Who We Are: This Privacy Policy (“Policy”) applies to Globfone telecommunication service which hereafter is referred to as “Globfone”, “we” or “us”, etc. Globfone is a company/partnership/sole proprietorship registered in Poland with its registered office at Druskiennicka 27, Gdynia and registration number KRS 220929702.  Globfone provides affordable text messages, VoIP calls, text and video chat as well as peer-to-peer file sharing services (collectively, “Services”). Globfone believes in fairness, transparency and accountability in the collection and use of personal information.  In this spirit, we have created this Policy to explain our approach in processing personal information in connection with globfone.com (hereafter the “site”) and the choices you can take to access and/or control your information.  For the purpose of clarity, “processing” of personal information, as used in this Policy, means the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. This Policy also applies to such personal information we collect via our digital platforms including this website and our Globfone mobile application (“App”), software and advertising networks or services. Globfone has a designated Data Protection Officer who can be contacted at: dpo @ globfone.com .

By using our website and Services, you represent 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 do not agree with the way we process personal information, and by extension, this Policy, we advise that you do not use the Site and Services. This Policy also accounts for data protection obligations under the General Data Protection Regulation (EU) No 2016/679 of the European Parliament and Council (GDPR) and constitutes a binding legal agreement in terms of article 28 of GDPR.

Information we collect:  We collect certain information in order to make our Services and Site to function effectively and provide you with best possible experience as well as meet our legal and contractual responsibilities. Some of this information is provided directly by you including for example when you register via the App, fill in an online purchase order form, and subscribe to our newsletter, buy a product in our web shop or contact customer support. Information you provide to us may include:

• Name
• Avatar
• Email address
• Mailing address
• Telephone number
• Country and/or city of residence.

We also receive certain information concerning your interaction with our services and products including through the use of cookies and other technologies on the website as well as information to which we have access to via the device you are using to access the service or App. This information may include:

• IP address
• Device information,
• Page views
• Language setting,
• Notifications details.

Information from App Usage: We may also collect information from your usage of our Globfone Mobile App. This data may include text message content, activity logs, call history details, short message service (SMS) activity report.
Information from third parties: We may also collect information from third parties. These third parties may vary over time but generally includes:
Social medial networks, when you grant our App or Service access to your information in one or several social media networking services for example if you choose to identify you through Facebook, Twitter or Google+.

Third-party services providers: Globfone may receive personal data from who help us to improve or deliver our services including, for example, partners we cooperate with in marketing, advertising, technical support and maintenance, payment processing, web analytics and information search services.

Globfone maintains a register of the Personal Data that it processes in accordance with this Policy (“Register”). You are not compelled to provide any information to us.  We rely on your consent to collect personal information and you can withdraw your consent any time. We are also under no obligation to verify the accuracy of our source from which personal information is provided.  If you believe that your information was obtained by us unlawfully please contact us at dpo @ globfone.com and we will remove or restrict the processing of such information.
If you do not provide information necessary to obtain access our service or certain function, there is a risk that you will not be able to use specific services or functionalities.
The kind of information that Globfone collects depends on the context of your interaction with us, your choices, including your device’s privacy settings and those aspects of our services, website or App used by you.
Cookies:  Our App and website uses cookies to make them work better, improve and personalize user experience and for advertising purposes.  A cookie is tiny text-string file saved on to the user’s device by a web server upon visiting the site. Cookies contain information about the site of origin and duration of expiry of the cookie. Some cookies are only active when you browse the site or app and disappear immediately when you exit the site or App (“session cookies”) and other cookies may remain in the user’s device until their specific expiry period (“persistent cookies”).  We use cookies to : remembering your previous interaction with our Website and App including your preferences and settings;  remember if you have already filled in a survey or participated in other site activity;  manage the number of times you’re shown a particular advertisement; as well, provide information that’s relevant to content, products or services that you have shown interest in.

Third-party cookies and web tracking technologies:   Globfone also uses third party services and may feature links to external websites. These services include Google Analytics, Google AdSense, Google AdWords, Google Firebase as well as Facebook Fan pages.  Google Analytics helps us to measure, record and analyse web traffic to our site and user interaction on the site so as to improve performance, interface and functionality. Google AdSense helps us deliver and target ads basing on user’s previous interaction with our website as well as other websites using Google AdSense.  Google AdWords help us to track conversions and measure the effectiveness of our ad and marketing campaigns. If you use or App or website or if you follow any of the links available on the site, these third party services and websites may set and use third party cookies on your devices.   These cookies are used to deliver personalized ads and content as well as control the number of times the ads is displayed to a user. Third party services may also associate your browsing activity with information about what is being accessed by other users, into interest groups, and then used to show you advertisements based on those interests (online behavioural advertising). Globfone is not responsible for privacy practices of third party services. To understand how to opt-out of Google’s online behavioural advertising and how to opt-out, please read more from Google’s Help and privacy pages at: http://www.google.com/intl/en/policies/privacy/ . To opt out of Google Analytics, you may install the Google Analytics opt-out add-on on your browser, available at https://tools.google.com/dlpage/gaoptout . For more information about Google AdWords advertising, please visit https://policies.google.com/technologies/ads.  To know more about Facebook interest-based ads and how to opt-out, please visit https://www.facebook.com/policies/cookies/

