European Disclosures

At GLOBECOMM, we are committed to protecting and respecting your privacy. This policy explains how we collect and use any personal information (i.e., any information that relates to you and that identifies or can be used to identify you) that you share with us, including how we collect, process, protect and share your personal information.

You do not need to take any action as a result of this privacy policy, but you may have certain rights as described below.

We keep this privacy policy under regular review. This EU privacy policy was last updated on May 21, 2018.

When you provide us with your personal information, Globecomm Systems Inc. (“GLOBECOMM”, “we”, “us” and “our”) act as “data controllers” as such term is defined in Regulation (EU) 2016/679 (the General Data Protection Regulation). In simple terms, this means that we: (i) “control” the personal information that you provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect such personal information, but only to the extent that we have informed you about the use or are otherwise permitted by law.

Please note that this EU privacy policy pertains to information that may be collected in connection with your use of this Website and in certain other limited circumstance as described herein. Personal information GLOBECOMM may collect from investors in funds and accounts sponsored or managed by GLOBECOMM will be addressed in separate notices to the extent required by law.
If you have any questions regarding our use of your personal information, or this privacy policy, please contact the Compliance Department at contracts@globecomm.com. This privacy policy is provided in a layered format so you can click through to the specific areas set out below:

What information do we collect about you?
How we obtain your personal information
Why we use your personal information
Who we share your personal information with
How we keep your personal information secure
Our retention of your personal information
Transfers of your personal information
Your rights
Contact us
Complaints


1.  What information do we collect about you?

The types of personal information we collect about you depends on the nature of your interaction with us. The types of personal information we collect may include:

  • personal, device and business contact information (such as name, postal and email address, IP addresses, and telephone number);
  • other personal information you submit to us, such as information you provide to register for email alerts or correspond with us in relation to inquiries;
  • personal information you may submit to us in connection with any potential employment opportunities; and
  • information we may collect about you in connection with making proposals to you or performing under contracts with you.
  • The personal information collected about you will help us provide you with better service or facilitate our business relationship.


2.  How we obtain your personal information
We collect information about you directly when you provide it to us in correspondence and conversations (including via email and telephone) and through forms and contracts we may enter with you. We may also receive information about you from your employer, service providers or other transaction parties. Depending on the nature of the relationship, such may include information about your name, address, email address, date of birth, passport details or other national identifier, driving license, your social security number and income, and employment information.

In connection with an employment inquiry, we also collect information regarding your work authorization status, education history, employment history and professional designations; and other information about your qualifications.

We will only collect and process personal information about you where we have lawful bases to do so (please see section 3 below).

We may combine personal information that you provide to us with information that we collect from, or about you, in some circumstances. This will include information collected in an online or offline context.

3.  Why we use your personal information
We will use the personal information you provide us or we otherwise collect for the following purposes, and pursuant to the corresponding legal bases:

Purpose Legal Basis
To make proposals for, enter into, and perform contracts with you that you have requested. Contractual necessity
To improve our website and notify you about changes to our services. Legitimate interest
To respond to requests for information submitted by you through our website. Legitimate interest
To keep a record of your relationship with us. Legitimate interest
To assess your qualification for available employment opportunities. Legitimate interest
To conduct know-your-customer, anti-corruption and similar regulatory reviews. Legitimate interest

Additionally, we will use your personal information, subject to applicable law, to keep you informed of our products and services based on our legitimate interests.

No automated decision making, including profiling, is used when processing your personal information.

4.  Who we share your personal information with
We will share your personal information with third parties as required by law or regulation.
We will also share your personal information with affiliates and certain service providers and professional advisors, including our lawyers, auditors and other professional advisors and service providers as necessary to fulfill the purposes set out in this privacy policy.

We will seek to ensure any third party that acts as a data processor on our behalf:
(i) enters into an agreement with us and meets our standards for data security;
(ii) does not use your personal information for any purpose other than the clearly defined purpose relating to the service that such party is providing;
(iii) treats your personal information as confidential; and
(iv) holds your personal information securely and retains it only for such period of time as necessary.
We will also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment or other disposition of all or a portion of our business, assets or shares.

5.  How we keep your personal information secure
We are committed to protect the personal information you entrust to us, and to that end we employ appropriate organizational, physical, technical and procedural safeguards designed to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
We also train and instruct our employees that all personal information must be handled in accordance with this privacy policy and applicable privacy and data protection laws, and any misuse by employees is subject to disciplinary action.

6.  Our retention of your personal information
We will keep your personal information only for as long as is necessary for the purposes it was collected, set out in section 3 of this privacy policy, unless a longer retention period is required under applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7.  Transfer of your personal information
To the extent that you reside in the European Union, or EU data privacy legislation applies to you, and we transfer your personal information to countries located outside of the European Economic Area (“EEA”), such transfers are made in accordance with applicable data privacy laws.

8.  Your rights
To the extent that you reside in the European Union, or EU data privacy legislation applies to you, you have the right to access the personal information we hold about you, and there are, subject to certain limitations, a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us at contracts@globecomm.com.

Access: You have the right to access the personal information that we hold about you free of charge (subject to certain situations where we may charge a ‘reasonable fee’).
Correction: You have the right to correct any inaccuracies in the information we hold about you.
Deletion: You have the right to request that we delete your personal information in certain situations (subject to any legal obligations for us to retain it).
Restrictions on use: You may request that we stop processing your personal information (other than storing it): (i) while its accuracy is verified; (ii) if the processing is illegal; (iii) if the processing is no longer necessary for the purposes for which it was collected; or (iv) if you object to the processing and we are verifying whether our legitimate grounds to process your personal information override your own rights.
Object: You have the right to object to processing, including: (i) for direct marketing (from which you may opt-out at any time); (ii) for research or statistical purposes; and/or (iii) where processing is based on legitimate interests.

This website may contain links to other websites. GLOBECOMM is not responsible for the privacy practices or the content of such third party websites.

9.  How to contact us
For any questions regarding our processing of your personal information (including the rights and controls explained in section 8 of this privacy policy) please contact contracts@globecomm.com.

10.  Complaints
If you reside in the European Union, or EU data privacy legislation applies to you, and you should you wish to lodge a complaint with regards to how your personal information has been processed by GLOBECOMM, please contact your local supervisory authority. In the UK, this is the Information Commissioner (https://ico.org.uk/).