Global Access LLC: Privacy Statement
1. Who We Are
Global Access, LLC, (“Global Access”) is an international logistics organization that provides services for retailers, distributors and end-user customers, enabling international delivery of purchased products.
For its business clients, Global Access acts on behalf of its clients to deliver goods internationally and facilitate associated services including website language translation and hosted checkouts. Data is collected from client systems via API calls and FTP and browser-based file uploads.
Global Access maintains corporate offices and warehouses in the United States and Japan. Global Access utilizes third-party Processors to provide services, including: logistics, payments, insurance and communication. Local regulations for customs and tax require the sharing of Personal Data with regulatory authorities.
3. EU-U.S. Data Privacy Framework
Global Access is certified under its parent company Global Access Group, LLC.
4. Personal Data We Process
We collect personal data that we (a) receive from our business clients and (b) obtain for marketing purposes for potential clients, customers or others. We may process your personal data with or without automatic means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of your personal data.
a. Data received from our business clients. Our business clients submit personal data to us in order for us to be able to provide the services requested, which may include delivery of products, processing of payments, calculation and submission of relevant taxes, submission of customs forms, reporting of shipping volumes and frequency, and reconciliation of distributor commissions. The personal data collected generally includes the name, physical address and phone number of the ‘Ship-to’ party, and the name, physical address, phone number, email, payment information, business client and Personal Client ID. A Personal Client ID is typically the ID number used by the business client to identify a salesperson such as a distributor, who is responsible for the product sale. Personal Client IDs are assigned by the business client and may be the social security number or other national ID of the person.
Related services offered to our business clients include access to a web module that provides tracking and reporting information on shipping orders. Business clients have the option to extend access to this module to their agents, salespersons or distributors so that they can manage, track, and obtain reporting on the orders for which they are responsible.
Processing of this personal data is performed on behalf of the business client and for the purpose of providing the services requested by the business client. Personal data received from our business clients is done so in accordance with the Service Level Agreement or other agreement entered with the business client.
b. Data obtained for marketing purposes for potential clients, customers or others. We obtain marketing data that we use to reach out to inform potential clients, customers and others of the services offered by our organization. The personal data collected generally includes the email address of a potential client, customer or contact and may also include their name and phone number.
c. Personal data not actively collected or processed. We do not actively collect or otherwise process personal data from minors and include in our Terms and Conditions a condition that the customer is not a minor and does not provide personal data of minors. The age of a minor varies by country. For the purposes of personal data collected from the European Union, the age of a minor is under age sixteen (16).
We do not actively collect or otherwise process special categories of personal data as identified in the GDPR including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, or genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We do not actively collect or otherwise process personal data relating to criminal convictions and offences.
5. Tracking Technologies, Cookies and Clear GIFs
We use tracking technologies, cookies and clear GIFs to collect information. Tracking technologies are used to collect information from your web browser through our servers or filtering systems when you visit any of our sites. Cookies are small bits of data used to transfer information to your computer’s hard drive or your web browser for record-keeping purposes, including recognizing your web browser when you return to our sites. A clear GIF is a transparent graphic image placed on a website. The use of clear GIFs allows us to monitor your actions when you open a web page and makes it easier for us to follow and record the activities of recognized browsers. Clear GIFs are used in combination with cookies to obtain information on how visitors interact with our websites.
Information collected may include but is not limited to your browser type, your operating system, your language preference, any referring web page you were visiting before you came to our site, the date and time of each visitor request, and information you search for on our sites. We can also track the path of page visits on a website and monitor aggregate usage and web traffic routing on our sites. We collect this information to better understand how you use and interact with our sites in order to improve your experience. We also collect this information to better understand what services and marketing promotions may be more relevant to you. We may also share this information with our employees, service providers and customer affiliates as well as between affiliated entities.
