Privacy Policy

GLOBAL MILLIONAIRES INC. PRIVACY POLICY

1 Introduction

Global Millionaires Inc. (“Global Millionaires” or "we") values and respects the privacy of individuals and as a result we have created our Privacy Policy to align with applicable data protection laws (including the United States Federal and applicable state law, and the European General Data Protection Regulation (Regulation (EU) 2016/679)) and any other legislation in force which applies relating to either or both privacy or the handling of personal data (the "Data Protection Legislation").  This Privacy Policy is effective [July 28, 2018].

  • This Privacy Policy aims to clearly outline our policies and procedures for collecting, using, storing and disclosing personal data of individuals. All of the different forms of data, content, and information described in this Privacy Policy are collectively referred to as “personal data”.
  • Global Millionaires’ service offering involves providing individuals, organizations and individuals within those organizations with access to and use of the Global Millionaires Services (the "Services") through their devices (any computer device used to access the Global Millionaires Website (the “Application”), including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each a "Device")).
  • This Privacy Policy explains what we do with your personal data when:
    • you sign up to the Service and you access the Global Millionaires Application using an account via our website (www.GlobalMillionairesInc.com), subdomain (*.Global Millionaires.com), through applications on devices, through APIs, or through third-parties (together, the "Application Users");
    • you cease to access the Global Millionaires Application ("Former Application User");
    • you visit our website (www.GlobalMillionairesInc.com) and subdomain (*.GlobalMillionairesInc.com) (the "Website") while browsing the internet (together, the "Website Users"); and
    • you call our customer service team or sales team for any purpose ("Phone User").

 

  • If you are an Application User, our primary purpose for using your personal data is to provide the Service to you. When we use your personal data to allow you to access and use the Global Millionaires Application, we do so on your behalf. This makes us a "data processor" for the purposes of the Data Protection Legislation.  However, there may be certain circumstances under which we use your personal data for purposes that are not on your behalf, for example, where we need to use it for our own purposes. Under these circumstances, we are a "data controller" for the purposes of the Data Protection Legislation. Please see section 4 ("How do we use your personal data") for more information.
  • If you are a Former Application User, we may retain your personal data to maintain a limited version of your account profile and for our own purposes, for example, where we wish to offer you services which we think you may be interested in. This makes us a "data controller" for the purposes of the Data Protection Legislation. Please see section 4 ("How do we use your personal data") for more information.
  • If you are a Website User, we use your information for our own purposes. This makes us a "data controller" for the purposes of the Data Protection Legislation. Please see section 4 ("How do we use your personal data") for more information.
  • If you are a Phone User, we may record your call for our own purposes. This makes us a "data controller" for the purposes of the Data Protection Legislation. Please see section 4 ("How do we use your personal information") for more information.
  • It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

 

2 WHAT KIND OF PERSONAL DATA DO WE COLLECT?

Application Users:

  • We need to use personal data about you in the course of providing the Service to you and for ancillary purposes set out in this Privacy Policy. Depending on the relevant circumstances and requirements, we may collect some or all of the personal data listed below to help us with this:
    • Name;
    • Phone number;
    • Date of Birth;
    • Gender;
    • Credit card details or other billing information;
    • Email address;
    • Home and business postal addresses;
    • Profile photo;
    • Contacts (if we are provided with access to your third party services (for example, your email account));
    • Any further personal data contained in any files that you upload, download, or create ("Files") within the Global Millionaires Application; and
    • Log data from your Device, its software, and your activity using the Global Millionaires Application including the Device’s Internet Protocol (“IP”) address, browser type, locale preferences, geo-Location Information, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your Files, and other interactions with the Global Millionaires Application.
    • We will retain the following personal data listed below:
      • Name;
      • Phone number;
      • Date of Birth;
      • Gender;
      • Credit card details or other billing information (if you were the primary account holder in relation to your business account);
      • Email address;
      • Home and business postal addresses;
      • Profile photo;
      • Emergency contact details;
      • Any further personal data contained in any files that you uploaded, downloaded, or created ("Files") within the Global Millionaires Application; and
      • Log data from your Device, its software, and your activity when you used the Global Millionaires Application including the Device’s Internet Protocol (“IP”) address, browser type, locale preferences, geo-Location Information, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your Files, and other interactions with the Global Millionaires Application.
  • We collect a limited amount of personal data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes log data such as your Device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information and other interactions with the Website. If you contact us via the website (including via any chat widget), we will collect any information that you provide to us, for example your name and contact details.
  • We may collect a limited amount of personal data by recording and subsequently storing certain telephone calls. On each occasion, you will be notified whether the call is being recorded at the commencement of the call. The primary purpose of the call recording is to improve the quality of the services we provide. During the course of the phone call we will collect limited categories of personal data including name, phone number, and email address to assist us in confirming the identity of the caller.

