Global Guardian, LLC (“Global Guardian,” “we,” “us,” “our”) provides security services to our clients, including, but not limited to: (1) GPS-based personnel and asset tracking globally, (2) emergency response teams in over 80 countries, (3) intelligence reports, (4) medical support and evacuation services (“Air Ambulance Services”), (5) cyber security, (6) global aviation support, and (7) real-time video surveillance (collectively, the “Security Services” and each individually, a “Security Service”). We rely on numerous applications, devices, and technological services to perform the Security Services, including, but not limited to, websites, web-based forms, applications on phones, video monitoring software, and data analytics programs (collectively, the “Apps,” and each individually, an “App”) (the Apps and Security Services are collectively referred to as the “Services” and each individually as a “Service”).
A. Information You Provide to Us:
We may collect Personal Information from you when (i) you contact us with questions or concerns, and (ii) you use, interact with, respond to, or answer questions from any of the Services. The information we collect depends on your needs and, if your employer has retained us to provide the Services to you, your employer’s needs. Examples of Personal Information we may collect include the following:
You can choose not to provide us with some or all of this information, although that may affect our ability to provide the Services to you.
B. Information Collected Automatically:
When you use a Service, certain information may be passively collected (that is, gathered without your actively providing the information) using various technologies and means, including, but not limited to, Internet Protocol (IP) addresses, cookies, and Global Positioning System (GPS) location data. These are described in more detail below:
C. E-mail and Other Communications:
We may contact you, by email or other means; for example, we may send you promotional offers on behalf of Global Guardian or our clients, or communicate with you about the Services. When we do this, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please indicate your preference by clicking on the unsubscribe link in any of our emails or by contacting us at:
Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.
D. Personal Information from Other Sources
After collecting Personal Information from you as described above, Global Guardian may use that Personal Information to collect further Personal Information about you from your employer and from travel agencies that are coordinating travel for you. The Personal Information collected from those sources may include, but is not limited to, employment information, information regarding trip itineraries, and other travel-related information.E. Special Categories of Personal Information
F. Personal Information Global Guardian Has Collected in the Last 12 Months
A. Provide Security Services to You
Global Guardian collects your Personal Information in order to provide Security Services to you and may use your Personal Information to:
B. Improve the Services We Provide to You
Global Guardian may also use your Personal Information to improve the services we provide to clients by:
We may derive your general geographic location (city, state or metropolitan region) based on your IP address. IP addresses may also be used to provide an audit trail regarding use of the Services.
We share your Personal Information with third parties as described below and acknowledge our potential liability if any such third parties misuse your Personal Information.A. Your Employer When Your Employer Has Retained Global Guardian to Provide the Services to You
In the event that your employer has retained us to provide the Services to you, we will disclose Personal Information to your employer.B. Third Party Businesses We Do Not Control
Global Guardian contracts with third party businesses to provide certain Security Services to you. For example, we rely on third parties to provide the Air Ambulance Services while you are traveling. Global Guardian only provides Personal Information to these third parties to the extent necessary to provide Security Services to you.
In certain situations, businesses or third party websites we are affiliated with may communicate with you, market to you, sell items, or provide services to you through emails or through a website (either alone or jointly with us). You can recognize when an affiliated business is associated with such communication, marketing, transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such activity. We have no control over the policies and practices of third parties or their websites as to privacy or anything else, so if you choose to engage with, enter into a transaction with, or to receive such service from a third party, please review the applicable third party’s privacy policies.
Global Guardian retains third party service providers and suppliers to manage or support its business operations, provide professional services, deliver complete products, services and customer solutions and assist Global Guardian with marketing and communication initiatives. These providers and suppliers may be located in the US or other locations and may include, for example, providers of customer support and live-help, marketing and communications, hosting and IT services, email services, automated data processors, shipping solutions, management and support of the Sites, order fulfillment services, and delivery services. Global Guardian will only disclose your Personal Information to such service providers and suppliers to the extent necessary for those third parties to provide services and supplies for Global Guardian.
