GLMS Australia Pty Ltd. (GLMS or We) respect your privacy. This Privacy Policy informs you about our privacy practices including details of the personal data we collect, use, disclose and transfer as well as choices you can make and rights you can exercise in relation to your personal data. This Privacy Policy is available from a link on the footer of every GLMS web page.
GLMS respects and takes into account the major privacy principles and frameworks around the world, including, the EU General Data Protection Regulation 2016/679 (GDPR) and The Australian Privacy Principles (or APPs) are the cornerstone of the privacy protection framework in the Privacy Act 1988.
This Privacy Policy applies to all GLMS – owned websites, domains, services, applications, and products, except that a privacy policy or statement specific to a particular GLMS program, product or service may supersede or be supplemented by this Privacy Policy.
We collect personal data only if required to provide our products or services, fulfil our legitimate business purposes and/or comply with applicable laws and regulations. Depending on your relationship with GLMS we collect and process your personal data as follows:
GLMS products and services: contact details, login credentials and interactions with our digital assets and content, for the following main purposes: account creation and management; entering into and performing agreements with you or your organisation; integration with your hosted applications, providing support and tools to activate licenses and request support; managing and fulfilling orders; deploying and delivering products and services; conducting quality controls; operating and providing access to customer portals, hosted management services, consulting; notifications of contract expiry and renewal options; developing and improving our products and services and ensuring compliance with regulatory requirements.
Online Data Collection Tools: digital activity information for the following main purposes: enabling efficient use of our website, products and services; collecting statistics to optimise the functionality of our website, products and services; improving user experience and delivering content tailored to their interests.
Online forums and surveys: contact details, login credentials, comments and feedback for the following main purposes: conducting customer satisfaction and engagement surveys.
Training and education: contact details for the main purpose of conducting trainings and managing education programs for customers, partners and suppliers.
Due diligence screening:contact details and other information as may be relevant (e.g. information from publicly available sources) for the following main purposes: conducting anticorruption due diligence on third parties and conducting required investigations, in compliance with applicable laws.
Brand-protection programs: contact details, login credentials and other relevant information (e.g.
information from publicly available sources) for the main purpose of conducting investigations into GLMS product-related fraud, compliance, grey marketing, theft and/or counterfeit.
Whistleblowing: contact details and information about alleged misconducts for the main purpose of detecting, preventing and investigating misconduct by GLMS staff, customers, partners and suppliers.
Enquiries and complaints: contact details and information included in enquires and complaints for the main purpose of addressing and resolving enquiries and complaints.
Non-GLMS web sites and social media features. GLMS sites or services may provide links to third-party applications, products, services or website for your convenience or information. We may also provide social media features that enable you to share information with your social networks and to interact with GLMS on various social media sites. GLMS does not control third party sites, or their privacy practices and we do not endorse or make any representations about third party sites. The personal data you choose to provide to or that is collected or shared by these third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal data.
GLMS does not sell, rent, or lease personal data to others except as described in this Privacy Policy. We may share and/or disclose your personal data as follows:
Disclosure within the GLMS group. GLMS has its headquarters in Australia and operates worldwide. GLMS may disclose your personal data as necessary within the GLMS group in connection with how we use your personal data.
Except as described in this Privacy Policy, GLMS will not share your personal data with third parties without your permission, unless to: (i) respond to duly authorized information requests of police and governmental authorities; (ii) comply with law, regulation, subpoena, or court order; (iii) enforce/protect the rights and properties of GLMS or its subsidiaries; or (iv) protect the rights or personal safety of GLMS, our employees, and third parties on or using GLMS property when allowed and in each case in accordance with applicable law.
Circumstances may arise where, whether for strategic or other business reasons, GLMS decides to sell, buy, merge, or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers. It is GLMS’s practice to seek appropriate contractual protection for personal data in these types of transactions.
GLMS may transfer your personal data as necessary within the GLMS group of companies and to other third parties. The recipients may be located in countries which do not provide the same level of data protection as the country in which you are located. GLMS will take steps to ensure personal data we transfer is adequately protected as required by applicable data protection laws. Where required by local law, we will request your consent to transfer your personal data.
Transfers to third parties. With respect to transfers to third parties located in countries which do not provide an adequate level of data protection, GLMS will take appropriate safeguards such as signing Contractual Clauses, or other model clauses that comply with applicable data protection regulations, with the recipient, relying on approved codes of conduct or certification mechanisms adopted by the recipient or binding and enforceable commitments of the recipient.