Former Application Users:

 

  • We will retain the following personal data listed below:
    • Name;
    • Phone number;
    • Date of Birth;
    • Gender;
    • Credit card details or other billing information (if you were the primary account holder in relation to your business account);
    • Email address;
    • Home and business postal addresses;
    • Profile photo;
    • Emergency contact details;
    • Any further personal data contained in any files that you uploaded, downloaded, or created ("Files") within the Global Millionaires Application; and
    • Log data from your Device, its software, and your activity when you used the Global Millionaires Application including the Device’s Internet Protocol (“IP”) address, browser type, locale preferences, geo-Location Information, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your Files, and other interactions with the Global Millionaires Application.


Website Users:

 

We collect a limited amount of personal data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes log data such as your Device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information and other interactions with the Website. If you contact us via the website (including via any chat widget), we will collect any information that you provide to us, for example your name and contact details.


Phone Users:

 

We may collect a limited amount of personal data by recording and subsequently storing certain telephone calls. On each occasion, you will be notified whether the call is being recorded at the commencement of the call. The primary purpose of the call recording is to improve the quality of the services we provide. During the course of the phone call we will collect limited categories of personal data including name, phone number, and email address to assist us in confirming the identity of the caller.

3 HOW DO WE COLLECT YOUR PERSONAL DATA?

Application Users:

  • We collect your personal data in three primary ways:
  1. Personal data that you provide to us;
  2. Personal data that we receive from other sources; and/or
  3. Personal data that we collect automatically.

Personal data you give to us

  • Where you provide personal data to us when you use the Global Millionaires Application;
  • Where you contact us via the Global Millionaires Application; and/or
  • Where you upload, download, or create Files within the Global Millionaires Application
  • Where we receive personal data about you from other sources, such as previous or current employers; and/or
    • Where we receive personal data (for example, your email address) through other Application Users, if they have invited you to their Global Millionaires account
    • When you use the Application, where we automatically record personal data in the form of log data from your Device, its software, and your activity using the Global Millionaires Application; and/or
    • Where we collect your personal data automatically via cookies, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see section 11 ("Cookies").

Personal data we receive from other sources

¥ Where we receive personal data about you from other sources, such as previous or current employers; and/or
¥ Where we receive personal data (for example, your email address) through other Application Users, if they have invited you to their Global Millionaires account

Personal data that we collect automatically

¥ When you use the Application, where we automatically record personal data in the form of log data from your Device, its software, and your activity using the Global Millionaires Application; and/or
¥ Where we collect your personal data automatically via cookies, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see section 11 ("Cookies").

 

Former Application Users:

  • We will have collected your personal data during the period that you were an Application User in the manner described above.

 

Website Users:

  • When you visit our Website there is certain personal data in the form of log data that we may automatically collect, whether or not you use the Global Millionaires Application.
  • We also collect some limited personal data automatically via cookies, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see section 11 ("Cookies").

 

Phone Users:

  • As set out in section 2 above, we collect a limited amount of personal data by recording and subsequently storing certain telephone calls. On each occasion, you will be notified at the commencement of the call whether the call is being recorded and for what purpose.

 

4 HOW DO WE USE YOUR PERSONAL DATA?

Application Users:

  • Our primary purpose for using your personal data is to provide the Service to you.  When we use your personal data to allow you to access and use the Global Millionaires Application, we do so on the instructions of you and on the behalf of you. This makes us a "data processor" for the purposes of the Data Protection Legislation. Activities that we may carry out on this basis include:
  • Allowing you to access and use the Global Millionaires Application;
    • Providing you with assistance (including technical assistance) in relation to your use of the Global Millionaires Application;
    • Personalizing and optimizing your experience of the Global Millionaires Application and providing you with software updates; and
    • Ensuring compliance with the terms of our agreement with you.

 

  • However, there may be certain circumstances under which we use your personal data for purposes that are not on your behalf or in accordance with your instructions. Under these circumstances, we are a "data controller" for the purposes of the Data Protection Legislation. Activities that we may carry out on this basis include:
    • Making announcements to you regarding our products and service offerings (see section 5 ("Marketing") below);
    • Providing you with any service offering outside of the Global Millionaires Application directly;
    • Ensuring compliance with our own obligations under applicable law and regulations;
    • Using your personal data to help us to establish, exercise or defend legal claims; and
      • Analyzing log data/user statistics with the aim of improving the Global Millionaires Application for all Application Users.