You can change your web browser settings to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. If you do not accept cookies, however, you may not be able to use some sections or functions of our sites.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
6. Purposes for Processing Personal Data
We process Personal Data for logistics, payment, insurance, customs, tax, other regulatory requirements, communication, customer service, marketing, web analytics, system monitoring, data security and other operational and administrative purposes.
We use Personal Data to provide logistics and other related services to enable international product purchase and delivery for our customers and business clients while meeting the regulatory requirements of the relevant countries. We may use Personal Data to (a) provide you order shipping and reporting information, (b) package and inventory product for you, (c) store product for you, (d) deliver product to you, (e) insure product, (f) submit customs or other regulatory forms on your behalf, (g) contact you, (h) create and maintain account profiles for your agents/distributors/salespersons, (i) fulfill requests you make. (j) seek your voluntary feedback, (k) customize features or content on our websites and software, (l) verify identity, (m) administer our services, including through use of third-party services providers, or (n) communicate with you for marketing purposes where you are the contact for a potential business client.
In this context, the legal basis for our Processing of your Personal Data is either the necessity to perform contractual and other obligations that we have towards you or our business clients or carrying out our legitimate activities as a logistics organization.
We may also use your data to comply with applicable laws and exercise legal rights as the basis for our data Processing.
We may also use your Personal Data for internal purposes, including auditing, data analysis, system troubleshooting, and research. In these cases, we base our Processing on legitimate interests in performing the activities of the organization.
7. Sharing of Personal Data
We share your Personal data with other parties in the following circumstances:
a.Third-Party Providers. We may share your information with third party providers to perform tasks on our behalf. These companies include (for example) logistics companies (e.g. USPS, FedEx, DHL), our payment processing providers (e.g. Worldpay), website analytics companies (e.g. Google Analytics), and our insurance providers (e.g. Shipsurance). Other tasks such as data analysis, surveys and customer service are completed in-house by our staff and do not require the sharing of your Personal Data with other parties. In instances where your Personal Data is shared with third party providers, the providers will be contractually required to protect Personal Data from additional Processing (including for marketing purposes) and transfer.
Your Personal Data may be transferred to another country outside of the EEA, other than the United States, in order to fulfil the services requested, for example, where the ship-to address for product delivery is in another country. In this case, the country where Personal Data is transferred may not provide a similar or adequate level of protection to that provided by the EEA.
Under certain data protection laws, including the GDPR, Global Access, LLC, is liable if a third-party provider that we have engaged to Process Personal Data fails to fulfil its data protection obligations.
b. Legal Requirements. We may access and disclose your personal data to regulatory bodies if we have a good-faith belief that doing so is required under regulation. This may include screening against the Consolidated Screening List for which the United States Government maintains restrictions on certain exports, re-exports or transfers of items. This may also include submitting personal data required by local customs authorities and tax authorities. Additionally, we may disclose your personal data and other information as required by law, including in response to lawful requests by public authorities or to meet national security or law enforcement requirements. We may also disclose your personal data to exercise or defend legal rights; to take precautions against liability; to protect the rights, property, or safety of the resource, of any individual, or of the general public; to maintain and protect the security and integrity of our services or infrastructure; to protect ourselves and our services from fraudulent, abusive, or unlawful uses; or to investigate and defend ourselves against third-party claims or allegations.
8. Storage of Personal Data
9. Personal Data Security
Global Access uses technical and organizational measures to protect the Personal Data received against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed. We regularly consider appropriate new security technology and methods as we maintain and develop our software and systems. Security measures implemented include:
SSL is used on all pages where Personal Data is collected;
Data requiring a higher level of protection, such as payment card account numbers and passport numbers, is encrypted prior to transmission to the database for storage;
Web and database servers are protected using firewalls;
Passwords used for account registration cannot be ‘defaulted’;
User access is tracked;
Role-based security is applied to system access;
All employees are contractually obligated to maintain the confidentiality of Personal Data accessible through their employment;
Regular system backups are made;
Regular maintenance is performed on systems; and
Systems are monitored for security.
