TERMS & POLICIES
Global Relay Online Privacy Statement
Online Privacy Statement
Global Relay Communications Inc. (“Global Relay” or “we”) values your privacy and recognizes the importance of protecting your personal information. This online privacy statement (“Privacy Statement”) explains how we collect, use, share and secure your personal information. We use the words “personal information” in this Privacy Statement to describe information that is about you that identifies you.
This Privacy Statement applies to personal information or information we collect from visitors to our website and customers of our services (including individuals that may be granted access to our services by our customers) – in these situations, Global Relay is considered a “controller” (or its equivalent) under applicable data protection laws. This Privacy Statement does not apply to data collected and maintained in Global Relay’s enterprise message archiving service, which is governed by a separate service agreement – in that situation, Global Relay is generally considered a “processor” (or its equivalent) under applicable data protection laws.
This Privacy Statement describes:
- The personal information we collect from you
- How we use your personal information
- How we use automated technologies (e.g. cookies and other analytics)
- How we share your personal information
- Our storage and retention of your personal information
- How we protect your personal information
- Links to third-party websites
- The transfer of your personal information to other countries
- Your rights regarding your personal information
- Who to contact with questions or concerns
We may modify this Privacy Statement from time to time. Any changes we make to this Privacy Statement in the future will be posted on this page. The updated policy will take effect upon posting to this page.
Personal Information We Collect
Global Relay may collect or ask you to provide personal contact information such as your name, address, telephone number, email address. We may also collect billing and financial information from you, including credit card and payment information. We sometimes maintain other user account information like your transaction history. In some cases, in order to provide you with technical or customer support, we may ask you for additional information.
As described in further detail below, we also use automated technologies (like cookies) to collect certain information when you visit our website.
How We Use Your Personal Information
Global Relay only uses your personal information when the law allows us to do so. Most commonly, we will use your personal information where: (i) we need to comply with a legal obligation; (ii) we need to perform a contract we have entered into with you; or (iii) it is necessary for our legitimate interests. In some instances, we process your personal information based on your consent. When the legal basis for the processing of your personal information is your consent, you may withdraw that consent at any time by contacting us at firstname.lastname@example.org.
We primarily use your personal information for our internal business purposes. This is in our legitimate interest in order to operate as a business and monitor and improve the quality of the services we provide. For example, our use of your contact information is necessary to keep you well informed of maintenance, support, and usage issues, invoicing and accounting issues, escalated critical issues, and problem resolutions that may arise with the services. Your information is also logged to help us diagnose technical problems, to contact you to resolve technical problems, and to administer Global Relay’s website. When our developers must investigate or troubleshoot issues for mobile applications, we may collect information that does not personally identify you, including device state, device identifiers, device hardware, operating systems, application functionality, or physical location of a device.
We also like to keep you informed about our offered services and trends in the industry, so we may also use email addresses to provide you with informative newsletters and other similar information. To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or contact us at email@example.com.
We may also track and analyze non-identifying and aggregate usage, including volume statistical information, from website visitors and customers and provide such anonymized information to third parties.
Sometimes we use personal and demographic information to help us determine which services are most likely to be of interest to you or to help diagnose problems with our systems or administration of our website.
We also use demographic information to gather general interest in our products and services, to help in the analysis of product/service usage, purchasing, and target markets.
Global Relay is committed to continually improving your experience when you visit our website. Accordingly, we use automated methods, like cookies, to collect certain information when you visit our website. A cookie is a small text file that a website or application can send to your computer’s browser to collect and record information about your use of that website or application.
As you interact with our website, we automatically collect technical data such as the type of internet browser you use, the language of your browser, the website from which you have come to the site, the webpages you view on our website, the links you clicked on our website, and your IP address (the unique address which identifies your computer on the internet).
To find out more about cookies, including how to manage and delete them, visit www.allaboutcookies.org.
How We Share Your Personal Information
Global Relay primarily maintains and uses your personal information for internal business purposes, but we may disclose it to third parties in aggregate form (i.e. not individually attributable to you) for marketing, promotional, or other business purposes.
We may share your personal information with third parties in responding to your requests for products or services, or product evaluations. We may share information that does not personally identify you with a third party service provider to help us diagnose and solve technical issues related to mobile applications, including device state, device identifiers, device hardware, operating systems, application functionality, or physical location of a device. We will not sell, rent, trade or otherwise disclose individual customer information to any third parties or outside companies for any reasons other than those specified in this Privacy Statement.
Where you provide us with credit card information, be assured that we endeavor to use secure technologies to protect such information against unauthorized disclosures. Credit card information may be shared with the credit card companies themselves and with other credit verification organizations. We also may make general information about the purchases available to third parties from time to time.
Our Storage and Retention of Your Personal Information
Global Relay securely keeps your information for as long as we reasonably require it, either for business purposes, to comply with any legal obligations, or for as long as we are contractually obliged.