 

We may use your personal data for these purposes if we have a legal basis for doing so. If you would like to know more about what this means, please see section 12 ("Legal bases for processing your personal data"). If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this in section 9 ("How can you access, amend or take back the personal data that we hold about you").

 

Former Application Users:

  • If we retain your personal data once you have left your organization and cease to use your Global Millionaires Account for our own purposes, we are a "data controller" for the purposes of the Data Protection Legislation. Activities that we may carry out on this basis include:
    • Making announcements to you regarding our products and service offerings (see section 5 ("Marketing") below);
    • Providing you with any service offering outside of the Global Millionaires Application directly;
    • Ensuring compliance with our own obligations under applicable law and regulations; and
    • Using your personal data to help us to establish, exercise or defend legal claims.

 

  • We may use your personal data for these purposes if we have a legal basis for doing so. If you would like to know more about what this means, please see section 12 ("Legal bases for processing your personal data"). If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this in section 9 ("How can you access, amend or take back the personal data that we hold about you").
  • We use your personal data to help us to improve your experience of using our website, for example by analyzing your recent search criteria to help us to present information to you that we think you will be interested in. This makes us a "data controller" for the purposes of the Data Protection Legislation.

Website Users:

 We use your personal data to help us to improve your experience of using our website, for example by analyzing your recent search criteria to help us to present information to you that we think you will be interested in. This makes us a "data controller" for the purposes of the Data Protection Legislation.

Phone Users:

  • We use your personal data to help us to improve our customer experience, for example by analyzing whether the personal data we collect is suitable for the purpose of verifying the identity of the caller. This makes us a "data controller" for the purposes of the Data Protection Legislation.

 

5 MARKETING

  • If you are an Application User or a Former Application User, we may wish to use your personal data in order to let you know about, and invite you to participate in, our products and service offerings.
  • We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt-in or soft opt-in (which we explain further below).
  • Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by signing up to the Global Millionaires Application or requesting more information about our service offerings), and we are marketing service offerings similar to those you have previously engaged with us above. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For other types of e-marketing, we are required to obtain your explicit consent.
  • We will not, as a matter of course, seek your consent when sending marketing materials to a corporate email address. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so in section 9 ("How can you access, amend or take back the personal data that we hold about you?").
  • If you want to know more about how we obtain consent, please see section 12 ("Legal bases for us processing your personal data"). If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so in section 9 ("How can you access, amend or take back the personal data that we hold about you?")
    • Where appropriate and in accordance with applicable laws and requirements (and where we use your personal data as a data processor on behalf of and under your instructions in accordance with our obligations under our agreement with you), we may share your personal data in the following ways:
      • Your Use: We will display your personal data on your profile page and this may be accessed by other persons to whom you are connected depending on their access level. If you use community services on the Global Millionaires Application such as blogs, forums, and wikis, you should be aware that any personal data you provide in these areas may be read, collected, and used by Application Users who access them. Your posts may remain even after you close your account.
      • Service Providers, Business Partners and third parties: We may use certain trusted third party companies and individuals to help us provide, analyze, and improve the Global Millionaires Application (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improving the features of the Global Millionaires Application). These third parties may have access to your personal data only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.
      • Other Service Providers, Business Partners and third parties: We may share your personal data with our agents or third party service providers (including professional advisers and telecommunication service providers) which require your personal data to provide their services to Global Millionaires. Such agents and third party service providers will not be permitted to use your personal data for any other purpose.
      • Third-Party Applications: We may share your information with a third party application with your consent, for example when you choose to access Global Millionaires through such an application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you before allowing this feature to be employed.
      • Compliance with Laws and Law Enforcement Requests: We may disclose to parties outside Global Millionaires, Files stored in your Global Millionaires Application and personal data about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; or (b) to protect Global Millionaires’ intellectual property rights. If we provide your Files to a law enforcement agency as set forth above, we will remove Global Millionaires’ encryption from the files before providing them to law enforcement.
      • Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on our website) of any change in control or use of your personal data or Files, or if either become subject to a different Privacy Policy.
      • Non-private or Non-Personal data: We may disclose your non-private, aggregated, or otherwise non-personal data, such as usage statistics of the Global Millionaires Application.
      • Group Companies: We may share your personal data with our group companies.

