Last Updated: February 16, 2024
Globant S.A., its affiliates, and subsidiaries (“Globant,” “we,” “our” or “us”) is a global company that builds technology that transforms businesses to help them reach their full potential. If you are a California resident, please review our California Notice at Collection and Privacy Rights.
Table of Contents
- Scope
- Personal Data We Collect
- How We Use Personal Data
- Disclosures of Personal Data
- International Data Transfer
- Legal Basis
- Cookies and Other Tracking Mechanisms
- Security
- How Long We Retain Your Personal Data
- Your rights as a data subject
- Your Privacy Choices
- Personal data of Minors
- External Links
- California Notice at Collection and Privacy Rights
- Brazilian Privacy Statement
- Changes to this Policy
- Contact us
1. Scope
This privacy policy (“Policy”) explains how we process personal data from customers and visitors to our websites (“Sites”) and users of our services (“Services”) as a controller or business under applicable privacy laws.
When we collect personal data as a processor on behalf of business customers, we process personal data in accordance with our contract with them and their privacy policy will apply.
This Policy does not apply to the personal data of employees or job applicants or to information that is exempt under applicable laws. We may provide additional notices when needed to clarify our privacy practices in specific circumstances.
2. Personal Data We Collect
While the personal data we collect varies depending upon your use of our Services and our interactions with you, we may collect personal data from you, from third-party sources, and automatically in the following circumstances:
Personal Data Collected Directly from You. We may collect the following personal data from you:
- Customer Service and Support. When you contact us for support or other customer service requests, we maintain support tickets and other records of your requests/ related communications. For example, when you use our Contact Us form, we may collect details including your name, country, email address, and the nature of your request. We may also collect your company, job title, and industry if you choose to provide it.
- Communications. We collect the information you provide such as contact information and records of our communications.
- Transaction and Billing Information. We collect information when you purchase a product or Service from us.
- Surveys. When you fill out a survey, we collect your response, which depends on the type of survey, but may include contact information and your satisfaction with a product or Service.
- Events. We also collect personal data related to your registration for and participation in events we host or sponsor.
- Sweepstakes, contests and promotions. If you participate in sweepstakes, contests and promotions that we offer, we will collect your name, age, country of residence, email address, and other registration information related to contests, sweepstakes and promotions. In some jurisdictions, we are required to disclose the name and other personal information of the winners.
- Image / video recording and transcripts. Your image may be captured and/or recorded on video security/monitoring systems when you enter Globant premises or captured during marketing or public filming events/sessions, and/or audio video recording and transcription during meetings.
- Other Information. We may collect other personal data that you consent to or would reasonably expect based on the nature of the circumstances.
Personal Data Collected from Third Parties. We may collect personal data about you from third party sources such as public databases, advisors and agents, affiliates and subsidiaries, Internet service providers, operating systems and platforms, data brokers and analytics providers, advertising and marketing companies, business partners, clients, social media platforms, or other third parties.
Personal Data Collected Automatically. When you visit our Sites or Services, we and third parties may collect personal data including through the use of cookies, pixel tags, and other similar technologies such as:
- Device and Browsing Information. When you visit our Site, we may collect information, which may be considered personal data under certain laws, such as IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique or online identifier, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
- Activities and Usage. We also collect activity information related to your use of the Site, such as information about links clicked, searches conducted, features used, items viewed, time spent on certain pages, your interactions with us, log file information, and other activity and usage information.
- Location Information. We may also collect or derive general location information about you, such as through your IP address.
For more information please review Section 7: Cookies and Other Tracking Mechanisms and our cookie policy page.
3. How We Use Personal Data
Generally, we use personal data for the following purposes:
- Providing Services and Support. To provide and operate our Site and Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, communicate with you, and for similar service and support purposes.
- Communications. To respond to your questions and fulfill your orders and requests; to send you communications, which you have requested or that may interest you; and to notify you of changes to our Services.
