Privacy Policy

Your personal data includes any information that may lead, directly or combined with other information, to your identification or tracing as a natural person. Personal data include, indicatively, details such as name and surname, tax identification number, social security number, natural/electronic addresses, phone/mobile phone numbers, credit/debit/prepaid card numbers, e-mails, transactions’ data, telephone and electronic communications data, payments data, identification details of equipment or terminal appliances, as POS, PC, smartphone, tablet, browser history (log files, cookies etc.), as well as any other piece of information that may allow your identification, in accordance with the provisions of the General Data Protection Regulation (GDPR 2016/679), the applicable laws per country of operation and the decisions of the relevant Data Protection Authority.

1. Object 

This Privacy Policy aims to inform you on the terms of collection, processing and transfer of your personal data that we may collect as Data Controllers or Data Processors. Globex Innovations, Ltd is continuously training the personnel on lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality and accountability in order to protect your eight Rights regarding the use of your Personal Data (information, access, rectification, erasure, restriction of processing, data portability, right to object and non-automated individual decision-making based on profiling, as specified in the legislation of each country of operation). The above apply without any distinction to all processing activities performed and to all services provided by Globex Innovations, Ltd.

2. Forms of personal data collection

Globex Innovations, Ltd will always ask for your minimum, as stipulated by law, personal data, within the framework of our respective contractual relationship and cooperation. Such personal data may include, indicatively, name/user code, password, number, validity and expiration date of debit/credit/prepaid card, telephone number, e-mail, postal address for issuance or postage of invoice or receipt or details of your order.

Globex Innovations, Ltd keeps your personal data only for as long as imposed by the contractual terms of each service, in combination with the applicable financial, banking, tax, telecommunication and other laws, based each time on the respective processing purpose, while afterwards it anonymizes or destroys them.

3. Cases of personal data collection

Globex Innovations, Ltd collects your personal data in the following cases:

• Upon the creation of your account, when you fill out an application form.

• Upon your willful subscription to hard-copied or electronic lists so that you receive informative material or other marketing material in the form of prospectuses, electronically or by SMS or so that you renew your preferences or upon your participation in questionnaires and surveys.

• Upon your communication with our offices or the personnel of our customer care department by the recording of the content of your calls and each communication.

• Upon your visit and browsing in our websites, where we collect with the appropriate means of data collection (e.g. cookies) information from your terminal device, such as the operating system that you use, the type and version of your browser etc.

• Upon the submission to us of documents, judicial documents, orders, reports, confiscation documents, judicial orders etc. by third parties such as supervisory, prosecution, judicial, tax authorities, banking organizations, card issuance organizations, payment institutions, credit card institutions, companies that provide information on your creditworthiness for your protection against fraud or money laundering or combat against financial and electronic crime. 

4. Cookies policy

Our webpage uses small files, which are known as “cookies”, to be able to function better and to improve your experience. These files are stored on your device only if they are necessary for the website to function properly. For the rest cookies’ types, we obtain your consent through an appropriate mechanism.

5. Processing principles 

We are committed to protecting your privacy and handling your data in a transparent manner, therefore, we process your personal data in accordance with GDPR and each country’s data protection law for at least one of the following reasons:

I. For contract execution

We process personal data in order to complete your transactions and to offer our services based on our terms of service, but also in order to be able to complete the contracting process with prospective partners and customers.

The purpose of personal data processing depends on the requirements for each service and the contractual terms and conditions provide more details about the purposes involved.

II. To comply with a legal obligation

There are certain legal obligations arising from the relevant laws applicable to us as well as regulatory / legal requirements, e.g. the Law on Money Laundering, the Tax Legislation, the Law on Payment Companies. There are also several supervisory principles that we have to apply with, such as, each country’s Banking Supervisory Authority. Such obligations and requirements require from us to execute the necessary personal data processing activities for identity verification, compliance with court decisions / warrants, fraud reporting obligations and anti-money laundering controls.

III. In order to protect legal interests

We process personal data in order to safeguard the legitimate interests pursued by us or by third parties. There is a legitimate interest when we have a business or commercial reason for using your information. But, even under this perspective, this should not be opposed to what is right and better for you. Examples of such processing activities include the following

i. Creation of legal claims and preparation of our defence during litigation.

ii. Measures and procedures we follow in order to ensure the security of our systems and to prevent possible criminal activity.

iii. Communication with our customers on new services we provide.

iv. Technical support.

Once you have explicitly given us your consent to process your personal data (except for the reasons stated above), the legality of such processing is based on that consent. You have the right to withdraw your consent at any time. However, any processing of personal data prior to receiving your recall will not be affected.

6. Transfer to Third Parties

When you use our website and you provide us with personal information, we do not transfer nor share your information, nor even among the group companies or third parties, but only to the extent it is necessary for the completion of your order and to fulfil requests associated with our services. Such third parties may include, indicatively, telecommunications providers, international payment services providers, international card schemes (e.g. debit, credit etc.), banking institutions etc.

We take the appropriate technical and organizational measures to ensure that your personal information is transferred, stored and processed in accordance with the appropriate security standards and with the provisions of this policy and the applicable data protection laws. 

We may transfer or reveal your personal data to the official, national or foreign, state and supervisory bodies (e.g., Police, Banking Supervisory Authority, international tax authorities, etc.) when we are asked to comply with the law and to prevent any unlawful actions (e.g., fraud, money laundering etc.) to our customers or our customers’ detriment.

7. Your data protection rights

You have the following rights regarding the personal data we preserve about you: 

I. Access to your personal data. You have the right, for example, to receive a copy of the personal information we preserve about you and verify that we process it legally.

II. Rectification of your personal data. You have the right to rectify and/or completely inaccurate and/or incomplete data we preserve about you.

III. Erasure of your personal data [also known as “right to be forgotten”]. You have the right to ask for your personal data erasure when there is no longer any valid reason to continue processing it.

IV. Object to processing of your personal data when, even though we are based on a legitimate interest, you are in a particular situation that makes you object to the processing of your data for this reason. If you submit an objection, we shall no longer process your personal data, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms. Additionally, you have the right to object in cases where your personal data are processed for direct marketing purposes. This also includes profiling to the extent that this is related to such direct marketing. If you object to your personal data processing for direct marketing, then we shall no longer process your personal data for such purposes.

V. Restriction of processing of your personal data. You have the right to ask from us restriction of processing, i.e., to use such data only for specific purposes, if:

i. are not accurate;

ii. processing is unlawful and you oppose the erasure of your personal data;

iii. we do not need your personal data anymore, but they are required by you for the establishment, exercise or defence of legal claims;

iv. you have objected to processing, pending the verification of whether our legitimate grounds override those of yours.

VI. Receive the personal data concerning you in a structured, commonly used and machine-readable format, in order to transmit these data to another organization. Also, you have the right to have your personal data transmitted directly from one controller to another that you will indicate to us [also known as the right to “data portability”].

VII. Withdrawal of your consent to the processing of your personal data at any time. Please, note that any revocation of your consent does not affect the legality of the consent-based processing before it is withdrawn or revoked by you.

Any amendments to this Policy will apply to the collected information from the date on which the amended version will be published and on the existing information we keep. By using the website after the publication of the amendments, you automatically accept such amendments.