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Privacy Policy

Effective Date: August 11, 2023

Globant values individual privacy and we want to give our Site's visitors the opportunity to know what information we collect about them and how it is treated by us.

This Privacy Policy (this “Policy”) explains:

  • Information we collect.
  • Purposes of using your personal information and legal basis.
  • Retention of your personal information.
  • Disclosures of personal information.
  • Where your personal information is stored and what your rights are.
  • Additional Disclosures for California Residents
  • Brazilian Privacy Statement
  • Contact us.

INFORMATION WE COLLECT.

• Information collected when setting-up your account.

You will need an account to use and access our Products. Your account may be assigned to you by an administrator, such as your employer. If your account is being assigned to you by an administrator, such administrator (i.e. your employer) will send us certain personally identifiable information about yourself in order to create your account, such as your first name, last name, e-mail address, and related information.

• Widget data.

Other websites may integrate Globant widgets. When you visit a site with a Globant widget or a widget related to any of our Products embedded, we may receive certain information, including information about the web page you visited. Globant and the widget can recognize you when you interact with a widget.

• Content.

Through use of our Services you may create Content that directly provides information about you to Globant, including, for example: all Content that you create, share or post through the Services; communications with other users of the Services.

PURPOSES OF USING YOUR PERSONAL INFORMATION AND LEGAL BASIS.

Globant uses the information collected through our Services to (i) identify Users; (ii) send Users notifications regarding important news involving the Services, like updates or modifications to the Terms of Use; and (iii) notify Users about events related to the Services themselves.

If you contact us regarding identity theft or some other form of unauthorized use of the Services, Globant may disclose pertinent information to law enforcement agencies and other third parties with responsibility and authority.

At all times, however, Globant reserves the right to disclose information where required by law or to comply with valid legal process (such as a search warrant, subpoena or court order), to protect Globant's rights or property, including without limitation in the event of a transfer of control of Globant or substantially all of its assets, or during emergencies when safety is at risk.

We are entitled to use your personal information 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; (iii) to process your data to comply with a legal obligation; or (iv) to process your data for the performance of a contract.

RETENTION OF YOUR PERSONAL INFORMATION.

Globant will retain your personal information for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, and maintain appropriate business records. Once the purpose has been fulfilled your personal information will be retained blocked up due to the possibility of legal and governmental requirements and until their statutes of limitations have run out.

DISCLOSURES OF PERSONAL INFORMATION.

Globant may share your personal information with:

– Related companies. We share information with entities that belong to our corporate group, that operate under the same internal processes and policies, in order to provide services, comply with our internal regulations, prevent fraud, manage risks and facilitate the management and supply Services.

– Service providers. We share information with other companies that we engage to provide services for us or to provide services on our behalf, following our instructions and in accordance with the terms of this Privacy Policy. These services contribute to improving or facilitating transactions. These service providers have access to the information that is necessary for them to provide the services they were hired to provide, and they cannot use that information for purposes other than those agreed to with Globant.

– Business partners. We share information with companies that have a collaboration or alliance relationship with Globant, and that help us develop or improve our activities -and to fulfil the purposes indicated above-, with the purpose of offering promotions, products and services of these companies or co-branded.

You should review the privacy policies and privacy settings of the platforms of these business partners in order to obtain information regarding their data practices and options to manage the information sent to us. Globant is not responsible for the data and privacy practices of its business partners.

– Merger or acquisition. We may share your information and data as part of any process of merger, acquisition or sale of Globant's assets, as well as in the unlikely situation of insolvency, payment suspension or bankruptcy, in which the data should be transferred as one of Globant's assets.

– Public authorities. We share information with administrative and judicial authorities that, exercising their power, require information from Globant, the companies that belong to our corporate group, our service providers and/or our business partners, even if there is no executive or judicial order or citation to that effect, with the purposes of: (a) collaborating in an investigation and reporting fraud, piracy, violations of intellectual or industrial property rights or any other unlawful act, as well as any activity or circumstance that could result in legal responsibility for Globant and/or its users; (b) safeguarding a public interest, procurement or administration of justice, acknowledgement, exercise or defence of a right in a judicial or administrative process, and/or the resolution of disputes; and (c) compliance with any applicable law, regulation or legal provision, or with any well-founded and justified requirement from a competent authority.

