Privacy Policy

Who We Are and Why We Collect Your Information

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”).

We are committed to protecting the confidentiality, integrity, and security of your personal information. We take this responsibility seriously. This Privacy Policy is intended to help you understand how we collect and safeguard your information. By accepting the terms of this Privacy Policy, you hereby consent to our collection, use, and sharing of your information in the following ways.

I. What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States(such statutes, the “PII Laws”), (2) information protected by the California Consumer Privacy Act (the “CCPA”) and the California Online Privacy Protection Act (“CalOPPA”), (3) personal information and private information, as defined by the New York Stop Hacks and Improve Electronic Data Security Act (the “SHIELD Act”); (4) protected health information (“PHI”), as defined by the Health Insurance Portability and Accountability Act (“HIPAA”), (5) personal data, as defined by the European Union General Data Protection Regulation (the “GDPR”), and (6) personal information, as defined by Canada’s Personal Information Protection and Electronics Documents Act (“PIPEDA”, and collectively with the PII Laws, CCPA, CalOPPA, the SHIELD Act, HIPAA, and GDPR, the “Privacy Laws”) (collectively, “Personal Information”), which we gather when you access, view, complete, or use any of the Services or any webpage that hosts an App. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

II. What Information Does Global Guardian Collect?

Global Guardian does not collect Personal Information indiscriminately. We limit the type of Personal Information and the amount of Personal Information to what is necessary to fulfill the purposes identified in this Privacy Policy. With that in mind, we collect the following types of information from you:

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:

• your name;
• personal contact information, including phone number and/or email address;
• business contact information, including name, address, telephone number, and email address;
• travel information;
• health information;
• racial or ethnic demographic information;
• medical history;
• family member contact information;
• passport information;
• employment information;
• financial institution and account information;
• Voice recordings when you contact us via phone, Skype, etc.;
• user name or e-mail address in combination with a password or security question that would permit access to the Services; and
• the contents of any communications.

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:

• IP Addresses. Some Apps use IP addresses. An IP address is a number assigned to your computer by your internet service provider to access the internet. In most consumer cases an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user's computer). 
• Cookies. Cookies are small files that are stored on your computer, smartphone or other device by your web browser. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. They are widely used to make websites work, or work more efficiently, and to provide information to the owners of the site. We may collect the following information via cookies: information related to your use of any webpage that hosts an App (including your password, the links you click on, your movement around the site, the pages you visit, the number of times you open a page, information you consult, the website from which you arrived, your language, your access times, and other tracking of online behavior); your IP address; your device; your unique device identifier; your operating system; and your browser type. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to refuse some or all cookies, or to delete existing cookies from your device. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services’ features. This Privacy Policy does not cover the use of cookies by any third parties.
• GPS Location Data and Other App Data. When a user downloads one of the Apps onto his or her smartphone, Global Guardian uses the App to obtain GPS location data passively from the user’s smartphone.
• Video Recordings and Security Alarm Information. In the event that we install security cameras and/or alarms in or around your home or office, we will collect information automatically from those devices. This information may include (1) video footage of you and other people in or around your home, and (2) the detection of one or more visitors or intruders.

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:

Attn: Data Protection Officer
Global Guardian LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
(703) 566-9463
privacy@globalguardian.com

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.

Global Guardian may collect the following Personal Information, which may fall within a special category of Personal Information under the GDPR: race and/or ethnicity information as part of the demographic information you provide us; health information; and medical history. Except as stated otherwise in the previous sentence or elsewhere in this Privacy Policy, we do not knowingly collect special categories of Personal Information, including (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, and (2) genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation.

F. Personal Information Global Guardian Has Collected in the Last 12 Months

Global Guardian has collected the following categories of Personal Information in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the bottom of this document: names; personal contact information; business contact information; travel information; health information; racial or ethnic demographic information; medical history; family member contact information; voice recordings; passport information; employment information; financial institution and account information; user name e-mail address in combination with a password or security question that would permit access to the Services; the content of communications; IP addresses; information related to the use of any webpage that hosts an App; device types; unique device identifiers; operating systems; browser types; video recordings; security alarm information; location data; email confirmations; employment information; information regarding trip itineraries, and travel-related information.