How We Protect Your Personal Information
We use a variety of technical and organizational security controls to help protect your personal information from unauthorized access, use, disclosure, alteration, or destruction consistent with applicable data protection laws. These controls include:
Data Center Security
- Mirrored, SOC 2-audited Data Centers
- Physically secured with 24x7x365 uniformed guard service
- Electronic key card access at Data Center entrances
- Physical access to Data Centers limited solely to Global Relay employees whose duties require access
- Monitored video surveillance cameras and alarm systems throughout Data Centers and building
- All environmental control systems monitored and controlled locally and remotely monitored
- Redundant facility HVAC cooling systems
- Fire detection and prevention systems
- High sensitivity, early warning smoke detection systems
- Redundant power utilizing uninterruptible power supplies (UPS)
- Independent routing of network traffic between redundant Tier 1 ISPs providing 10G connectivity
- Highly secure, reliable, and scalable IT infrastructures
- Use of anti-virus software and encryption
- Mirrored active/active firewalls to ensure that in the event of a failure data will remain secure
- Continually upgraded systems ensuring performance at the highest level
- Systems monitored 24/7 by a dedicated Cyber Security Operations Center to protect against unauthorized intrusion
- Multi-factor authentication and Virtual-Private-Network (VPN) provides secure, remote monitoring
- System alerts for unusual activities
- Performance of regular security reviews and monitoring of security logs for anomalies
- All employees receive mandatory security awareness training, including mandatory security refreshers and testing
- Al employees are subject to background checks
- All employees must sign confidentiality and non-disclosure agreements
- Strict authorization protocols, logging, and monitoring for privileged systems access by Operations staff
In addition, access to sensitive personal information is limited to those individuals and agents having a need to know.
When we engage a third party service provider to collect or otherwise process personal information on our behalf, the third party is selected carefully and will be required to have appropriate security measures in place.
Global Relay’s website contains hypertext links to other sites as a convenience to users. We are not responsible for the privacy practices or contents of any information provided by outside sites through these links. You will need to check the policy statement of these other sites to understand their policies. If you access a linked site you may be disclosing your personal information. It is your responsibility to keep such information private and confidential.
Transfer of Your Personal Information
Global Relay’s operational center is located in Canada. Canada has robust and comprehensive laws that protect your personal information. The European Commission has recognized Canada as an “adequate” jurisdiction that offers a level of data protection similar to the European Economic Area (EEA).
However, as a global business with offices, employees, entities, and service providers all over the world, we may need to transfer your personal information across international borders to countries that have different levels of data protection laws than the country from where you submitted your personal information. In these circumstances we will take appropriate steps to reasonably ensure that your personal information is treated securely and as described in this Privacy Statement, in accordance with applicable data protection laws. These steps will include appropriate contractual mechanisms (such as the Model Clauses adopted by the European Commission to provide safeguards for personal information transferred outside of the EEA) or other approved methods.
Your Rights Regarding Your Personal Information
Global Relay will try to keep your personal information accurate. We will provide you with access to your information and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your information.
If you are located in the EEA or the United Kingdom: the European Union’s General Data Protection Regulation 2016/679 (GDPR) and/or the Data Protection Act 2018 (c12) provide certain rights in relation to your personal information. Subject to any exemptions or limitations provided by the applicable law, you have the right to be informed about the collection and use of your personal data, to access and receive a copy of information we hold about you, to rectify any personal information held about you that is inaccurate and to request the deletion of personal information held about you. You also have the right to data portability for personal information you provide to us – this means that you can obtain a copy of your personal information in a commonly used electronic format so that you can manage and move it, or request we send it to a third party. You may have the right to restrict or object to the processing of your personal information by us including for marketing purposes.
If you are a Californian Resident: the California Consumer Privacy Act of 2018 (CCPA) provides certain rights, subject to certain limitations, in relation to your personal information, including the right to non-discrimination for exercising your CCPA rights, the right to know about the personal information we’ve collected about you in the past 12 months and how it is used and shared (which is described in this Privacy Statement), and the right to deletion. Individuals protected by the CCPA also have the right to opt-out of the sale of your personal information. Global Relay does not currently “sell” (as defined in the CCPA) the personal information that we collect from you. Should this change in the future, Global Relay will ensure that the right to opt-out is made available to you. For clarity, this Privacy Statement constitutes Global Relay’s “notice at collection” under the CCPA.
In the event that you wish to exercise your rights regarding your personal information or make a complaint about how we process your personal information, please contact us at firstname.lastname@example.org. and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with any supervisory authority.
If you have any questions or concerns about this Privacy Statement, wish to contact our Data Protection Officer, or wish to make a complaint in the case you believe your personal information was not respected, please contact us using the details below.
If you are located outside the EEA:
Global Relay Communications Inc.
Attn: Privacy or Legal
220 Cambie Street, 2nd Floor
Vancouver, BC V6B 2M9, Canada
If you are located in the EEA:
Global Relay Communications Inc.
Attn: Privacy or Legal
45 Cannon Street
London, UK EC4N 5SH
Phone: +44 (0) 203.139.9064