Privacy Statement

PRIVACY POLICY

Global Response is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the Global Response Web site and governs data collection and usage. By using the Global Response website, you consent to the data practices described in this
statement.

Definitions

“Personal Information” and “Personal Data” (both hereinafter referred to as “Personal Data”) are data about an identified or identifiable individual that can be used to identify that individual either on its own or in combination with other readily available data.

“Sensitive Data” is personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of an individual.

Collection of your Personal Data

Global Response collects Personal Data and sensitive data on our web site through visitors submission of forms. Global Response may also collect anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.

There is information about your computer hardware and software that is automatically collected by Global Response. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by Global Response for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Global Response Web site.

Global Response encourages you to review the privacy statements of Web sites you choose to link to from Global Response so that you can understand how those Web sites collect, use and share your information. Global Response is not responsible for the privacy statements or other content on Web sites outside of the Global Response and Global Response family of Web sites.

Use of your Personal Data

Global Response collects and uses your Personal Data to operate the Global Response Web site and deliver the services you have requested. Global Response also uses your Personal Data to inform you of other products or services available from Global Response and its affiliates. Global Response may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Global Response does not sell, rent or lease its customer lists to third parties. Global Response may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique Personal Data (e-mail, name, address, telephone number) is not transferred to the third party.

Global Response does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

Global Response keeps track of the Web sites and pages our customers visit within Global Response, in order to determine what Global Response services are the most popular. This data is used to deliver customized content and advertising within Global Response to customers whose behavior indicates that they are interested in a particular subject area.

Global Response Web sites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Global Response or the site; (b) protect and defend the rights or property of Global Response; and, (c) act under exigent circumstances to protect the personal safety of users of Global Response, or the public.

Use of Cookies

The Global Response Web site uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer.

Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We will automatically collect cookies and other non-personally identifying information when you visit the Site and, therefore, do not respond to Do Not Track (DNT) signals.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Global Response pages, or register with Global Response site or services, a cookie helps Global Response to recall your special information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Global Response Web site, the information you previously provided can be retrieved, so you can easily use the Global Response features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Global Response services or Web sites you visit.

Security of your Personal & Sensitive Data

Global Response secures your data from unauthorized access, use or disclosure. Global Response secures the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal and sensitive data (such as a credit card number) is transmitted it is protected through the use of encryption.

Choices for Email and Marketing Communications

You may opt-out of receiving Program emails from us. Doing so will affect the level of benefits and participation in any event hosted across our sites. If you do not wish to receive email communications from us, you can unsubscribe from the link in the email you received, or indicate your preferences within a direct communication to us. You may also email us if you wish to unsubscribe, but for your security, please do not send credit or debit card information via email.

Retention, Disposal, and Correction of Information

We retain your information as long as we determine it is required for the operation of our business and services and to meet legal, regulatory, and other requirements. We take reasonable steps to ensure that information is disposed of securely when we no longer require such data. You may request in writing that any Personal Data be corrected or removed. (See the contact information below.)

Changes to this Statement

Global Response will occasionally update this Statement of Privacy to reflect company and customer feedback. Global Response encourages you to periodically review this Statement to be informed of how Global Response is protecting your information.

Contact Information

Global Response welcomes your comments regarding this Statement of Privacy. If you believe that Global Response has not adhered to this Statement, have questions about this statement, or wish to edit or delete your Personal Data please contact Global Response by written request by e-mail or:

Global Response Corporation
Attn: Legal Department
777 South State Road 7
Margate, FL 33068

PrivacyOffice@GlobalResponse.com

GLOBAL RESPONSE PRIVACY SHIELD STATEMENT

This Privacy Shield Statement (Statement) describes how Global Response Corporation and its subsidiary, Global Response Fulfillment Corporation (collectively “Global Response”) collects, uses and discloses personally identifiable information that is received in the United States (“U.S.”) from the European Union (“EU”).

Global Response recognizes the EU has established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EU. To provide adequate protection for certain Personal Data relating to website visitors, clients, prospective clients, client’s customers and vendors that Global Response receives in the U.S., Global Response has elected to self-certify to the EU-U.S. Privacy Shield Framework administered by the Department of Commerce (“Privacy Shield”).