WHERE IS YOUR PERSONAL INFORMATION STORED AND WHAT ARE YOUR RIGHTS.

• Storage of the Information.

All of the information collected by Globant through the Services is stored on secured servers, to protect against unauthorized use and access.

Globant may share your information with other companies in the Globant group that are located in countries different than your home country in order to carry out the activities specified in this Privacy Policy.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live.

• Your access rights.

You can exercise your rights as a Data Subject regarding your personal information, by contacting the following address: policy@fluentlab.ai.

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS.

If you are a California resident, the California Consumer Privacy Rights Act 2018 (CCPA) requires us to provide you with certain information regarding the personal information collected by Globant that relates to, or is reasonably capable of being associated with, you as an individual. The below disclosures supplement the information provided in our general Privacy Policy (“Policy”) and describe our information collection practices going back 12 months prior to the date of any Consumer Request submitted in accordance with this supplemental privacy policy.

A) Disclosures Required by CCPA

• Categories of Personal Information we Collect (collectively “Personal Information”)

We may collect Personal Information about you, including, but not limited to: Identifying Information such as your name. Employment Related Information such as the name of your employer and your corporate email.

• Sale of Personal Information

We do not sell any of your Personal Information.

B) Consumer Rights for California Residents

• No Sale of Information

As we do not sell any of your Personal Information, the right to opt out from the sale of personal information does not apply to Information collected by us.

• Right to Know/Access Specific Pieces of Information

With respect to the Personal Information we have collected from you in any 12 months prior to you making a consumer request, you have the right to information about the categories of Personal Information we collected, and, for each category, the commercial purposes of such collection, the categories of sources for such Personal Information, and the categories of parties such information has been shared with, if any. In addition, you have the right to access specific pieces of Personal Information collected about you. You may exercise this right no more than twice in any given 12 months period.

• Right to Request of Deletion of Information

You have the right to require us to permanently delete certain Personal Information that we collected from you. However, this right is subject to a variety of restrictions and exceptions, for example we may have to keep your Personal Data that is necessary for legal and legitimate business purposes, to resolve potential disputes, to make or defend legal claims, to conduct audits and/or to enforce any agreements.

• How to Exercise your Deletion Rights, Right to Know or Right to Access Personal Information

You must make a verified request, i.e., a request indicating what type of right you wish to exercise that allows us to make sure that you are the person authorized to make such a request or a duly authorized agent of such a person. Typically, we need to be able to verify the identity of the person making any such request.

Please contact us by e-mail at policy@fluentlab.ai to communicate your request. We will get back to you within 10 days at the latest to confirm receipt of your request and inform you about the next steps. If we are able to verify your request, we typically provide you with the requested information or otherwise act on your request within 45 days from the date of its receipt. If we are unable to complete the actions required to comply with your request within the ordinary 45 day time period, we will notify you during that time period and provide you with an update, including how much additional time we need to comply with your request.

Under certain circumstances, we are authorized to refuse compliance with your Consumer Request, e.g., if we are unable to verify that you or the person making the request is in fact authorized to do so, your request is manifestly unfounded, or excessive, in particular because of its repetitive character, or if doing so would force us to violate other legal obligations recognized by California law. In each case we will provide you with a written explanation highlighting the reasons for our decision. There is no charge for exercising your Consumer Rights, provided however, that we may impose a reasonable administrative fee taking into account the cost of acting on your request in case your request is manifestly unfounded or excessive.

• No Discrimination for Exercise of Consumer Rights

We will not discriminate against you for exercising any rights you may have as a consumer under CCPA.

• Other California Privacy Rights

California's "Shine the Light" law permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

• Children's Privacy

Our website is not intended for, nor targeted to, children under 13, and we do not knowingly request or collect personal information from any person under 13 years of age. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.

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 policy@fluentlab.ai. Our person “in charge” (encarregado, in accordance with Art. 41, §1º, LGPD) is Mr. Bryan Longo, lawyer at Clasen & Casado Filho Sociedade de Advogados.

CONTACT US.

If you have any question regarding this Policy please contact us at policy@fluentlab.ai