Privacy Policy

Global Guardian, LLC (Global Guardian) respects the privacy of information that identifies you or is identifiable to you (Personal Information). We want you to understand how Global Guardian processes Personal Information, and how you can submit privacy rights requests to us concerning your Personal Information, in compliance with the various laws in the United States, Canada, European Union, and other countries that govern Global Guardian processing of Personal Information (Data Privacy Laws). Our processing of Personal Information is governed by those Data Privacy Laws as well as this Privacy Policy (Policy).

DATA PRIVACY OFFICER AND SECURITY POLICY

For questions about Global Guardian’s processing of Personal Information or this Policy, please contact our Data Privacy Officer as follows:

Name: Data Protection Officer

Phone: (703) 566-9463

Email: privacy@globalguardian.com
Address: 8280 Greensboro Drive, Suite 750, McLean, VA 22102

PERSONAL INFORMATION

Global Guardian provides security services to our clients (Clients), including, but not limited to: (1) GPS-based personnel and asset tracking globally, (2) emergency response, (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 (Security Services). We rely on numerous applications, devices, and technological services to perform the Security Services, including, but not limited to, websites, web-based forms, computer and mobile device applications, video monitoring software, and data analytics programs (Applications) (Applications and Security Services are referred to as Services).

Depending on how Clients interact with us, we may collect Personal Information when Clients: (1) register for Services; (2) send communications to us or contact us with questions or concerns; (3) use, interact with, respond to, or answer questions from any of the Services; (4) visit the Site or download Applications; (5) have a travel agency or employer interact with us to obtain information regarding travel-related information or employment information; (6) otherwise interact with us.  

In the course of providing the Services, Global Guardian receives from Clients, itself collects, and processes Personal Information, which may include the following: (1) identifiers, such as first and last name, email address, billing address, and phone number; (2) communication records, such as voice recordings when you contact us and the contents of any communications; (3) financial information, such as your financial institution, bank name, and account number, provided that Global Guardian does not store any such financial information and uses a third-party payment processor to process all payments; (4) employment information, such as current or past job title, and other employment-related information; (5) familial data, such as family member’s contact information; (5) travel information; (6) user name or e-mail address in combination with a password or security question that would permit access to the Services; (7) GPS location; and (8) video recording footage, in the event that we install or monitor security cameras and/or alarms around a Client’s home or office.  

SENSITIVE INFORMATION PROCESSED

In addition, depending on the nature of Services performed for the Client, and depending on the type of information provided by the Client to Global Guardian, in the course of providing Services to Clients, Global Guardian may receive from Clients, itself collect, and process certain limited types of Personal Information that is of a sensitive nature (Sensitive Personal Information), including information about the following: Clients who are children or children of Clients; health information and medical history; racial or ethnic demographic information; and passport number and other government issued identification information. For purposes of this Policy, Sensitive Personal Information is considered to be a special category of Personal Information.

Global Guardian has collected Personal Information in the last twelve months and processed it for the purposes described in this Policy.

LEGAL BASES FOR PROCESSING, AND USE OF, PERSONAL INFORMATION

Global Guardian processes Personal Information to perform our contractual and other commercial, business, and legal relationships with and obligations to provide Services to Clients. As a result, Clients provide Personal Information to Global Guardian and Global Guardian collects and processes Personal Information in order to provide the Services. In addition, Global Guardian seeks and obtains consent for the use and processing of Personal Information when required by Data Privacy Laws. Those are the legal bases for Global Guardian to process Personal Information.

Global Guardian may process Personal Information to: (1) provide Services to Clients; (2) monitor Clients while traveling; (3) provide emergency response upon request; (4) communicate with Clients while traveling; (5) send real time travel alerts; (6) provide country-specific travel advice; (7) view Clients’ travel itinerary; (8) coordinate medical services and support; (9) evacuate Clients from other countries in the event of emergency (medical, civil unrest, etc.) (10) provide cyber security to Clients’ home or work; (11) provide aviation support; (12) maintain video surveillance of Clients’ home or work; (13) communicate with Clients and law enforcement about threats; (14) communicate with Clients’ employers regarding Client travel; (15) develop and improve the Services and the Site; (16) communicate with Clients about the Services; (17) provide support for the Services including responding to requests, questions and feedback; (18) send Clients marketing and promotional communications; (19) preventing and detecting security threats, fraud, or other malicious activity; (20) comply with legal and regulatory obligations, and (21) establish, enforce, and otherwise exercise our rights and defend against claims.