Global Response complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. Global Response has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

DEFINITIONS

“Personal Information” and “Personal Data” (both hereinafter referred to as “Personal Data”) are data about an identified or identifiable individual residing within the EU that can be used to identify that individual either on its own or in combination with other readily available data.

“Sensitive Data” is personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of an individual.

“Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data.

NOTICE

As a provider of e-commerce, call center out-sourcing and fulfillment services, Global Response processes Personal Data received from you, our client’s customer, and returns or forwards the data to our client as specified by contract. Global Response only acts as an agent for the collection of data on behalf of our clients. In this context, Global Response is acting as a data processor and will process the Personal Data on behalf of and under the direction of each particular client as defined in our agreements with our clients. The Personal Data that Global Response collects from you in this capacity is used for:

  • Managing transactions;
  • Operations related to your requests for services;
  • Providing information about our client’s products;
  • To deliver services for our client on your behalf;
  • Satisfying governmental reporting, tax and other requirements;
  • Storing and processing data, including Personal Data, in computer databases and servers located in the United States;
  • Verifying identity (for on-line access to accounts);
  • Fulfillment of orders.

Global Response will only process Personal Data in ways that are compatible with the purpose for which Global collected the information or for purposes that you or the entity providing the Personal Data later authorizes. When providing our services, Global Response will only process and retain Personal Information as necessary to provide our services as permitted in our agreement with clients, or as required or permitted under applicable law.

The types of Personal Data collected are: e-mail address, name, driver’s license, home or work address, telephone number, zip code, age, gender identifier and credit card data.

CHOICE

If Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Global Response will provide you or owner of the Personal Data with an opportunity to choose whether to have the Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: PrivacyOfficer@globalresponse.com.

If Sensitive Personal Data covered by this Privacy Shield is to be disclosed to a third party or used for a purpose other than for which it was originally collected and subsequently used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized by the individuals, Global Response will obtain explicit consent prior to such use or disclosure.

Adherence to these principles may be limited to the extent necessary to meet national security, public interest, or law enforcement requirements; by statute, governmental regulation, or case law that creates conflicting obligations or explicit authorizations.

ONWARD TRANSFER

Global Response only transfers Personal Data under the direction and control through contract with its clients who act as third-party controllers. Global Response will only process your information for the limited and specified purpose consistent with either the consent you provide or under contractual terms with our client.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Global Response’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Global Response remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Global Response proves that it is not responsible for the event giving rise to the damage.

DATA INTEGRITY AND SECURITY

Global Response, adheres to Privacy Shield Principles in that personal information collection is limited to the information relevant for the purposes of processing. Global Response maintains reasonable and appropriate measures to help protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction taking into account the risks involved in the processing and the nature of the Personal Data.

Global Response has implemented physical and technical safeguards to protect Personal Data utilizing a secure network with firewall protection, using user authentication via passwords or similar means and secure encryption.

ACCESS

Where appropriate, individuals have the right to access to their Personal Data and may request corrections, deletions, or additions where the Personal Data is inaccurate or has been processed in violation of the Privacy Shield Principles. Global Response may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Privacy Shield Principles. You may request access to your Personal Data by contacting us at PrivacyOfficer@globalresponse.com.

RECOURSE, ENFORCEMENT AND LIABILITY

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Global Response is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Global Response has established procedures to periodically verify implementation of and compliance with the Privacy Shield Principles. Global Response conducts an annual self-assessment of its practices regarding Personal Data which is intended to verify that the assertions Global makes about its practices are true and that such practices have been implemented as represented.

In compliance with the Privacy Shield Principles, Global Response commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact COMPANY by email at PrivacyOfficer@globalresponse.com. The Global Privacy Officer will endeavor to investigate and attempt to resolve any complaints within a reasonable time.

Global Response has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

AMENDMENT

This Privacy Shield Statement may be amended from time to time consistent with the requirements of the EU-U.S. Privacy Shield Framework.