C. Business Transfers
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.D. Legal Obligations, Our Protection, and the Protection of Others
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Global Guardian, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.E. With Your Consent
Except as set forth above, we will obtain your consent before disclosing your Personal Information with third parties, and you will be able to prevent the sharing of this information.F. Personal Information Global Guardian Has Sold in the Last 12 Months
G. Personal Information Global Guardian Has Disclosed to Third Parties in the Last 12 Months
For individuals and Personal Information Subject to the GDPR: In addition to relying on informed consent, Global Guardian reserves the right to process your Personal Information:
(1) As a processor, pursuant to the written authorization of a controller, i.e., your employer, as a client. Consistent with the GDPR, the controller determines the purposes and means of processing your Personal Information. As a processor, Global Guardian relies on the controller to obtain the necessary legal basis from each data subject before collecting and processing Personal Information. In the event that the controller does not have a legal basis to collect and process your Personal Information, the controller will be liable for all damages arising due to that deficiency.
(2) As a processor, in order to pursue the legitimate business interests of our clients, which is to provide security, medical, and other emergency services to their employees while traveling and in other defined situations.
(3) In order to pursue our legitimate business interests in assisting clients to protect their employees while traveling and in other defined situations.
(4) In order to perform a contract to which you are a party. Where the processing is based on a contractual requirement, your failure to provide the relevant Personal Information may result in Global Guardian being unable to assist with the completion of the contract. For example, if you do not provide your Personal Information, Global Guardian may not be able to provide medical or evacuation services while you travel.
Any one or more of these bases are the legal basis for our collection and use of your Personal Information, depending on (x) the Services Global Guardian provides to you, and (y) your relationship with Global Guardian.
Except upon the request of an individual, as explained in Section VII below, and except as the law permits and requires, Global Guardian maintains Personal Information as follows:
Except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding Global Guardian’s collection and use of your Personal Information.
A. Requests to Global Guardian:
You may request (1) the correction, updating, deletion, or restriction of collection and use of your Personal Information, (2) the categories of Personal Information Global Guardian has collected, (3) the categories of sources from which Global Guardian has collected your Personal Information, (4) the business purpose(s) for collecting and disclosing your Personal Information, (5) an account of how Global Guardian has used or is using your Personal Information, (6) a copy of your Personal Information retained by Global Guardian, to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible, (7) the categories of third parties with whom Global Guardian shares your Personal Information, (8) the categories of Personal Information which we share with third parties, and the contact information for such affiliates and/or third parties, (9) a list of all third parties that have received your Personal Information from Global Guardian, and (10) the specific pieces of Personal Information Global Guardian has collected about you. We will respond to all such requests at least 30 days, subject to lawful extension of that period, and there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your Personal Information be deleted or that we restrict our disclosure of your Persona Information such that we cannot provide that information to third parties we rely on to provide Services, we reserve the right to terminate and/or limit your access to the Services. If we do not have your Personal Information, have not collected your Personal Information, or have not disclosed or transferred your Personal Information to another party, we will inform you in response to a request regarding your Personal Information. Any of the above requests may be made by contacting us at:
When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
B. "Do Not Sell My Personal Information"
The CCPA permits consumers to instruct companies not to sell their Personal Information. Global Guardian does not sell your Personal Information, however Section 1798.135(t) of the CCPA defines “sell” broadly: “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.” This definition includes the employee Personal Information clients retain us to track and disclose to them.
You may opt out of this “sale” of your Personal Information by completing the form at the following link:
In the event your employer has retained us to provide Services to you, we reserve the right to terminate and/or limit your access to the Services in the event that the restrictions you place on the sale of your Personal Information prevent us from providing your employer with Personal Information necessary for Global Guardian to provide those Services.
If you exercise your right to opt out of all sales of your Personal Information, Global Guardian will cease disclosing your Personal Information to clients. Global Guardian will not contact you about opting in to disclosing your Personal Information to clients for at least 12 months following receipt of the form.
C. Withdrawal of Consent:
You may withdraw your consent at any time by contacting us at:
Please be aware that such withdrawal does not affect the lawfulness of Global Guardian’s use of your Personal Information before such withdrawal. We reserve the right to terminate and/or limit your access to the Services in the event that you withdraw your consent.
D. Do Not Track
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities, over time and across different websites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked. Setting or releasing your Do Not Track signal may affect how the Services operate. For clarity, this is just our Do Not Track Policy. Global Guardian does not make any promises about how third parties react when you set Do Not Track signals on your browser. In addition, the Do Not Track signal does not impact the use of information collected prior to such request.