- Analytics and Improvement. To better understand how users access and use the Site and Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Site and Services and business operations, to develop our Site and Services and features, and for internal quality control and training purposes.
- Customization and Personalization. To tailor content we may send or display on the Site and Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
- Marketing and Advertising. To send you information about our Services, such as offers, promotions, newsletters and any other information that you sign up to receive; and to manage, analyze, measure and improve our advertising campaigns.
- Planning and Managing Events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
- Research and Surveys. To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.
- Sweepstakes, contests and promotions. To facilitate your participation in sweepstakes, contests and promotions including to communicate with you about your involvement in the sweepstake, contest, or promotion.
- Security and Protection of Rights. To protect the Site and Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our terms or this Policy.
- Legal Proceedings and Obligations. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
- General Business and Operational Support. Related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.
4. Disclosures of Personal Data
In general, we disclose and make available personal data to third parties in the following ways:
- Corporate Affiliates. We may disclose personal data to corporate affiliates as part of our global business operations and for purposes and uses that are consistent with this Policy.
- Processors and Service Providers. We may disclose personal data to our service providers who perform services on our behalf such as IT service providers, hosting providers, email service providers, chat bot providers, call centers, etc.
- Third Parties, Platforms, and Services. We may disclose or make available personal data to third-party platforms and providers that we use to provide or make available certain features or portions of the Site and Services, or as necessary to respond to your requests.
- Marketing & Advertising Networks. We may share information you provide us with advertising networks, search engines, social media platforms, sponsors and/or traffic measurement services, who use this data to improve and measure the effectiveness of our ads and to serve targeted ads to you on third-party websites and platforms. For more information, including how to opt out of interest-based advertising, see Section 7: Cookies and Other Tracking Mechanisms and Section 11: Your Privacy Choices below.
- Third-Party Analytics Providers. We may also engage third-party analytics companies to collect information about how you access and use our Site and Services, to improve our Sites and Services, and for other research and analytical purposes.
- Compliance, governance and legal requirements. We may disclose personal data to comply with legal and compliance obligations and to respond to legal process and related to legal proceedings. For example, we may disclose personal data in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement. We may also disclose information, including personal data, related to litigation and other legal claims or proceedings, for our internal accounting, auditing, compliance, recordkeeping, and legal functions. In addition, we may disclose the names of sweepstakes and contests winners, in accordance with applicable law.
- Business Transfers. We may disclose personal data as part of commercial transactions (e.g., mergers, acquisitions, bankruptcy, or other similar business transactions) and in contemplation of such transactions (e.g., due diligence).
- Business partners. We may disclose your personal data with partners who are co-hosting or organizing an event with Globant.
- Other Disclosures. We may disclose your personal data for other purposes, which we will notify you of and/or obtain your consent when required.
Aggregate and/or Deidentified Data. We may use and disclose aggregate, deidentified, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose, or process deidentified data we will maintain and use the information in deidentified form and not to attempt to reidentify it except where permitted by law.
5. International Data Transfer
Given Globant’s international presence, your personal data may be transferred within and out of the European Economic Area (EEA). Any international transfers of your personal information will be made in compliance with applicable laws and regulations regarding personal data protection as well as complying with all legal confidentiality and security obligations. Your personal data will not be shared with any third parties that do not have authorization for their processing.
To efficiently provide services, some of our service providers (data processors) are located in countries out of the EEA, or if located in the EEA, they may share information with entities out of the EEA.
When we transfer personal data outside of the EEA, to be processed by companies hired by Globant or affiliates or subsidiaries of Globant, we will comply with the EU General Data Protection Regulation and all applicable data transfer regulations. Specifically, all data transfers will comply with appropriate safeguards.
6. Legal Basis
We are entitled to use your personal data based on (i) our legitimate interest such as for research and development, to market and promote our Services, to protect our legal rights and interests, to the extent that your interests or your fundamental rights are not overridden; (ii) your consent to do so for a specific purpose; or (iii) to process your data to comply with a legal obligation.
