W Connect (D3A) Privacy Policy

1. Scope

This privacy policy ("Policy") explains how Software Product Creation S.L. ("we") processes the personal data of users of the W Connect / D3A product ("W Connect / D3A").

When you access W Connect / D3A in a workplace setting or through a device or account provided by your employer ("Organization"), that Organization may have its own policies regarding the storage, access, modification, deletion, and retention of information you provide or input into W Connect / D3A. In this case, Globant is the data processor. When we collect personal data as a processor on behalf of another Organization, the data will be processed in accordance with the contract we have signed with that Organization and will be governed by the Organization’s privacy policy. This means your Organization has the right to control and manage your account and access to W Connect / D3A, and to process any data you provide through W Connect / D3A. Please contact your Organization for any privacy-related questions regarding policies on the use of W Connect / D3A, including service agreements with us.

2. Personal data we collect

Although the personal data we collect varies based on your use of W Connect / D3A and our interactions with you, we may collect personal data directly from you, from third-party sources, and automatically under the following circumstances:

Personal data collected directly from you:

  • Account Creation. You will need an account to use and access W Connect / D3A. You can create your own account, or your account may be assigned to you by an administrator, such as your employer. If you create your own account, information will be collected when you voluntarily provide your identification data upon registering for W Connect / D3A and provide the requested information. If an administrator assigns the account to you, this administrator (i.e., your employer) will send us certain personal information about you for us to create your account, such as your first name, last name, job title, email, and related information.
  • Customer service and technical support. When you contact us for technical support or other customer service requests, tickets and other records of your related requests/communications are logged.
  • Content. Messages and transcripts of communications with leads made through the call center in which you participate.
  • Communications. We collect the information you provide, such as contact information and records of our communications.
  • Transaction and billing information. We collect information when you subscribe to W Connect / D3A.
  • Surveys. When you respond to a survey, we collect the response, which depends on the type of survey, but may include contact information and satisfaction with a product or service.
  • Sweepstakes, contests, and promotions. If you participate in sweepstakes, contests, and promotions we offer, we will collect your name, age, country of residence, email address, and other registration information related to these activities. In some jurisdictions, we are required to disclose the name and other personal information of winners.
  • Image/video recording and transcripts. Video security/surveillance systems may capture your image if you visit our offices or during marketing or public events or filming sessions, and we may obtain audio and video recordings and transcripts during meetings.
  • Other types of information. We may collect other personal data if you give your consent or if it is reasonable given the nature of the circumstances.

Personal data collected automatically. When using W Connect / D3A, we and third-party providers may collect personal data via cookies, tracking pixels, and similar technologies such as:

  • Device and Browse information. When you use W Connect / D3A, we may collect information, which certain laws consider personal data, such as IP address, browser type, domain names, access times, date and time stamps, operating system, language, device type, unique or online identifier, Internet service provider, referrer and exit URLs, clickstream data, and other similar types of device and Browse information. We may also enable features that rely on the use of additional information on your mobile device or that require access to certain services on your mobile device that will provide you with a better experience with our Services, although they are not necessary to use W Connect / D3A. To access certain types of information such as your location, microphone, camera, and IP, in the mobile application, we will ask for your permission before accessing this information or these features of your mobile device. If you grant us that permission, we will collect the information for the specific purposes we will explain to you at the time we request permission.
  • Activities and usage. We also collect activity information related to your use of W Connect / D3A, such as information about the links you select, searches you conduct, features you use, items you view, time spent on certain pages, interactions with our content, log file information, and other types of activity and usage information.
  • Location information. We may also collect or derive general location information about you, for example, through your IP address.