DISCLOSURE OF PERSONAL INFORMATION

Except as necessary or appropriate to provide Services, Global Guardian does not disclose Personal Information about Clients to unaffiliated third parties, provided that we may disclose Personal Information for the following purposes and in the following circumstances.

• If directed to do so by the individual about whom such Personal Information pertains or that individual’s legal representative
• If required to do so by Data Privacy Law, any other law, rule, or regulation, legal process or warrant, or order of any court or governmental agency or authority
• With your employer, in the event your employer has retained us to provide the Service to you
• To third parties necessary or appropriate to provide the Services, such as third parties that provide Air Ambulance Services, providers of customer support and live-help, hosting and IT services, email services, automated data processors, shipping solutions, management and support of the Sites, order fulfillment services, delivery services, or any other third party that is necessary or appropriate for Global Guardian to disclose Personal Information to in order to provide the Services;
• To professional service providers, including attorneys, accountants, tax professionals, and financial advisers, if doing so is necessary or appropriate to obtain professional services from them
• In connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of Global Guardian
• To entities that perform marketing, advertising or market research on our behalf

In addition, in certain situations, Global Guardian may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Global Guardian will notify you of any such requests unless prohibited by law.

PRIVACY RIGHTS

Depending on the Personal Information that Global Guardian has about you, and depending on the manner in which we process your Personal Information, you may have the following privacy rights related to our processing of your Personal Information:

• Be informed about how your Personal Information is being processed, the categories of Personal Information being processed, and the categories of sources from which your Personal Information has been collected
• Be informed about whether and how your Personal Information being processed is being sold, shared, traded, exchanged or brokered with unaffiliated third parties, and which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with unaffiliated third parties
• Access or receive a copy of your Personal Information
• Rectify, update or correct inaccurate or incomplete Personal Information about you
• Erasure or deletion of certain categories of your Personal Information
• Object and opt-out of processing of your Personal Information
• Limit processing of your Personal Information
• Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties
• Portability of your Personal Information in a commonly used format
• Withdrawal of your consent to processing of your Personal Information to the extent such processing is based on your consent, provided that such withdrawal will not affect the lawfulness of Global Guardian’s use of your Personal Information before such withdrawal
• Non-discrimination for exercising your privacy rights

To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on this Site. We will confirm receipt of all such complete Privacy Rights Request Forms within 10 days of receipt. We will substantively respond to all such requests within 30 days, subject to any lawful extension of that period. Additionally, 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 person.

Please be aware there may be valid reasons to refuse a request, including legal and regulatory requirements that we retain and process certain information. Also, please be aware that certain requests may limit or prevent us from providing Services to you. In those situations, we will notify you in writing within 30 days. You may also contact our Data Privacy Officer for help with those situations.

Global Guardian will not discriminate against you if you exercise any of the foregoing rights or any other rights under Data Privacy Laws, including, by not denying Services to you, not providing a different level or quality of Services to you, and not suggesting that you will receive a different level or quality of Services.

SELLINg, SHARE, TRADING, EXCHANGING AND BROKERING PERSONAL INFORMATION

Except as otherwise disclosed in this Policy, Global Guardian does not sell, share, trade, or exchange Personal Information (including as those terms are defined and used in Data Privacy Laws) in any way, including for itself, or any unaffiliated third party. If and to the extent you want to opt-out of the sale, sharing, trading, or exchanging of your Personal Information, please complete and submit the Privacy Rights Request Form on this Site, and we will address such requests as described in the foregoing section of this Policy.