6 INFORMATION SHARING & DISCLOSURE

 

 Where appropriate and in accordance with applicable laws and requirements (and where we use your personal data as a data processor on behalf of and under your instructions in accordance with our obligations under our agreement with you), we may share your personal data in the following ways:
¥ Your Use: We will display your personal data on your profile page and this may be accessed by other persons to whom you are connected depending on their access level. If you use community services on the Global Millionaires Application such as blogs, forums, and wikis, you should be aware that any personal data you provide in these areas may be read, collected, and used by Application Users who access them. Your posts may remain even after you close your account.
¥ Service Providers, Business Partners and third parties: We may use certain trusted third party companies and individuals to help us provide, analyze, and improve the Global Millionaires Application (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improving the features of the Global Millionaires Application). These third parties may have access to your personal data only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.
¥ Other Service Providers, Business Partners and third parties: We may share your personal data with our agents or third party service providers (including professional advisers and telecommunication service providers) which require your personal data to provide their services to Global Millionaires. Such agents and third party service providers will not be permitted to use your personal data for any other purpose.
¥ Third-Party Applications: We may share your information with a third party application with your consent, for example when you choose to access Global Millionaires through such an application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you before allowing this feature to be employed.
¥ Compliance with Laws and Law Enforcement Requests: We may disclose to parties outside Global Millionaires, Files stored in your Global Millionaires Application and personal data about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; or (b) to protect Global Millionaires’ intellectual property rights. If we provide your Files to a law enforcement agency as set forth above, we will remove Global Millionaires’ encryption from the files before providing them to law enforcement.
¥ Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on our website) of any change in control or use of your personal data or Files, or if either become subject to a different Privacy Policy.
¥ Non-private or Non-Personal data: We may disclose your non-private, aggregated, or otherwise non-personal data, such as usage statistics of the Global Millionaires Application.
¥ Group Companies: We may share your personal data with our group companies.

7 HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

  • We are committed to taking all reasonable and appropriate steps to protect the personal data that we hold from misuse, loss, destruction or unauthorized access. We do this by having in place a range of appropriate technical and organizational measures. These include measures to deal with any suspected data breach. If you enter payment details onto our payment pages, we encrypt the transmission of that information using secure socket layer technology (SSL) which is PCI compliant.
  • All call recordings that we (or our third party service providers) collect and store are encrypted.
  • For more information about the security measures that we have put in place, please click here: [https://globalmillionairesinc.com/security-policy]
  • We will not keep your personal data for longer than we are permitted to do so under our agreement with you or as is necessary for the purposes for which we have collected it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements.
  • When we are no longer permitted under our agreement with you or it is otherwise no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. While we will endeavor to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.
  • All Call Recordings are stored for a maximum of 1 year from the date of collection where after they are automatically deleted.

8 HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will not keep your personal data for longer than we are permitted to do so under our agreement with you or as is necessary for the purposes for which we have collected it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements.

When we are no longer permitted under our agreement with you or it is otherwise no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. While we will endeavor to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.
All Call Recordings are stored for a maximum of 1 year from the date of collection where after they are automatically deleted

 

9 HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT WE HOLD ABOUT YOU?

  • You have various rights in relation to the personal data that we hold about you.
  • To get in touch about these rights, please contact us.
  • If you are an Application User and you wish to make a request in relation to our use of your personal data, or you are a Former Application User or a Website User, please contact us and we will handle your request.
  • The Data Protection Legislation gives you the following rights in relation to your personal data:
  • Right to object: this right enables you to object to us processing your personal data
    • Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, sharing your information with a third party application), you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative legal basis to justify our continued processing of your personal data for this purpose, in which case we will inform you of this condition.
    • Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. You may also request a copy of the information we hold about you.
      • Right to erasure: You have the right to request that we "erase" your personal data in certain circumstances. We will try to delete your personal data quickly upon request and if desired make it available to you. While we will endeavor to permanently erase or return your personal data upon request, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this personal data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again. We may retain and use your personal data if we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements. If you are an Application User connected with an organization, we shall not delete or edit your personal data without the approval of your organization.
      • Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with

third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

  • Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you, including by means of providing a supplementary statement. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
    • Right of data portability: If you wish, you have the right to request that we transfer your personal data to another third party. To allow you to do so, we will provide you with your personal data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the personal data for you. This right of data portability only applies to certain types of personal data.
    • Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

 

