Effective Date: September 5, 2019
General Privacy Notice
This Privacy Notice covers all processing of personal data that Global LT engages in, with the exception of HR data. If you are an employee, a prospective employee or a former employee and would like to find out more about how we protect your data, please see the employee privacy notice available on the Global LT internal SharePoint or contact Privacy@Global-LT.com.
WHO WE ARE
We are Global LT, Inc. and our global Headquarters are located at 1871 Woodslee Drive, Troy, MI 48083, United States. You can reach us by telephone at 1 (888) 645 5881. We also have offices in London, Shanghai and Hong Kong. See a list of contact details HERE.
Global LT has appointed a global Data Protection Officer, who can be contacted at Privacy@Global-LT.com.
If you are a student or assignee, we are a processor/service provider in relation to your personal data, acting on behalf of and at the instructions of your employer to provide training, destination services or translation services.
If you are a trainer, teacher or destination consultant, we act as controller for the personal data we have to manage your relationship with us and the services you provide on our behalf. We also act as controller for the personal data of visitors collected through the use of our website and for personal data processed for our marketing campaigns.
CATEGORIES OF PERSONAL DATA WE PROCESS AND FOR WHAT PURPOSE
By personal data we understand any information that relates to an identified or identifiable individual. We collect personal data that you directly provide to us, as well as personal data about you that we obtain from other sources.
Depending on the context in which we process your personal data, we collect and otherwise process:
When we act as controller for personal data of prospective teachers, trainers, consultants
- Identification and contact information, biographical data, geographical location for the purpose of contracting your services; you may submit this personal data to us, or we may collect this personal data from your public professional profile to contact you.
- Background check information for all successful prospective teachers, trainers and consultants that work with children, to ensure the safety of students and assignees.
When we act as controller for personal data of teachers, trainers, consultants
- Identification and contact information, geographical location, language skills and level of experience for being able to match you with open jobs;
- Banking information, for managing payments;
- Reviews made by students or assignees related to your work, for ensuring high quality of services for our clients and for defense for legal claims;
- A history of all your completed and ongoing tasks, for payment and audit purposes;
- Username, passwords and logs related to your use of the GLTPortal, for the administration of your tasks.
- E-mail communications with Global LT staff, for the administration of your tasks.
When we act as controller for personal data collected from website visitors
- Age Range, Gender, Language, City, Country, Continent, Subcontinent, Service Provider, Browser & OS, Device, number of visits and time of visit collected for website visits measurement (via Google Anlyatics).
- The fact that a unique visitor clicked on one of the social media buttons to connect with us through our social media accounts made available on our website (Facebook, Twitter, LinkedIn, Pinterest, Youtube, Instagram), to better engage with our community; we do not have access to, nor collect the username of any unique website visitor that connects with us via social media; the social media platforms you access from the button on our website may further collect and use additional personal information for their own purposes, for which each of them is responsible.
When we act as controller for personal data processed for marketing purposes
- Identification information, contact details and job title of representatives of potential new clients, collected and processed for marketing purposes.
When we act as processor for personal data of students or assignees
- Personal data made available by your employer, such as identification and contact information, current location and relocation destination, office address and job title, civil status, spouse and children related information; we process this personal data on behalf of your employer, who is the entity establishing the purposes and means of this processing.
RECIPIENTS OF YOUR DATA
Global LT does not make your personal data available to any third party other than our vendors and service providers, who process personal data on our behalf and following a strict mandate. The vendors and service providers are prohibited through contractual measures to make this data available to any other entity which is not a sub-processor, they are required to provide adequate security measures and to keep the data confidential.
Global LT does not sell any personal data it collects and processes, nor do we permit such information to be used for reasons other than those for which it was originally provided to us. If this practice should change in the future we will update this notice accordingly and provide opt-out or opt-in choice as appropriate.
We have contracted several vendors and service providers to support different functions of our activity. Specifically, our vendors are:
For all personal data we process:
- Cloud storage providers (US based)
- E-mail services providers (US based)
- Customer Relationship Management services providers (US based)
For personal data of prospective teachers, trainers or consultants working with children
- Background check providers (US based)
For personal data of students and assignees:
- In addition to the third-party service providers mentioned above, we share the personal data of students and assignees with teachers, trainers or destination consultants assigned to their case.
For Web site measurement data:
- Google Analytics
We may also share your personal data with law enforcement agencies pursuant to a lawful and specific request and in any case strictly when required by applicable law, including to meet national security and law enforcement requirements.
According to our retention policy, we only keep personal data in our records as long as they are necessary for the purposes they have been collected and processed for. We adhere to our Records Management Policy to determine how long we retain data, including personal data.