7. Cookies and Other Tracking Mechanisms
We and other third parties use cookies, pixel tags, and other similar tracking mechanisms to automatically collect information about browsing activity, device type, and similar information within our Site and Services. We use this information to, for example, analyze and understand how you access, use and interact with our Site and Services; to identify and resolve bugs and errors in our Site and Services; to assess, secure, protect, optimize, and improve the performance of our Site and Services; for marketing, advertising, measurement and analytics purposes; and to personalize content on our Site and Services. We may also deidentify or aggregate such information to analyze trends, administer our Site and Services, gather broad demographic information for aggregate uses and for any other lawful purpose.
Cookies. “Cookies” are alphanumeric identifiers used for tracking purposes. Some cookies allow us to make it easier for you to navigate, while others are used to enable a faster log-in process, support the security and performance of the Site, or allow us to track activity and usage data within the Site and across websites.
Pixel Tags and Similar Technologies. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. We may use these tracking technologies to understand users’ activities, help manage content and compile usage statistics, and in emails to let us know when they have been opened or forwarded so we can track response rates and gauge the effectiveness of our communications.
Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third party companies to evaluate usage of our Site. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Site to provide us with reports and metrics that help us evaluate usage of our Site, improve our Site, and enhance performance and user experience. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
8. Security
No data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot guarantee or warrant the security of any information collected through our Site and Services. You use our Site and Services and provide us with your personal data at your own risk.
9. How Long We Retain Your Personal Data
Your personal data will be retained until such time as needed to fulfill the purposes and uses for which it was collected as outlined in this Policy. If you request we delete your personal data from our databases, please note we may still retain your personal data as necessary to comply with our legal obligations, regulatory requests, resolve disputes, and enforce our agreements.
10. Your rights as a data subject
You may excercise your rights of access, rectification, deletion, portability, restricting processing and opposing processing by sending a letter to Globant’s address as outlined below, or by sending an email to privacy@globant.com. In case we need to verify your indetity, we may require you to send us a copy of a valid government issued identification document.
In case you consider your request has not been properly responded to you may file a complaint with the competent authority. However, we recommend that prior to filing any complain with the competent authority, you reach out to our Data Protection Officer by sending an email to privacy@globant.com in order to review the specific situation and try, if possible, to find an amicable and efficient solution.
11. Your Privacy Choices
Marketing Communications. We may send periodic promotional emails or other similar communications to you. You may opt-out of these communications by following the instructions provided to you in the communication, such as using the “unsubscribe” option. If you opt-out of receiving promotional content from us, we may still send you communications about your account or any Services you have requested or received from us.
Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Site and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt-out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices tool in order to help control interest-based advertising on apps on your mobile device.
Cookie Settings. You can adjust your cookie settings by clicking“Cookie Preferences” in the footer of our website. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function. If you come to our Site from a different device or from a different browser on the same device, you will need to apply your cookie settings for that browser and/or device as well.
Browser Signals. To the extent required by applicable law, if our Site detects that your browser is transmitting an opt-out preference signal, such as a “global privacy control” (or GPC) signal, we will apply that signal to opt that particular browser on your device out of targeting cookies on our Site. If you come to our Site from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well. We do not respond to do not track signals.
12. Personal Data of Minors
We provide a general audience Site. The Site and Services are not designed for minors, and we do not knowingly collect personal data from minors.
13. External Links
Our Sites and Services may contain links to third-party websites or features. Any access to and use of such linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection of your personal data. You should review the privacy policies and terms for any third-party websites before proceeding to those websites or using those features.
14. California Notice at Collection and Privacy Rights
This section of the Policy (the “California Privacy Notice”) provides additional information for California residents (“you”) and describes our information practices pursuant to applicable California privacy laws, including the California Consumer Privacy Act and the regulations issued thereto, each as amended (the “CCPA”).