III. What Does Global Guardian Do With Personal Information?

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:

• Monitor you while traveling and provide emergency response upon request;
• Communicate with you while traveling;
• Send real time travel alerts;
• Provide country-specific travel advice;
• View your travel itinerary;
• Coordinate medical services and support;
• Evacuate you from other countries in the event of emergency (medical, civil unrest, etc.);
• Provide cyber security to your home or work;
• Provide aviation support while traveling;
• Maintain video surveillance of your home or work;
• Communicate with you and law enforcement about observed potential threats to your home, work, or electronic resources; and
• Communicate with your employer regarding your travel.

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:

• Managing our relationship with you;
• Communicating with you about our products, services, promotions, surveys, or support;
• Sending marketing communications;
• Providing products, services, promotions, surveys, and support to you;
• Assessing and improving the performance and operation of the Services;
• Keeping your contact details up to date and providing updated details to our service providers and suppliers where necessary;
• Processing and responding to any complaint made by you;
• Preventing and detecting security threats, fraud, or other malicious activity; and
• Improving and developing our products, services, and support through quality control, research, and data analysis activities.

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.

IV. Will Global Guardian Share Any of the Personal Information it Collects?

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.

In the event that your employer has retained us to provide the Services to you, we will disclose Personal Information to your employer.

1. Third Party Businesses that Provide Security Services

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.

2. Third Party Businesses that Interact with 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.

3. Third Party Businesses that Assist Global Guardian Business Operations

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.

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.

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.

Global Guardian does not sell Personal Information, but we disclose to clients certain Personal Information of their employees when we are retained to provide Services to employees. Global Guardian has disclosed the following categories of Personal Information to our clients in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the bottom of this document: health information; medical history; personal contact information; family member contact information; trip itineraries; travel-related information; and location data.

G. Personal Information Global Guardian Has Disclosed to Third Parties in the Last 12 Months

In the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the bottom of this document, Global Guardian has disclosed the following categories of Personal Information to third parties that provide business and operational services to us: names; personal contact information; business contact information; travel information; health information; racial or ethnic demographic information; medical history; family member contact information; voice recordings; passport information; employment information; financial institution and account information; the content of communications; user name e-mail address in combination with a password or security question that would permit access to the Services; IP addresses; information related to the use of any webpage that hosts an App; device types; unique device identifiers; operating systems; browser types; video recordings; security alarm information; location data; email confirmations; employment information; information regarding trip itineraries, and travel-related information.

V. Global Guardian’s Legal Basis for Collecting and Using Your Personal Information

To the extent possible, Global Guardian collects and uses your Personal Information pursuant to your informed consent, which you have granted by confirming the prompts produced when you initially provided Personal Information. Please note that without your consent to collect and use the Personal Information required for any particular Service, Global Guardian may not be able to provide that Service. If you have any questions concerning the terms of this Privacy Policy and the conditions of your consent, please contact us at:

Attn: Data Protection Officer
Global Guardian LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
(703) 566-9463
privacy@globalguardian.com

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.

VI. How Long Will Global Guardian Retain Your Personal Information?

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:

• PHI Collected as Part of the Air Ambulance Services. Global Guardian retains for at least 6 years the PHI collected by our Air Ambulance subsidiary as part of providing the Air Ambulance Services.
• Marketing Information If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in the Security Services. Every marketing email we send will provide you with the option to opt out of receiving future emails.
• Other Information. Other than as described above, we will determine the retention period for your Personal Information based on the following criteria:
1. The nature of our relationship with the relevant client;
2. The nature of our relationship with you;
3. The nature of the Personal Information in question; and
4. Our internal research needs.

VII. What Are Your Rights to Control Your Personal Information?

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:

Attn: Data Protection Officer
Global Guardian LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
(703) 566-9463
privacy@globalguardian.com

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:

Opt-Out 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:

Attn: Data Protection Officer
Global Guardian LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
(703) 566-9463
privacy@globalguardian.com

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:

Attn: Data Protection Officer
Global Guardian LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
(703) 566-9463
privacy@globalguardian.com

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.

Under the CCPA: You may file a complaint with the California Attorney General’s Office, although please note that the CCPA is not effective as of the date of this Privacy Policy and that the rules governing the CCPA and the formal complaint mechanism have yet to be established.