3. How we use personal data

Generally, we use personal data for the following purposes:

  • Provide you with access to W Connect / D3A. To assign you a user and provide you with access to W Connect / D3A.
  • Provide customer service and technical support. To provide services and operate our product, transmit useful information about your use of W Connect / D3A, troubleshoot problems, and provide technical assistance, respond to your inquiries, fulfill your orders and requests, communicate with you, and for similar customer care and technical support purposes.
  • Communications. To respond to your questions and fulfill your orders and requests; send you communications you have requested or that may be of interest to you; and notify you about changes to W Connect / D3A.
  • Analytics and improvements. To better understand how users access W Connect / D3A; and for other research and analysis purposes, such as evaluating and improving our product and business operations, developing our product and functionalities, and for internal quality control and training purposes.
  • Personalization and adaptation. To tailor the content we send or present in W Connect / D3A, such as offering location personalization and personalized help and instructions, and to otherwise personalize your experiences.
  • Marketing and advertising. To send you information about our product, such as offers, promotions, newsletters, and any other information you agree to receive; and to manage, analyze, measure, and improve our advertising campaigns.
  • Event planning and organization. For the planning and organization of events, including registration, attendance, contacting other attendees, and the possibility of offering you relevant events and services.
  • Research and surveys. To administer surveys and questionnaires, for example, for market research or customer satisfaction purposes.
  • Sweepstakes, contests, and promotions. To facilitate your participation in sweepstakes, contests, and promotions, to communicate with you about your participation in the sweepstakes, contest, or promotion.
  • Security and protection of rights. To protect the product and our business operations; prevent and detect fraud, unauthorized activities and access, and other types of misuse; when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our terms or this Policy.
  • Legal actions and obligations. To comply with the law and our legal obligations, respond in the context of legal processes and matters related to legal actions.
  • General administrative and operational support. To perform tasks related to the general administration of our company, accounting, auditing, compliance, record-keeping, and legal capabilities.

4. Disclosure of personal data

In general, we disclose and allow third parties to access personal data in the following ways:

  • Corporate affiliates. We may disclose personal data to our corporate affiliates as part of our global business operations, and for purposes and uses that respect this Policy.
  • Customers. If you use W Connect / D3A as part of an Organization, your Organization has access to your information on our servers that you create when using W Connect / D3A.
  • Processors and service providers. We may disclose personal data to providers who provide services on our behalf, such as IT service providers, web hosting providers, email service providers, chatbots, call centers, etc.
  • Third parties, platforms, and services. We may disclose or make personal data available to external platforms and providers that we use to provide or offer certain functionalities or parts of W Connect / D3A, or as necessary to respond to your requests.
  • Marketing and advertising networks. We may disclose information you provide to us to advertising networks, search engines, social media platforms, sponsors, and/or traffic measurement services, which use this data to improve and measure the efficiency of our ads.
  • External analytics providers. We may also engage external analytics companies to collect information about how you access and use our Site and Services, for the purpose of improving them and for other research and analysis purposes.
  • Compliance, governance, and legal requirements. We may disclose personal data to comply with legal and compliance obligations, and to respond to legal processes and events related to legal actions. For example, we may disclose personal data in response to subpoenas, court orders, and other legal requests from regulators and law enforcement authorities. We may also disclose information related to litigation and other claims or legal actions, including personal data, to perform internal accounting, auditing, compliance, record-keeping, and legal capabilities. Additionally, we may disclose the names of sweepstakes and contest winners, in accordance with applicable law.
  • Corporate transactions. We may disclose personal data as part of corporate transactions (e.g., mergers, acquisitions, bankruptcies, or other similar transactions) and in contemplation of such transactions (e.g., due diligence).
  • Business partners. We may disclose your personal data to partners who are organizing an event with us.
  • Other cases. We may disclose your personal data for other purposes, for which we will notify you and request consent when necessary.

Aggregated and/or anonymized data. We may use and disclose aggregated, anonymized, and other non-identifiable data related to our company and W Connect / D3A for quality control, analysis, research, development, and other purposes. When we use, disclose, or process anonymized data, we will maintain and use the information in an unidentified form and will not attempt to re-identify it, except where permitted by law.

5. International data transfers

Your personal data may be processed inside and outside the European Economic Area (EEA) given our international dimension, always in compliance with contractual limits on confidentiality and security and in accordance with applicable laws and regulations related to personal data protection. Under no circumstances will your personal data be communicated to subjects or entities not authorized for their legitimate processing.

Likewise, for service efficiencies, some of our providers are located in countries outside the EEA, or, being located in the EEA, share information with other entities located outside that territory.

When we transfer your personal data outside the EEA, to be processed by Globant's associated companies and subsidiaries established outside the EEA, we will do so in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR). Specifically, transfers will be carried out in compliance with the appropriate safeguards required by applicable regulations.