Controlling cookies:  Please note that you can control cookies being downloaded on your devices by adjusting the security or privacy settings of your internet browser to block, accept or clear cookies.  For more information about cookies, visit www.allaboutcookies.org

How Use Information: Globfone uses information collected from users and customers for the following purposes:

• To provide our services (including improvement and personalization), which includes ensuring that our users and customers have access and can use Globfone telecommunication services both through the App and Website. (For example, creating a user account and fulfilling orders and purchasers).
• To provide personalized services or feature of the App or site to a user or customer.
• To ensure that our services are used in accordance with our Terms of Service and in compliance of applicable laws and security requirements.
• To communicate with our users and customers concerning user-/customer relationship, which may include responding to inquiries, complaints or feedback in a customer support mater or marketing communication which is specifically addressed to you, as permitted by the law, and
• To market our services and provide advertising.

Legal Basis for Processing Data

• Consent: We rely on your consent to process your personal data so as to create your user account, provide the specific site services order by you and engage in direct service communication.
• Contractual performance. We will process your personal data to meet any obligation under any legal agreement between you and Globfone.
• Compliance with Legal Obligation. We may process your information as is necessary for complying with any legal order or obligation including for example in connection with requests by law enforcement, juridical process and public regulatory authorities.
• Legitimate interests. We may, in our legitimate, use your information to provide information or promotional communication that we believe is beneficial and reasonably expected by you basing on the existing user or customer relationship with us. We will not process your information under this lawful base if entails high risk to your individual rights and freedoms.

Sharing and Disclosure of Personal Data:
In certain cases it may become necessary for us to share certain information about you in our legitimate concerns with other companies or with other partners who perform or deliver services on our behalf. We may for example share information to third parties we contract to provide web maintenance and support services, marketing and advertising, web analytics as well as assistance to protect and secure our App, Website and telecommunication services where they need access to personal information to be able to provide such services. We may also share personal information in connection with business transfer, merger or acquisition and to our current or potential investors for the App or website. In addition, Globfone may also share or disclose personal information in the following situations:

• To comply with the law.
• In response to requests from law enforcement agencies or public and government authorities.
• To enforce this Policy or Terms.
• To protect the rights, privacy, safety or property of Globfone and/or other users.
• To defend ourselves, exercise our rights or protect ourselves from liability.

Data Retention:
We will keep your information for long as necessary to fulfil the purposes for which it was collected, for example as long as necessary to be able to provide services, improve performance of exiting services, send necessary communications, develop our App and website and fulfil our obligations in accordance with the law. Globfone has also adopted a Data Retention Policy to help in comply with data retention and protection obligations.

Data Security:  Globfone takes appropriate legal, organizational and technical measures to enhance the protection Personal Data against accidental loss or unauthorized processing, acquisition, disclosure or destruction.  The security measures include authentication of employees and contractors suing individual accounts and passwords, restricted access to data stored on our servers and systems basing on employee or contractor role and duties, pseudonymisation and anonymization of IP addresses and other online identifiers as well as maintaining confidentially agreements.

Your Individual Rights:
It is of great importance to Globfone that users understand their rights with respect to information we hold about them. Contact information about how to exercise your rights is provided below.

• Right to withdraw consent for processing of personal data.
• Right to access and request free copy of your personal information
• Right to request for rectification of inaccurate information.
• Right to right to request the deletion of personal information under certain circumstances.
• Right to restrict the processing personal information.
• Right, under certain circumstances, to data portability which means obtaining your personal information , in a structured, general and machine-readable and being able to transmit it other data controllers in such cases where processing is based on consent or performance of contract with you.

International Data Transfers: Globfone uses come products or services that may be hosted or stored outside of your jurisdiction, including outside of the European Union for the purposes of GDPR, which means that Globfone may transfer certain personal data submitted by you through the App or website outside the European Economic Area (“EEA”).  We may transfer data for the purpose of web hosting and maintenance, software maintenance and development, website safety security (detecting and preventing fraud and for the purpose of traffic encryption and email domain authority detection tool), email service , VoIP service, VoIP and SMS sending/receiving service,  bookkeeping and payment processing as well as data processing and analytic service. To ensure that personal data is protected in accordance with this Policy and relevant data protection laws, Globfone has also entered into data processing agreements with third party service providers who process data on our behalf. Globfone shall regularly review the terms of processing of Personal Data by its business partners.

Changes to this Policy: Globfone may change or update this Policy at any time to take into account any change in how we collect, use and disclose information. In the event of important changes, we will as soon as practicable notify you through the email you provided to us. We will also post notice of and the updated policy on a clearly visible and accessible page of this website. We recommend our users to review this Policy regularly because it gives you ways to control how your important personal information is collected and used.

Contact and Complaints:  For any questions regarding this Policy or your rights to access and control of information we hold about you, or for any complaints regarding our data processing activities, please contact us via e-mail at dpo @ globfone.com  or write to us at the address provided below.

Globfone
Data Protection Officer