GLMS may provide you with information that complements our products and services and/or communications about our new products, services and offers. If you or your organisation purchase our products or services, you may receive alerts, software updates or responses to support requests that are part of our products and services. If you choose to receive GLMS communications you may also choose to subscribe to receive specific newsletters and publications. In some cases, you may also choose whether to receive the information and communication by email, telephone, or post.
Manage communication choices. You can change your choices and preferences relating to GLMS communications by:
Getting in touch with us via email at info@glms.com.au, indicating or changing your choices and providing your email address;
Unsubscribe from communications. In the event you no longer wish to receive GLMS communications, you can unsubscribe from such communications by:
Following opt-out or unsubscribe link and/or instructions included in each email subscription communication;
Accessing the Communication preference center, selecting “Unsubscribe” and providing your email address;
In the event your opt-out or unsubscribe request has not been resolved in a timely manner, please contact us at info@glms.com.au with details of your name, contact information, and description of the communications you no longer wish to receive from GLMS.
Please note that these options do not apply to communications relating to the administration of orders, contracts, support, product safety warnings, or other administrative and transactional notices, where the primary purpose of these communications is not promotional in nature.
How GLMS uses Automatic Data Collection Tools. GLMS web sites and applications use cookies, web beacons, device identifiers, IP addresses, and other similar technologies (collectively, Automatic Data Collection Tools), to provide and secure GLMS web sites and applications, remember log-in details, collect statistics to optimise functionality, collect information on user activity in response to email communications and related to white papers, documents and other assets made available through our web sites and applications, and more generally to improve your user experience and deliver content tailored to your interests. Some of these Automatic Data Collection Tools are strictly necessary to provide GLMS web sites and applications, while others are used to understand, tailor and improve GLMS web sites and applications.
GLMS also allows third-party advertising companies to use Automatic Data Collection Tools on our web sites and applications in order to understand how you interact with our web sites and applications, to optimise our advertisements and marketing and to serve advertisements specific to your interests on other web sites and applications you may visit or use.
Automatic Data Collection Tools may also be used when you share information using a social media sharing button on our website. The social network will record that you have done this and may use this information to send you targeted advertisements. The types of Automatic Data Collection Tools used by these companies and how they use the information is governed by their privacy policies.
When you enter your contact details on a web form on the https://connectplans360.com.au site, in order to subscribe to a service, download a white paper or request information about GLMS’s products and services, your contact details may be stored in a cookie on your device. This information is then accessed on subsequent visits the GLMS sites, allowing us to track and record the sites you have visited and the links you have clicked, in order to better personalize your on-line experience, and future GLMS communications.
Choices Regarding Automatic Data Collection & Online Tracking. While GLMS website at this time does not recognize automated browser signals regarding tracking mechanisms, such as “do not track” instructions, you can generally express your privacy preferences regarding the use of most Automatic Data Collection Tools through your web browser or device settings. You can set your browser in most instances to notify you before you receive certain Automatic Data Collection Tools, giving you the chance to decide whether to accept them or not. You can also generally set your browser or device to turn off certain Automatic Data Collection Tools. If you are accessing our website or applications in countries of the European Union (EU), or countries where the EU regulations apply, you are given the choice to accept or refuse our use of non-essential cookies (as described in the section titled ‘How GLMS uses Automatic Data Collection Tools’ above) through a ‘cookie preference’ banner that appears on our web pages. The banner stops being displayed when you have made your choice, but it can be brought back on display by selecting the ‘Cookies’ link on the footer of every GLMS web page.
Since these Automatic Data Collection Tools allow you to take advantage of some of our website and applications’ features, we recommend that you leave them turned on. If you block, turn off or otherwise reject certain Automatic Data Collection Tools, some web pages or user experiences may not display properly or you will not be able, for instance, to use any web site services that require you to sign in.
Sometimes our website uses Google Analytics cookies. Information collected by Google Analytics cookies will be transmitted to and stored by Google on servers in the United States of America in accordance with its privacy practices. To see an overview of privacy at Google and how this applies to Google Analytics, visit https://www.google.com/policies/privacy/. You may opt out of tracking by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
GLMS takes seriously the trust you place in us to protect your personal data. In order to protect your personal data from loss, or unauthorised use, access or disclosure, GLMS utilizes reasonable and appropriate physical, technical, and administrative procedures to safeguard the information we collect and process. All systems used to support GLMS’s business are governed by Microsoft Azure applications, which are built upon industry standards and best practices.
When collecting or transferring sensitive information we use a variety of additional security technologies and procedures to help protect your personal data from unauthorised access, use, or disclosure The personal data you provide us is stored on computer systems locked in controlled facilities which have limited access. Access to your information is restricted to GLMS employees or authorised third parties who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations. When we transmit sensitive information over the internet, we protect it through the use of encryption, such as the Transport Layer Security (TLS), Internet Protocol Security (IPSec), or Secure Socket Layer (SSL).