6. Legal basis

We have the right to use your personal data based on (i) our legitimate interest, such as for research and development, to market and promote our product, to protect our legal rights and interests, to the extent that your interests or fundamental rights do not override them; (ii) your consent to do so for a specific purpose; (iii) the necessity of processing your data to comply with a legal obligation; or (iv) for the performance of a contract.

7. Cookies and Other Tracking Mechanisms

We and other third parties use cookies, tracking pixels, and other similar tracking mechanisms to automatically collect information about Browse activity, device type, and other similar information within our product. We use this information, for example, to analyze and understand how you access, use, and interact with W Connect / D3A; to identify and resolve errors and glitches in our product; to evaluate, secure, protect, optimize, and improve the performance of our product; for marketing, advertising, measurement, and analysis purposes; and to personalize content in our product. We may also anonymize or aggregate such information to analyze trends, administer our product, gather broad demographic information for aggregated uses, and for any other lawful purpose.

Cookies. "Cookies" are alphanumeric identifiers used for tracking purposes. Some cookies allow us to facilitate your Browse, while others are used to enable a faster login process, support product security and performance, or allow us to track activity and usage data within the product.

Tracking pixels and other similar technologies. Tracking pixels (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, which have a similar function to cookies. We sometimes use these tracking technologies to understand user activity, help manage content, and compile usage statistics, and in emails to know when they have been opened or forwarded, so that we can track response rates and evaluate the efficiency of our communications.

Third-party analytical tools. We use third-party tools, such as Google Analytics, operated by external companies to evaluate the use of our product. These analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our product and provide us with reports and metrics that help us evaluate our product's use, optimize it, and improve performance and user experience. For more information about Google's privacy practices, review Google's Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

8. Security

No data transmission over the Internet is 100% secure. Therefore, while we strive to protect your personal data, we cannot guarantee the security of information collected through W Connect / D3A. You use our product and provide us with your personal data at your own risk.

9. How Long We Retain Your Personal Data

Your personal data will be retained for as long as necessary to fulfill the purposes and uses for which it was collected as set forth in this Policy. If you request that we delete your personal data from our databases, please note that we may still retain your personal data as necessary to comply with our legal obligations, regulatory requests, resolve disputes, and enforce our agreements.

10. What Rights You Can Exercise in Relation to the Processing of Your Personal Data

You may exercise your rights of access, rectification, erasure, data portability, restriction of processing, and objection by sending a letter to the company's registered office, or by email to privacy@globant.com, attaching, if necessary to prove your identity, a copy of your national identity document or equivalent identification document.

Likewise, we inform you that if you consider that your personal rights have not been duly addressed, you may file a complaint with the competent supervisory authority.

Nevertheless, we recommend that before filing any complaint or claim with the competent supervisory authority, you contact us, and especially our (privacy@globant.com) to analyze the specific situation, and, if applicable, try to find an effective and amicable solution.

11. Your Privacy Preferences

Marketing communications. We may send promotional emails or other similar communications on a regular basis. You can opt out of receiving these communications by following the instructions provided in the communication, for example, by using the "unsubscribe" option. If you opt out of receiving promotional content from us, we may still send you communications about your account or any Service you have requested or received from us.

Industry ad choice programs. You can also control how external advertising companies use the information they collect about your visits to our Site and third-party sites to show you more relevant targeted advertising. If you are in the United States, you can learn more and opt out of receiving targeted ads from third-party advertising networks at aboutads.info/choices (Digital Advertising Alliance, DAA). You can also download the DAA AppChoices tool to control interest-based advertising in apps on your mobile device.

12. Personal Data of Minors

W Connect / D3A is intended for the general public. The product is not designed for minors, and we do not knowingly collect personal data from minors.

13. External links

W Connect / D3A may contain links to third-party websites or features. This Policy does not govern the access and use of such cited websites or features; rather, it is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including the collection of your personal data. You should review the privacy policies and terms of any third-party websites before accessing those websites or using those features.

14. Changes to This Policy

If we change or update our Policy, we will post those changes on this page. Your continued use of W Connect / D3A is subject to our most current Policy, posted here. If we make significant changes, we may post a notification within our product.

15. Contact

If you have any questions or concerns about how we process your personal data or about this Policy, please email us at privacy@globant.com