10 HOW DO WE STORE AND TRANSFER YOUR PERSONAL DATA INTERNATIONALLY?

  • In order for us to carry out the functions described in this Privacy Policy (for more details, please see section 4 ("How do we use your personal data?") your personal data may be processed by us (or our third party service providers) In the United States, in the European Economic Area (EEA), and other territories where the entities set out in section 6 are located ("Information Sharing and Disclosure").
  • We want to make sure that your personal data is stored and transferred in a way which is secure. If you are based within the EU we will only process and/or transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your personal data, including for example:
    • By way of a data transfer agreement with you, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws; or
    • By way of a data transfer agreement with a third party, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws; or
    • By transferring your personal data to an entity which has signed up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
    • By transferring your personal data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
    • Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer your personal data to a benefits provider based outside the EEA); or
    • Where you have consented to the data transfer.
      • We also use “cookies” to collect information and improve our Services. A cookie is a small data file that we transfer to your Device. We may use “persistent cookies” to save your registration ID and login password for future logins to the Service. We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Application.
      • Online Tracking: We may use internal and external analytic and product platforms to better understand usage patterns on our website so that we can improve the design and usability of our products. Some web browsers may transmit “do-no-track” signals to websites with which the browser communicates.

11 COOKIES

We also use “cookies” to collect information and improve our Services. A cookie is a small data file that we transfer to your Device. We may use “persistent cookies” to save your registration ID and login password for future logins to the Service. We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Application.

Online Tracking: We may use internal and external analytic and product platforms to better understand usage patterns on our website so that we can improve the design and usability of our products. Some web browsers may transmit “do-no-track” signals to websites with which the browser communicates.

12 LEGAL BASES FOR US PROCESSING YOUR PERSONAL DATA

Where we process your personal data as a data processor on behalf of and under your instructions, you are responsible for ensuring that there is a legal basis for us processing your personal data on their behalf.

Where we process your personal data as a data controller, we need to ensure that there is a legal basis to justify our processing of your personal data. There are a number of different ways that we are lawfully able to process your personal data. We have set these out below.

Where processing your personal data is necessary for us to carry out our obligations arising from any contracts entered into between you and us

  • We process certain personal data where it: "is necessary for the performance of a contract to which [you] are a party.”
  • If you enter into a contract with us in relation to any service offerings outside of the Global Millionaires Application, we may process certain personal data about you in order to perform our obligations under this contract.
  • We can process certain personal data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
  • We may process your personal data for the purposes of our legitimate interests to enforce the terms of our website and to analyze log data/user statistics to improve the Global Millionaires Application for all Authorized Users.
  • We do not think that any of our data processing activities prejudice individuals in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this above.
  • In certain circumstances, we will seek to obtain your opt-in consent before we undertake certain processing activities with your personal data. In plain language, this means that:
    • You have to give us your consent freely, without us putting you under any type of pressure;
    • You have to know what you are consenting to – so we'll make sure we give you enough information;
    • You should only be asked to consent to one processing activity at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to;
    • You need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion; and
    • We will obtain your opt-in consent prior to sharing your personal data with third party applications and carrying out certain marketing activities.
    • As and when we introduce these particular processing activities, we will provide you with more information so that you can decide whether you want to opt-in.
    • You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found above at section 9 ("How can you access, amend or take back the personal data that we hold about you").

Where processing your personal data is within our legitimate interests

We can process certain personal data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."

We may process your personal data for the purposes of our legitimate interests to enforce the terms of our website and to analyze log data/user statistics to improve the Global Millionaires Application for all Authorized Users.

We do not think that any of our data processing activities prejudice individuals in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this above.

Where you give us your consent to process your personal data

  • In certain circumstances, we will seek to obtain your opt-in consent before we undertake certain processing activities with your personal data. In plain language, this means that:
    • You have to give us your consent freely, without us putting you under any type of pressure;
    • You have to know what you are consenting to – so we'll make sure we give you enough information;
    • You should only be asked to consent to one processing activity at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to;
    • You need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion; and
  • We will obtain your opt-in consent prior to sharing your personal data with third party applications and carrying out certain marketing activities.
  • As and when we introduce these particular processing activities, we will provide you with more information so that you can decide whether you want to opt-in.
  • You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found above at section 9 ("How can you access, amend or take back the personal data that we hold about you").

We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal data in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please see section 9 ("How can you access, amend or take back the personal data that we hold about you").

13 WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA AND CONTACT INFORMATION

  • If you would like further information about how we handle your personal data, if you have any concerns regarding this Privacy Policy or if you wish to exercise your legal rights, please contact Info.GlobalMillionairesInc@gmail.com. Please outline to us your concerns and our legal team or Global Millionaires representative will be in touch to discuss the matter.
  • The company responsible for compliance with this Privacy Policy is Global Millionaires Inc., P.O. Box 77635, Corona, CA 92877.