Online Privacy Statement

Global Relay Communications Inc. and its affiliates (“Global Relay”, “us” or “we”) value your privacy and recognize the importance of protecting your personal information. We use the words “personal information” in this Privacy Statement to describe information that is about you that identifies you. We also collect other types of information from you in certain circumstances (for example, anonymized and aggregated data).

This online privacy statement (“Privacy Statement”) contains information about how we collect, use, disclose and secure your personal information we receive through your interactions with Global Relay outside of our enterprise message archiving service (more information on that here). It also describes your rights and choices regarding your information.

We have organized this Privacy Statement in the following way:

• Application of this Privacy Statement
• How We Collect Personal Information
• Categories of Personal Information We Collect
• How We Use Personal Information We Collect
• Cookies and Automated Technologies
• How We Share Personal Information
• How We Store and Retain Personal Information
• How We Protect Personal Information
• Links to Third-Party Websites
• Transfer of Personal Information Outside of Canada and the EEA
• Job Candidates
• Your Rights Regarding Your Personal Information
• Contact Us

If you are a resident of a European Economic Area (“EEA”) member or of the United Kingdom, please go here to learn more about your privacy rights.

If you are a California resident, please go here to learn more about your privacy rights.

1. Application of this Privacy Statement

This Privacy Statement applies to information we collect from you in a variety of ways. We describe this in further detail in Section 2, How We Collect Personal Information.

This Privacy Statement does NOT apply to data collected and maintained in Global Relay’s enterprise message archiving service, which is governed by a separate service agreement. It also does NOT apply to third-party services, third-party websites or third-party platforms (such as social media platforms) that we do not control.

We may modify this Privacy Statement from time to time. Any changes we make to this Privacy Statement in the future will be posted on this page. The updated policy will take effect upon posting to this page.

This Privacy Policy was last updated in August 2022.

2. How We Collect Personal Information

This Privacy Statement does apply to personal information or information we may collect about you from a variety of other sources and in connection with:

• Global Relay’s website and social media: Your visits to our website and our pages on various social media platforms.
• Offers, programs or promotions: Your participation in a Global Relay offer, program or promotion.
• Events: Your registration, attendance or participation in a conference, meeting or other event (virtual or in-person).
• General communications: Your communications with our employees through their Global Relay-issued devices, email addresses, phones, and applications, or more generally in their professional capacity via phone, email, chat, in person or otherwise. This applies to a wide variety of situations in which you communicate with our employees – for example, if you are calling to inquire about our services. If you are a job candidate, please see more information here.
• Visits: Your visits to our offices and data centers.
• Publically available databases: We may collect information about you that is publically available, such as websites.
• Third Parties: Vendors, partners, or other or other third parties may send us your information.

Global Relay as a Controller: In the above situations, Global Relay is considered a “controller” (or its equivalent) under applicable data protection laws.

A Third Party as a Controller: In certain limited circumstances, we may engage service providers who process certain categories of personal information on our behalf that also process the information on their behalf, making them a “controller” of your personal information, as well. Please see more information here.

3. Categories of Personal Information We Collect

We may collect the following categories of personal information:

• Identifiers and contact information, such as your name, username(s), postal address, telephone number, email address;
• Financial information, such as billing and account-related information, credit card and payment information, transaction history;
• Professional or employment-related information, such as your job title, department, industry and name of your organization;
• Internet or other electronic network activity information, including browsing history, search history or information regarding your interaction with our website, applications or advertisements;
• Geo-location data and other demographic information;
• Other types of personal information, such as content you choose to provide to us (such as documents and comments) and content you make available through social media accounts or memberships with third parties;
• Inferences.  We may draw certain inferencesabout you from the personal information we collect to create a profile about your preferences, characteristics, and/or behaviors.

We may also collect information that does not identify you, including device state, device identifiers, device hardware, operating systems, application functionality, or physical location of a device.

As described in further detail below, we also use automated technologies (like cookies) to collect certain information when you visit our website.