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:

Attn: Data Protection Officer
Global Guardian LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
(703) 566-9463
privacy@globalguardian.com

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.

VIII. Disclosures Specific to PHI Collected as Part of the Air Ambulance Services

This section explains (A) your rights regarding the PHI collected as part of the Air Ambulance Services, (B) your choices regarding that PHI, (C) our uses and disclosures of that PHI, and (D) Global Guardian’s responsibilities specific to PHI collected as part of the Air Ambulance Services. Except as noted below, the terms of this Privacy Policy govern your PHI collected as part of the Air Ambulance Services.

A. Your Rights

You may:

• Get an electronic or paper copy of your medical record;
• Request a copy or a summary of your health information (for which we may charge a reasonable, cost-based fee);
• Ask us to correct your medical record, although we refuse and provide an explanation in writing within 60 days;
• Request confidential communications or that we contact you in a specific way;
• Ask us to limit the PHI we use or share for treatment, payment or our operations, although we may refuse if it would affect your care;
• Ask us not to share information with your health insurer regarding particular services or health care items if you pay for them out-of-pocket (which we will agree to unless a law requires us to share that information);
• Ask for a list (accounting) of the times we’ve shared your PHI for six years prior to the date you ask, who we shared it with, and why (which we will provide without charge once each year, and subject to a reasonable, cost-based fee thereafter;
• Get a copy of this Privacy Policy;
• Choose someone to act for you, provided we can confirm that person has the necessary authority and documentation (such as a medical power of attorney) to act for you before we take any action;
• File a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/ (for which we will not retaliate against you).

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:

• Treat you: We can use your PHI and share it with other professionals who are treating you.
• Operate the Air Ambulance Services: We can use and share your PHI to operate the Air Ambulance Services, improve your care, and contact you when necessary.
• Bill for services provided to you: We can use and share your PHI to bill and get payment from health plans or other entities.
• Help with public health and safety issues: We can share your PHI for certain situations such as: preventing disease; helping with product recalls; reporting adverse reactions to medications; reporting suspected abuse, neglect, or domestic violence; and preventing or reducing a serious threat to anyone’s health or safety.
• Conduct research: We can use or share your information for health research.
• Comply with the law: We will share your PHI if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we comply with federal privacy law.
• Respond to organ and tissue donation requests: We can share PHI with organ procurement organizations.
• Work with a medical examiner or funeral director: We can share PHI with a coroner, medical examiner, or funeral director when an individual dies.
• Address workers’ compensation, law enforcement, and other government requests: We can use or share your PHI: For workers’ compensation claims; for law enforcement purposes or with a law enforcement official; with health oversight agencies for activities authorized by law; and for special government functions such as military, national security, and presidential protective services.
• Respond to lawsuits and legal actions: We can share your PHI in response to a court or administrative order, or in response to a subpoena.

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.

IX. Is Personal Information About Me Secure?

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.

You may have accessed the Services from sites that we do not control. Additionally, the Services may contain links to sites we do not control. We are not responsible for the privacy policies and/or practices on sites we do not control. When viewing or following a link to another site you should read that site’s privacy policy.

X. Children’s Privacy

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:

Attn: Data Protection Officer
Global Guardian LLC
8280 Greensboro Drive, Suite 750
McLean, VA 22102
(703) 566-9463
privacy@globalguardian.com

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.

XI. Contractual or Statutory Requirement

Except as noted in this Privacy Policy, Global Guardian’s collection and use of Personal Information is not a contractual or statutory requirement or a requirement necessary to enter into a contract.

XII. Failure to Provide Personal Information

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.

XIII. Automated Decision Making

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.

XIV. Transfer of Data

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.

XV. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our website or sending you an email. You are bound by any changes to the Privacy Policy when you use any Service after such changes have been first posted.

XVI. Questions or Concerns; Contact Information

If you have any questions or concerns regarding our privacy policies, please contact our data protection officer by sending a detailed message to privacy@globalguardian.com. 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
(703) 566-9463

We will make every effort to resolve your concerns.

XVII. Translations

This Privacy Policy was originally published in English and may be translated into other languages. The content of the English original shall prevail in case of differences in the content or context of other language versions.

Effective Date: November 12, 2019