DATA PRIVACY FRAMEWORK NOTICE

Global Guardian complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce (collectively, the Data Privacy Framework) with respect to Personal Information we process from the EEA, the UK or Switzerland and transfer to the United States.

Global Guardian has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Information received from the European Union and the United Kingdom (and Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Global Guardian has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/.

The Federal Trade Commission has jurisdiction over Global Guardian’s compliance with the Data Privacy Framework.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

If and to the extent Global Guardian transfers Personal Information from another country into the United States, Global Guardian does so in compliance with the Privacy Laws of the originating country and for purposes outlined in this Policy. If and to the extent we transfer Personal Information of individuals in the EEA, Switzerland or the UK to the United States, we do so under the Data Privacy Framework. In addition, we also implement the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and the UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where appropriate.

LIABILITY FOR ONWARD TRANSFERS

We remain responsible and liable for the Personal Information that we receive under the Data Privacy Framework and subsequently transfer or disclose to third parties for external processing on our behalf, as described in the Policy. Global Guardian shall remain liable under the DPF Principles if such third parties process Personal Information in a manner inconsistent with the DPF Principles, unless Global Guardian proves that it is not responsible for the event giving rise to the damages.

AUTOMATED DECISION MAKING

Global Guardian does not use automated decision making or profiling in the processing of your Personal Information, and does not make decisions that affect you based on automated decision making or profiling using your Personal Information.

DURATION OF RETENTION

Because the Services that Global Guardian provides to Client’s vary significantly, the duration we retain Personal Information varies significantly, depending on the types of Services that Global Guardian provides to particular Client’s, the duration and depth of Global Guardian’s relationship with particular Client, and the nature of Personal Information in question. Global Guardian endeavors to retain Personal Information that it receives from or collects for only as long as is necessary or appropriate.

COOKIES

When you visit the Site, Global Guardian may place a cookie (a text file containing a randomly assigned number) on your device so that we have the ability to customize the look and feel of the Site for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the Site. Using cookies, we may also collect a variety of other information regarding your usage of the Site, including your Internet protocol address, username, session identification, browser you are using, web pages you view and referring web pages, when you access the Site, and general online behavior for performance and marketing purposes. You may decline to accept cookies by modifying your web browser settings. If you choose so, however, you may be unable to use all functions of the Site, or the Site may operate less efficiently.

RECOURSE MECHANISM AND BINDING ARBITRATION

In compliance with the Data Privacy Framework, we commit to resolve DPF Principles-related complaints about our processing of Personal Information. EU, UK, and Swiss citizens with inquiries or complaints regarding our processing of Personal Information received in reliance on the Data Privacy framework should first contact Global Guardian. In the event such complaints concerning our processing of Personal Information received in reliance on the Data Privacy Framework remain unresolved, EU, UK, and Swiss citizens may refer such unresolved complaints to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF-Principles-related complaint to your satisfaction, please visit [https://www.jamsadr.com/file-a-dpf-claim] for more information or to file a complaint. The services of JAMS are provided at no cost to you.

In case your complaint indicates a violation of obligations under the DPF Principles and your complaint cannot be resolved directly with Global Guardian, or through the independent dispute resolution mechanism, you may have the right to invoke binding arbitration under certain circumstances. For additional information on this option, please see Annex I of the Data Privacy Framework.

PERIODIC REVIEW AND VERIFICATION

Global Guardian will renew its Data Privacy Framework certification annually, unless we subsequently determine that we no longer need such certification or employ a different adequacy mechanism. Prior to such re-certification, Global Guardian will conduct a self-assessment to ensure that our attestations and assertions with regard to processing of Personal Information are accurate and that Global Guardian has appropriately implemented these practices.

CHANGES TO POLICY

Global Guardian reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Data Privacy Laws.

QUESTIONS OR CONCERNS

For questions or concerns, please contact our Data Privacy Officer as follows:

Name: Data Protection Officer

Phone: (703) 566-9463

Email: privacy@globalguardian.com
Address: 8280 Greensboro Drive, Suite 750, McLean, VA 22102

Last Updated: September 29th, 2023