10. Retention of Personal Data
Global Access retains Personal Data, including Personal Data collected via website and mobile applications, API calls and FTP and browser-based file uploads, upon instructions of our business clients.
We continue to retain Personal Data that we are required to retain in order to meet our regulatory obligations including tax records and transaction history. We comply with the Retention Policy of our parent company Global Access Group, LLC, which is regularly reviewed to ensure compliance with our obligations under data protection laws and other regulatory requirements. We regularly audit our databases and archived information to ensure that Personal Data is only stored and archived in alignment with the Retention Policy.
11. Personal Data Rights
Individuals in the EEA have certain data subject rights which may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification or erasure of their Personal Data; (ii) obtain restriction of processing or to object to processing of their Personal Data; and (iii) ask for a copy of their Personal Data to be provided to them, or a third party, in a digital format. If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below. Individuals also have the right to lodge a complaint about the processing of their Personal Data with their local data protection authority.
Please note that we rely upon our business clients maintaining accurate personal data in their client systems that we access through API calls and FTP and browser-based file uploads in order to facilitate logistics services.
For marketing communication an ‘unsubscribe’ option is provided in the footer of every marketing communication. In addition, we may be contacted directly to unsubscribe. Our contact details are provided at the end of this Privacy Statement.
You may contact the business client who provided your personal data to request changes to your personal data or exercise any rights you may have, including the right to: access, rectification, data portability, objection, processing restriction, and erasure of your personal data, or for assistance in modifying or updating your personal data.
On your request, we are happy to assist you with the contact details of the business client(s) who provided your personal data to us. You may also contact us to assist you with your inquiries or in exercising your rights in regards to our business clients. Our contact details are provided at the end of this Privacy Statement.
California Privacy Rights
California Civil Code Section 1798.83 permits users of the Site who are California residents to request certain information regarding our disclosure of Personal Data to third parties for direct marketing purposes. To make such a request, please contact us as described below.
12. Dispute Resolution
Global Access participates in the EU-U.S. Data Privacy Framework under Global Access Group, LLC. A list of participants can be viewed by accessing the link below:
As part of its participation in the EU-U.S. Data Privacy Framework, Global Access is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Organizations participating in the EU-U.S. Data Privacy Framework must respond within 45 days of receiving a complaint. If you have not received a timely or satisfactory response to your question or complaint, please contact one of the independent recourse mechanisms listed below:
EU Data Protection Authorities (“DPAs”)
Please note that these independent dispute resolution bodies are designated to address complaints and provide appropriate recourse free of charge to the individual.
Under certain circumstances, individuals located in the European Economic Area may invoke binding arbitration to resolve a Privacy Framework related dispute. In order to invoke arbitration, you must take the following steps prior to initiating an arbitration claim: (1) raise your complaint directly with Global Access and provide us the opportunity to resolve the issue; (2) make use of the independent recourse mechanism listed above; and (3) raise the issue through your relevant Data Protection Authority to the U.S. Department of Commerce and afford the U.S. Department of Commerce an opportunity to use best efforts to resolve the issue at no cost to you. For more information on binding arbitration, see the U.S. Department of Commerce’s Data Privacy Framework: Annex I (Binding Arbitration) at:
13. Effective Date and Amendments
This document is effective May 25, 2018. This document may be amended from time to time.
14. Contact Details
Inquiries may be made to:
Organization: Global Access Group, LLC.
Contact: Data Protection Officer (Chris Bauer)
Address: 2889 Ashton Blvd, Suite 350, Lehi, UT 84043
Contact: EU Representative (Daniel Eigner)
Address: Rastenfeld 151 Rastenfeld, 3532 Austria
*Please note that organizations participating in the EU-U.S. Privacy Shield Framework must respond within 45 days of receiving a complaint.
In the event that your Personal Data was processed on behalf of another company, you may also directly contact that company about your Personal Data. Global Access Processes Personal Data on behalf of other companies who are its business clients. On your request, we are happy to assist you with the contact details of the business client(s) who provided your Personal Data to us.