Last Revised April 1, 2020 – Effective Date June 1, 2020
Global knows that you care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with excellent service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. You may email us at firstname.lastname@example.org with any privacy-related questions you have. Please note, email is not a secure method of communication. Please do not send personal information via email.
This Policy applies to all information we collect through our mobile application and website www.ghllc.com/privacy-policy/ from current and former Global users, including you. When you are no longer our customer, we continue to share your information as described in this Policy.
Throughout this Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
THE INFORMATION WE COLLECT
When you visit one of our Sites, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our Sites. We also may collect Geolocation Information (defined below). If you do not agree to our collection of this information, you may not be able to use our Services.
If you open a Global account, we may collect the following information from you or the organization responsible for administering your program (the “debt settlement provider”):
- Account Information – username, password, machine or mobile device ID, and other similar information.
- Identification Information – your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
- Device Information – information about you: (a) from your mobile device such as your device type, machine or mobile device identification number, geo-location, time zone, language setting, browser type, and IP address.
- Fraud Protection Information
- Financial Information – bank account information, bank account and routing numbers linked to your Global account. We may also collect information about your Global status, Global account balance, deposit history, and withdrawal history.
- Transaction Information – information provided by or authorized by you instructing Global to take an action or initiate a transaction.
We are committed to providing a safe, secure and all-around great Service. Therefore, before permitting you to use our Service(s), we may require additional information from you that we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may obtain information about you from third parties such as identity verification, fraud prevention and similar services. When you are using the Global Services, we collect information about your Global account transactions and we may collect information about your computer or other access device for fraud prevention and other similar purposes. Additionally, Global may receive personal information about you from the Debt settlement provider in order to carry out the Services you have contracted with us to provide.
You expressly acknowledge that Global does not maintain records of any documents or information associated with your financial services program or your debt settlement provider, other than transactions or information associated with your Dedicated Account Agreement and Application.
INFORMATION FROM CHILDREN
Global’s Site(s) is not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us at email@example.com if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
HOW WE PROTECT & STORE PERSONAL INFORMATION
This information we collect is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Global password with anyone.
If Global learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Global Services, you agree that Global may communicate with you electronically. Global may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at firstname.lastname@example.org.
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. We may use your personal information to:
- provide the services and customer support you request;
- process transactions and send notices about your transactions or your Global account activity;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent potentially fraudulent, prohibited or illegal activities, and enforce our Dedicated Account Agreement and Application;
- create a transaction between your Global account and a third-party account or your creditor as authorized by you;
- customize, personalize, measure, and improve our Services and the content and layout of our mobile application and website;
- compare information for accuracy and verify it with third parties;
- perform other duties as required by law.
HOW WE SHARE PERSONAL INFORMATION WITH YOUR BANK, YOUR DEBT SETTLEMENT PROVIDER, AND YOUR CREDITOR(S)
To process transactions and fulfill the Services for which you have engaged us, we need to share some of your personal information with the bank and your debt settlement provider. The sharing of information among these parties is essential to the administration of your Global account. We share information with these parties to the extent necessary to facilitate the transactions you authorize and only to carry out the Services for which you have contracted with us.
We share information with your debt settlement provider, creditors and third parties with whom you authorize transactions with. Information is only shared to the extent necessary to complete your authorized transactions. We will not disclose your bank account number to any creditor.
HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
Global does not share your personal information with third parties for their promotional or marketing purposes. However, we may share your personal information with:
- Companies that Global plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this Policy with respect to your personal information. If your personal information could be used contrary to this Policy, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.
- Law enforcement, government officials, or other third parties if Global is compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Global Dedicated Account Agreement and Application, or as otherwise required by law.
- Third party service providers who assist us in providing Services to you.
- Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services).
- Other third parties with your consent or at your direction to do so.
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You can review and update your personal information associated with your Global account at any time by calling 1-877-271-1550.
LINKS TO OTHER SITES
Global’s Sites may contain links to other third-party websites. Global does not control the information collection of third-party websites that can be reached through links from the website. We encourage our users to be aware when they are leaving the website and to read the privacy statements of any third-party website that collects personally identifiable information.
NOTICE REGARDING CONSUMER FINANCIAL INFORMATION
As a company that conducts activities that are financial in nature, Global is a “financial institution” as that term is defined in the Gramm-Leach-Bliley Act (“GLBA”). Accordingly, much, if not all, of the consumer data that we collect, or that is provided to us, falls under the protection of the GLBA. For more information on how we comply with our privacy obligations under the GLBA please see the our GLBA Privacy Notice https://ghllc.com/glba-privacy/.
NOTICE TO CALIFORNIA RESIDENTS
If you are a California resident, California law may provide you with additional rights concerning Global’s collection and use of your personal information. After reading this Policy, please click hereto visit Global’s California Privacy Notice https://ghllc.com/ccpa-privacy/ to learn more about your California Privacy Rights.
NOTICE TO NEVADA RESIDENTS
We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing at email@example.com. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; email: BCPINFO@ag.state.nv.us.
HOW TO CONTACT US
If you have questions or concerns regarding this Policy, or any feedback pertaining to your privacy that you would like us to consider, please email us at firstname.lastname@example.org or call 1-877-271-1550.
Global Holdings LLC
4343 S. 118th East Ave., Ste. 220
Tulsa, OK 74146
Please print and retain a copy of this Policy for your records.