E. Object or Challenge:
You may object, on grounds relating to your particular situation, at any time to the collection and use of your Personal Information based on Global Guardian’s legitimate interests or based on public interests, or otherwise challenge our compliance with the Privacy Laws, by contacting us at:
Global Guardian shall respond within at least 30 days, subject to lawful extension of that period. Where such objection is received from an individual whose Personal Information Global Guardian collects and uses as the processor for a controller (as those terms are defined in the GDPR), Global Guardian shall inform the controller of the objection within at least 30 days, subject to lawful extension of that period.
F. Filing a Complaint:
Regulatory authorities that oversee the Privacy Laws advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with Global Guardian’s response to an objection or challenge filed under Section VII.E above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:
Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada.
Under GDPR: You may file a complaint with a supervisory authority in the relevant European Union member state.
Under PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.
Please note that the links above are subject to change by the relevant regulatory authorities and that you may need to go to another site or contact the relevant authority in another way in order to properly file a complaint.
G. Unsubscribe to Subscription Communications
Subscription communications include email newsletters, software updates, etc., that may be expressly requested by you or which you consented to receive. After you request such communications, you may opt out of receiving them by using one of the following methods:
1. Select the email “opt out” or “unsubscribe” link, or follow the opt-out instructions included in each email subscription communication. To unsubscribe from messages delivered on any supported device, reply to the message with the word “UNSUBSCRIBE.”
2. You may contact Global Guardian directly at:
Be sure to provide your name, relevant contact information, and specific relevant information about the Global Guardian subscriptions that you no longer wish to receive.
Please be aware that when you opt out of receiving certain subscription communications, it may affect other services you have chosen to receive from Global Guardian where accepting the communications is a condition of receiving the services.
Upon receipt of your request we will unsubscribe you from such messages within seven days.
H. Prohibit Automated Processing:
At your request, Global Guardian will terminate any automated decision making, including profiling. Please see Section XIII for an explanation of the automated decision making Global Guardian utilizes.
A. Your Rights
B. Your Choices
You may instruct us about who we share your PHI with and how much PHI we share. For example, you may tell us to share information with your family, close friends, or others in a disaster relief situation. Except as stated below, we do not share your PHI unless you instruct us to do so.
C. Our Uses and Disclosures
We may use or share your PHI to:
D. Our Responsibilities
Global Guardian is required by law to maintain the privacy and security of your PHI. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your PHI. We must follow the duties and privacy practices described in this notice and give you a copy of it. We will not use or share your PHI other than as described here unless you tell us we can in writing. If you tell us we can use or share your PHI in a particular way, you may change your mind at any time and can send us different written instructions at that time.
We employ appropriate administrative, organizational, technical, and physical measures to protect your Personal Information, which we regularly review and update as necessary. Further information follows.
We endeavor to protect the privacy of your Personal Information that we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of information at any time.
At times, your access to the Services is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser.
We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us. No one under age 18 may provide any Personal Information to us or through the Services. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible, except as provided below. If you believe that we might have any information from a child under age 18, please contact us at:
Upon request, we will provide a parent or guardian who has provided proper identification with the following: (1) a description of the specific types of Personal Information collected from the child, (2) the opportunity to refuse or permit Global Guardian’s further collection and use of Personal Information from the child, and (3) a reasonable means for the parent or guardian to obtain any Personal Information collected from the child. If a parent or guardian does not permit Global Guardian’s continued collection and use of Personal Information from a child, Global Guardian will delete the child’s Personal Information and terminate the account of the child, as applicable.
You can always opt not to disclose information to us, but keep in mind some information may be needed to for Global Guardian to provide the Services to you.
Per Article 4(4) of the GDPR, profiling is defined as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.” Global Guardian does not rely on automated decision making, including profiling, that will produce legal effects concerning you or similarly significantly affect you.
When we transfer personal information from a country of origin to the United States, we do so in compliance with all laws of the originating country.
If you have any questions or concerns regarding our privacy policies, please contact our data protection officer by sending a detailed message to firstname.lastname@example.org. Alternatively, you may contact us by telephone or postal service as follows:
Attn: Data Protection Officer
Global Guardian, LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
We will make every effort to resolve your concerns.
Effective Date: November 12, 2019