The retention period depends on the context in which we process data:
- We keep student and assignee records as long as required by our clients and in any case no longer than 3 months after our contractual relationship with the client ended;
- We keep information made available for translation services for as long as required by our clients or 6 months after the service was completed;
- We keep teacher or trainer records for 5 years after the last active engagement or until we receive a request for withdrawal from our database;
- We keep prospective teachers, trainers or consultants information for 12 months after an active contracting period ended and they were not extended an offer.
- We keep website visitor information in a non-aggregated form for 12 months.
Subject to limitations imposed by the applicable data protection law to the processing of your data, you have the following rights:
Access, correction and erasure
You have the right to obtain confirmation whether we process or not your personal data, as well as the right to obtain information about the personal data we process about you and to obtain a copy of this data.
You have the right to obtain erasure, correction, restriction and portability of your personal data, under certain conditions and as long as it does not interfere with the establishment, exercise or defense of legal claims.
Right to object
You have the right to object at any time to receiving marketing materials from us by following the opt-out instructions in our commercial e-mails, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to legal obligations.
If there are any processing operations based on your consent, you can withdraw consent at any time and we will stop those processing operations.
Right to equal service and price
You have the right not to be discriminated against by being denied goods or services, being provided a different level or quality of goods and services or being differently charged, if you exercise any of your rights detailed in this Privacy Notice.
You can exercise those rights by contacting us at the contact details mentioned above or by writing an email to Privacy@Global-LT.com.
NOTICE SPECIFIC TO INDIVIDUALS SUBJECT TO THE GDPR
If you are based in the European Economic Area (EEA) or if your personal data is processed by one of our representatives in the EEA, that processing may fall under the GDPR. In addition to the information above, which is fully applicable to your personal data as well to the personal data of individuals who are not subject to the GDPR, the following information only concerns the processing of personal data covered by the GDPR:
Legal basis for processing
- For the processing of personal data of teachers, trainers and consultants, we rely on Article 6(1)(b) GDPR (personal data necessary to enter or for the performance of a contract); for the processing of personal data of prospective teachers, trainers and consultants whose contact details and biographical information we access from their public professional profiles, we rely on our legitimate interests to contract and extend offers to the most qualified collaborators – Article 6(1)(f) GDPR. We balanced our legitimate interests with their rights and considering that the information is publicly available and it has professional character and that contacting them with an offer for collaboration is also in the interest of the individuals, a fair balance is present.
- For the processing of personal data of website visitors obtained through cookies or similar technologies, we rely on consent, as provided by Article 6(1)(a) GDPR and the EU ePrivacy Directive and its transposition laws.
- For the processing of personal data for e-mail marketing purposes, consent – as required by the ePrivacy Directive and its transposition laws.
- For the processing of student and assignee personal data the legal basis of processing is established by the controller of that processing (their employer).
Individuals with questions, feedback or complaints are encouraged to reach out to Global LT directly at Privacy@Global-LT.com. We will make everything possible to address your concern. If you will consider we have not been able to deal with your concern, you have the right to submit a complaint to the Data Protection Authority in the EU Member State of your residence, place of work or an alleged infringement of the GDPR, as granted by Article 77 of the GDPR. For more information on the DPAs and to locate the office that covers your specific region, please go to https://edpb.europa.eu/about-edpb/board/members_en
Global LT values its relationships with entities operating in the regions that comprise the European Economic Area (EEA) and Switzerland. Due to the nature of our services supporting relocation of staff throughout the world, we sometimes transfer personal data of individuals within the EEA and Switzerland towards entities located in countries outside of the EEA and Switzerland. We always make sure that personal data being transferred enjoys appropriate safeguards on the basis of one of the transfer mechanisms provided for by the GDPR and, respectively, the Swiss Data Protection Act.
The Privacy Shield for EU and Swiss Individuals
We transfer all categories of personal data as described in this Notice to the United States, where our servers are located, on the basis of the EU-US and Swiss-US Privacy Shield Privacy Shield Frameworks.
Pursuant to the Privacy Shield Frameworks, Global LT is subject to the following regarding EU and Swiss data that is transferred to the United States:
- The jurisdiction and enforcement powers of the United States Federal Trade Commission
- We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages
- We may be required to release personal data in response to lawful request by public authorities including to meet national security and law enforcement requirements
- We acknowledge the right of EU, and Swiss individuals to access their personal data to correct or delete said information if it is found not to have been processed in compliance with the Privacy Shield principles. Individuals wishing to exercise this right may do so by contacting us at Privacy@Global-LT.com
Privacy Shield Inquiries and Complaints
In compliance with the Privacy Shield Principles, Global LT commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Global LT at:
Global-LT has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
We may also enter Standard Contractual Clauses with our clients for the transfer of personal data subject to specific contracts.
Questions or concerns
If you have any questions or concerns related to the general processing of your personal data, please contact our DPO at Privacy@Global-LT.com.