In this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This section does not address or apply to our handling of publicly available information or Personal Information that is otherwise exempt under the CCPA.
Categories of Personal Information Collected and Disclosed. The following table identifies the categories of Personal Information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. Depending on how you use the Services, we may collect and disclose the following categories of Personal Information. For more information, please see Section 3: How We Use Personal Data Section 4: Disclosures of Personal Data above.
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Sale and Sharing of Personal Information. Additionally, the CCPA defines "sale" as disclosing or making available to a third-party Personal Information in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may disclose the following categories of Personal Information: identifiers, profiles and inferences, and internet or other electric network activity information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share Sensitive Personal Information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.
Sources of Personal Information. As further described in Section 2: Personal Data We Collect, we collect Personal Information from the following sources: directly from you; advertising networks; data analytics providers; social networks; internet service providers; operating systems and platforms; affiliated entities; and government entities.
Retention. We retain the Personal Information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. We retain Personal Information as necessary to comply with our tax, accounting and recordkeeping obligations, to provide you with the services you have requested, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your Personal Information, we may deidentify or aggregate it and use it in compliance with the CCPA.
Purposes for Collecting, Using, Disclosing, and Processing Personal Information. As more fully described in the Section 3: How We Use Personal Data, we collect, use, and otherwise process the above categories of Personal Information to provide our Services to you, respond to and fulfill your requests, as otherwise directed or consented to by you, and for the following business and commercial purposes: to provide Services and support, communications, analytics and improvement, customization and personalization, marketing and advertising, events, research and studies, security and the protection of rights, legal proceedings and obligations, and general business and operational support.
Sensitive Personal Information. We do not use or disclose of Sensitive Personal Information beyond the purposes authorized by the CCPA.
California Residents Rights. The CCPA provides you with certain rights regarding your Personal Information. Please note that these rights are subject to certain conditions and exceptions.
Right to Know/Request Access. With respect to the Personal Information we have collected about you in the prior twelve (12) months, you have the right to know:
- The categories of Personal Information we collected about you;
- The categories of sources from which we collected your Personal Information;
- The business or commercial purposes for collecting, selling, or sharing your Personal Information;
- The categories of third parties to whom we have disclosed your Personal Information; and
- The specific pieces of your Personal Information we have collected.
Right to Delete. You have the right to request we delete your Personal Information.
Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.
You also have the right to opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. If we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your Personal Information. If you come to our Site or use our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.
Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of “Sensitive Personal Information” that would trigger the right to limit use of Sensitive Personal Information under the CCPA.
Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
Exercising Your Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:
- Calling us at 1-800-921-2240
- Emailing us at privacy@globant.com
Verification. Before responding to your request, we must first verify your identity using the Personal Information you recently provided to us. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
Authorized Agents. You may designate someone as an authorized agent to submit requests and to act on your behalf. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify the identity and the authority of the authorized agent.
15. Brazilian Privacy Statement
Data collected and/or processed in Brazil, or other data processed in relation to people and/or Services located in Brazil, shall be also subject to the provisions of Brazilian General Data Protection Law (Law nr. 13.709/2018 – Lei Geral de Proteção de Dados Pessoais or LGPD). Any requests regarding data protection in Brazil shall be directed to the email privacy@globant.com. Our person “in charge” (encarregado, in accordance with Art. 41, §1º, LGPD) is Mr. Bryan Longo, lawyer at Clasen & Casado Filho Sociedade de Advogados.
16. Changes to this Policy
If we change or update our Policy, we will post those changes on this page. Your continued use of the Site and Services is subject to our most up-to-date Policy, posted here. If we make any material changes, we may notify you by means of a notice on our Site.
17. Contact us
If you have questions or concerns regarding the way in which your personal data is being processed or this Policy, please email us at privacy@globant.com or via the contact information below:
Globant S.A.
37A Avenue J.F. Kennedy
L-1855, Luxembourg