4. How We Use Personal Information We Collect

The main reason we use your information is to deliver and improve our services. Most commonly, we will use your personal information where: (i) we need to comply with a legal or regulatory obligation; (ii) we need to perform a contract we have entered into with you; or (iii) it is necessary for our legitimate business interests. In some instances, we may process your personal information based on your consent. When the legal basis for the processing of your personal information is your consent, you may withdraw that consent at any time by contacting us at privacy@globalrelay.net.

Use of Personal Information to Monitor, Improve and Provide Our Services.  We primarily use your personal information for our internal business purposes. This is in our legitimate interest in order to operate as a business and monitor and improve the quality of the services we provide. We may use certain categories of your personal information (for example: identifiers and contact information; financial information, professional or employment-related information; other types of personal information; inferences) in order to:

• Communicate with you and respond to inquiries in relation to our services or employment opportunities
• Keep you informed of maintenance, support and usage issues
• Request feedback about your experience with our services or to learn about your demographics, preferences or interests
• Provide invoicing and address accounting issues
• Evaluate your resume or other employment-related information if you apply for a position within Global Relay
• Escalate critical issues and problem resolutions that may arise with the services
• Diagnose, troubleshoot and resolve technical problems, and contact you to resolve such technical problems
• Administer Global Relay’s website

User of Personal Information to Market and Analyze Our Services:

• Information We Receive from You: We may also use certain categories of your personal information (identifiers; professional or employment-related information; internet or other electronic network activity information; geo-location data; other personal information) to help market and analyze our service offerings, which may include sharing your information with third party contractors that we engage for these purposes. For example, we may use your contact information to keep you informed about our offered services and trends in the industry. We may also use email addresses to provide you with informative newsletters and other similar information, customize or personalize your online experience, or to update marketing lists and manage databases. To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or contact us at privacy@globalrelay.net.  
• Information We Receive from Third Parties: Partners, third party service providers, and customers may send us certain categories of your information (identifiers and contact information; employment-related information; geo-location data; other types of personal information; inferences) through the tools they use, including our event registration forms and third-party tools we purchase to facilitate the purchase, development, delivery and promotion of our products and services.

5. Cookies and Automated Technologies

We are committed to continually improving your experience when you visit our website. Accordingly, we use automated methods, like cookies, to collect certain categories of information (internet or other electronic network activity information; geo-location data; other personal information) when you visit our website.

Cookies. A cookie is a small text file that a website or application can send to your computer’s browser to collect and record information about your use of that website or application. Specifically, we may use cookies to:

• Automatically collect technical data such as the type of internet browser you use, the language of your browser, the website from which you have come to the site, the webpages you view on our website, the links you clicked on our website, and your IP address (the unique address which identifies your computer on the internet).
• Identify unique users and understand their navigation during a visit to our website. We use cookies to store user identifications, gather demographic data, manage content, analyze trends, monitor page visits and content downloads, personalize our website and offer secure services for each account holder.
• To learn more about cookies, you can visit https://allaboutcookies.org/.

Data Analytics. We may also track and analyze non-identifying and aggregate usage, including volume statistical information, from website visitors, event attendees, partners, vendors, and customers to help us market and analyze our service offerings. Specifically, we may:

• Use information about your professional affiliations, employment, and/or industry to help us determine which services are most likely to be of interest to you or to help diagnose problems with our systems or administration of our website.

• Use information about your professional affiliations, employment, and/or industry to gather general interest in our products and services, to help in the analysis of product/service usage, purchasing, and target markets.

In many cases you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different so visit the “help” section of your browser when to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies or clear local storage this could affect the features, availability, and functionality of your experience on our website.

6. How We Share Personal Information

We share your personal information in a number of ways in order to operate, promote, improve and customize our service offerings to you. In particular, we share your personal information in the ways described below.

To Third Party Service Providers to Operate, Analyze and Market our Services.  We may disclose certain categories of your personal information (identifiers and contact information; financial information;  professional or employment-related information; internet or other electronic network activity information; geo-location data; other types of personal information) to third parties to help us for marketing, promotional or other legitimate business purposes.

