European Union – Additional Provision

Privacy Policy – (EU Additional Provisions)

In addition to the protections given under this policy, for individuals located in the European Union (EU) (including the European Economic Area (EEA)) that we offer or provide our products or services to, personal information will be subject to Regulation EU (2016/679) – General Data Protection Regulation (GDPR) and the following provisions apply:

• Globeway is the data controller for the purposes of processing personal information.

• Our Privacy Officer is our Data Protection Officer for the purposes of the GDPR.

• We rely on the following legal grounds to process your personal information:

– Contract performance – we may collect and process your personal information to enter into a contract with an individual or to perform our obligations under a contract to which an individual is a party.

– If it is necessary to pursue our legitimate interests and does not override your rights and interests – this is the usual basis on which we carry out our business and manage risk.

– With consent – where required, we will only use your personal information for the purposes for which valid or explicit consent is given.

– To comply with laws that apply to us including exercising our rights – we may use and process your personal information where we are legally required to do so.

Your Additional Rights and Choices

In addition to the above, an individual located in the European Union has the following rights:

• Erasure: You can ask us to erase your personal information without undue delay in certain circumstances such as if you withdraw your consent and we otherwise have no legal reason to retain it.

• Restrictions of processing: You can object to, and ask us to restrict, our processing of your personal information in certain circumstances, such as while we verify your assertion the information is inaccurate or if we are processing your information for our legitimate interests or for direct marketing purposes (we may be legally entitled to refuse that request).

• Data portability: You can, in some circumstances such as where we are processing your information with your consent, receive some personal information you have given us in a structured, commonly used and machine-readable format and/or ask us to transmit it to someone else if technically possible/feasible.

• Right to object: You can withdraw your consent (but we may be able to continue processing without your consent if there is another legitimate reason to do so).

• Right to complain: You can lodge a complaint with the relevant European data protection authority if you think that any of your rights have been infringed by us. If we refuse any request you make in relation to your personal information rights, we will write to you to explain why and how you can make a complaint about our decision.