Typically, we keep personal data for the length of any contractual relationship and, to the extent permitted by applicable laws, after the end of that relationship for as long as necessary to perform purposes set out in this Privacy Policy, to protect GLMS from legal claims and administer our business. When we no longer need to use personal data, we will delete it from our systems and records or take steps to anonymize the data unless we need to keep it longer to comply with a legal or regulatory obligation.
Our privacy practices are aligned with the requirements of Europe’s General Data Protection Regulation (GDPR) and the applicable data protection laws of other countries in which we operate. We respect the rights individuals have in relation to their personal data under these laws. Depending on what data protection laws you are subject to, this additional information may be relevant and applicable to you.
Data controllers. GLMS may act as data controllers in relation to your personal data for the processing of personal data described in this Privacy Policy. For instance, when users access our website and view information about us and our technology, communicate with us, download whitepapers, and register for events etc. or if an individual signs up as a user of the Platform via an Individual Plan.
Data Processors. GLMS may act as data processors in relation to your personal data for the processing of personal data described in this Privacy Policy. When an individual engages with the Platform because their employer has signed up to a business plan, then, the user’s employer is the data controller with respect to the user information it provides to us. This information typically includes first name, last name, and business email address. Where your employer is data controller in this way, we act as a data processor under data protection laws, meaning we use the information to provide a service to your employer.
Legal basis to process personal data. We process your personal data on the following legal bases:
Legitimate Interest. We may process your personal data as required to pursue our legitimate business interests (provided this is not overridden by interests or rights of relevant individuals). In particular, to manage, develop and improve our products and services; support our customers and sales operations; protect our staff and assets; communicate information that supplements our products and services and ensure compliance with laws and regulations.
Performance of an agreement. We may process your personal data to enter into or fulfil agreements with your or your organisations, including to deliver and manage our products and services and allow our customers to use our products, services and supporting tools.
Legal obligation. We may process your personal data to comply with applicable laws and regulations, establish or exercise our legal rights. For example, in connection with legal claims, compliance, regulatory and investigative purposes.
Consent. We may process your personal data where you have provided your consent. In particular, where we cannot rely on an alternative legal basis or we are required by law to ask for your consent in the context of some of our sales and marketing activities, online data collection tools, or surveys. At any time, you have a right to withdraw your consent by changing your communication choices, unsubscribing from GLMS communications or contacting us at info@glms.com.au.
Your rights in relation to your personal data. Depending on what data protection laws you are subject to, you may have the right to:
Request confirmation of the processing of your data, access or obtain copies of personal data GLMS processes about you;
Rectify your personal data, if inaccurate or incomplete;
Delete or anonymise your personal data, unless an exception applies. For instance, we may need to keep your personal data to comply with legal obligation;
Restrict the processing of your personal data, in certain circumstances. For instance, if you contest accuracy of your personal data you may request that we restrict processing of your personal data for the time enabling us to verify the accuracy of your personal data;
Data portability, in certain circumstances. For instance, in the EU you may request us to transmit some of your personal data to another organization if the processing is based on your consent or a contract;
Object to processing of your personal data, in certain circumstances. For instance, in the EU you may object to direct marketing including use of your personal data for profiling for direct marketing or where we process your personal data because we have legitimate interest in doing so.
Obtain information about the entities with which GLMS has shared your personal data;
Withdraw consent to the processing of your personal data.
These rights may be limited in some situations such as where GLMS can demonstrate that GLMS has a legal requirement or legitimate interest to process your personal data or can legitimately apply an exemption to the exercise of a right under applicable law.
To view and update the personal data you provided directly to GLMS, you can contact us at the address indicated in the How to contact us section below. To protect your privacy and security, we will take reasonable steps to verify your identity before processing your request.
If GLMS processes your personal data on behalf of an GLMS customer, then we will, in the first instance, refer your complaint to our customer to handle.
If you have any questions about our Privacy Policy, any concerns or complaint regarding our collection and use of your personal data or wish to report a possible breach of your privacy, please contact us by email or write to us at the appropriate address below. We will treat your requests and complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to address your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Email address: info@glms.com.au
Physical address: GLMS Australia Pty Ltd.
805/220 Collins St, Melbourne
VIC 3000, Australia
Attention: Privacy Team
If we modify this Privacy Policy, we will publish a revised version with an updated revision date. The privacy link on the footer of every GLMS web page will then point to that new version.