These third parties may use this information for services related to website analytics, hosting and cloud computing services and other IT services, payroll services, auditing services, consultancy services, regulatory services, legal services, customer relationship management systems, marketing and sales software solutions, event software providers, background checks, talent management and recruitment services. We authorize these service providers to use or disclose the information only as necessary to perform the services that we have retained them to provide  or comply with legal requirements, except as explained here. We require these service providers by contract to safeguard the privacy and security of personal information they process on our behalf.

• Sales Partners – Controllers of Personal Information. In order to manage and optimize how we engage with our sales partners, we provide certain categories of information (identifiers and contact information; professional or employment-related information), to service providers who process that information on our behalf, on our instruction. These service providers also input that information into their database and use it to populate their database for deal leads and other sales activities. In this circumstance, they become the controller of that information. For more information please contact our Privacy Officer at privacy@globalrelay.net.

We will not sell, rent, trade or otherwise disclose individual customer information to any third parties or outside companies for any reasons other than those specified in this Privacy Statement.

• To Fulfill Legal Obligations.  We may disclose all categories of your personal information if required as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so, including to:

• Comply with applicable law and regulations
• Cooperate with public and government authorities
• Cooperate with law enforcement
• Enforce our terms and conditions
• Protect our rights, privacy, safety or property, and/or that of our affiliates, you or others

7. How We Store and Retain Personal Information

We securely keeps your information for as long as we reasonably require it, either for business purposes, to comply with any legal obligations, or for as long as we are contractually obliged.

In some jurisdictions, you can request that your personal information be deleted (EEA Residents – see here; California Consumers – see here). Please note that if you request deletion of your personal information, we may retain your personal information for as long as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety, and to the extent necessary to comply with our legal obligations.  

8. How We Protect Personal Information

Data Center Security

• Mirrored, SOC 2-audited Data Centers

• Physically secured with 24x7x365 uniformed guard service

• Electronic key card access at Data Center entrances

• Physical access to Data Centers limited to Global Relay employees whose duties require access

• Monitored video surveillance cameras and alarm systems throughout Data Centers and building

• All environmental control systems monitored and controlled locally and remotely monitored

• Redundant facility HVAC cooling systems

• Fire detection and prevention systems

• High sensitivity, early warning smoke detection systems

• Redundant power utilizing uninterruptible power supplies (UPS)
• Independent routing of network traffic between redundant Tier 1 ISPs

System Security

• Highly secure, reliable, and scalable IT infrastructure

• Use of anti-virus software and encryption

• Mirrored active/active firewalls to ensure that in the event of a failure data will remain secure

• Continually upgraded systems ensuring performance at the highest level

• Systems monitored 24/7 by a dedicated Cyber Security Operations Center to protect against unauthorized intrusion

• Multi-factor authentication and Virtual-Private-Network (VPN) provides secure, remote monitoring

• System alerts for unusual activities

• Performance of regular security reviews and monitoring of security logs for anomalies

Legal Protection

• All employees receive mandatory security awareness training, including mandatory security refreshers and testing

• All employees are subject to background checks

• All employees must sign confidentiality and non-disclosure agreements

• Strict authorization protocols, logging, and monitoring for privileged systems access by Operations staff

In addition, access to sensitive personal information is limited to those individuals and agents having a need to know.

When we engage a third party service provider to collect or otherwise process personal information on our behalf, the third party is selected carefully and will be required to have appropriate data protection agreements and security measures in place.

9. Links to Third-Party Websites

Global Relay’s website contains hyperlinks to other sites as a convenience to users. We are not responsible for the privacy practices or contents of any information provided by outside sites through these links. You will need to check the policy statement of these other sites to understand their policies. If you access a linked site you may be disclosing your personal information. It is your responsibility to keep such information private and confidential.

10. Transfer of Personal Information Outside of Canada and the EEA

Global Relay’s operational center is located in Canada. Canada has robust and comprehensive laws that protect your personal information. The European Commission has recognized Canada as an “adequate” jurisdiction that offers a level of data protection similar to the EEA.

