring user-requested functionalities.
2. Analytical Cookies: Collect data on user behavior to improve the website. (Example: Google Analytics.)
3. Functional Cookies: Store user preferences, such as language or font size.
4. Advertising Cookies: Track visits to display tailored advertisements and measure marketing effectiveness.

Third-Party Tracking Tools: Globfone uses services like Google Analytics, Google Ads, and others to track user behavior and improve the website. For more details or to opt-out:

• Google Analytics Opt-Out
• Google Ads Policies
• Facebook Ad Settings

Globfone is not responsible for third-party privacy practices. For additional control, adjust browser privacy settings to manage cookies and tracking.

 

Final Provisions

Globfone may update this Policy to reflect changes in data processing practices. Updates will be posted on the website. Users are encouraged to review the Policy regularly. For questions or complaints, contact dpo@ globfone.com or the provided address.