However, as a global business with offices, employees, entities, and service providers all over the world, we may need to transfer your personal information across international borders to countries that have different levels of data protection laws than the country from where you submitted your personal information. In these circumstances we will take appropriate steps to reasonably ensure that your personal information is treated securely and as described in this Privacy Statement, in accordance with applicable data protection laws. These steps will include appropriate contractual mechanisms or other approved methods.

11. Job Candidates

If you are a job candidate, the personal information we process about you may vary depending on the job you seek but typically includes the following categories of personal information: identifiers and contact information; professional or employment-related information; other types of personal information, such as content you choose to provide us in the course of applying for a job with us. We collected this information directly from you, or from recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. We may share personal information with service providers that assist us with recruitment and technical data processing operations. We keep your personal information only as long as necessary for those purposes.

12. Your Rights Regarding Your Personal Information

We want to keep your personal information accurate and we will provide you with access to your information and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your information.

If we rely on consent to process your personal information, you may withdraw that consent at any time, subject to legal and contractual restrictions and reasonable notice. Please note, however, that withdrawing consent may affect our ability to provide our services to you and maintain our relationship.

If you are located in the EEA of the United Kingdom: the European Union’s General Data Protection Regulation 2016/679 (GDPR) and/or the Data Protection Act 2018 (c12), and its United Kingdom equivalent, provide certain rights in relation to your personal information (also referred to as your personal data). Subject to any exemptions or limitations provided by the applicable law, you have the following rights:

• The right to object to the processing. You have the right to object to the processing of your personal data in certain situations.
• The right to information. You have the right to be informed whether and to what extent we process your data.
• The right of access. Subject to certain exceptions, you have the right to obtain a confirmation as to whether or not we process your personal data, and if we do, request access to your data.
• The right to rectification. If the personal data that we process is incomplete or incorrect, you have the right to request completion or correction at any time.
• The right to deletion. Subject to certain exceptions, if you consider that we should stop processing some or all of your personal data, you have the right to request its deletion. However, immediate deletion may not be possible, such as where retention is required to meet legal or regulatory obligations).
• The right to restrict the processing. You have the right to request that we restrict the processing of your personal data in certain situations, such as if you contest the lawfulness of our processing.
• The right to data portability. You have the right to request that we provide your personal data to you in a machine-readable format.
• The right to object to automated decision making or profiling. You have the right to object to decisions based exclusively on the automated processing of your personal data.
• The right to withdraw your consent. If your personal data is processed on basis of your consent, you have the right to withdraw your consent at any time.

If you are a Californian Resident: the California Consumer Privacy Act of 2018 subsequent amendments, and accompanying regulations (“CCPA”) provide certain rights, subject to certain limitations, in relation to your personal information, including:

• The right to non-discrimination. If you exercise your CCPA rights, we will not unlawfully change or otherwise discriminate in how we provide our services to you.
• The right to know. You have the right to request the categories of personal information we have collected about you in the past 12 months and how it is used and shared.
• The right to deletion. You have the right to request that we delete your personal information, subject to certain limitations.
• The right to opt-out of sale. We do not sell the personal information that we collect from you. Should this change in the future, we will ensure that the right to opt-out is made available to you. For clarity, this Privacy Statement constitutes Global Relay’s “notice at collection” under the CCPA. 

If you want to lodge a complaint: In the event that you wish to exercise your rights regarding your personal information or make a complaint about how we process your personal information, please contact us at privacy@globalrelay.net and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with any supervisory authority.

13. Contact Us

If you have any questions or concerns about this Privacy Statement, wish to contact our Data Protection Officer, or wish to make a complaint in the case you believe your personal information was not respected, please contact us using the details below.

If you are located outside the EEA:
Global Relay Communications Inc.
Attn: Privacy or Legal
220 Cambie Street, 2nd Floor
Vancouver, BC V6B 2M9, Canada
Phone: +1.604.484.6630
Email: privacy@globalrelay.net

If you are located in the EEA:
Global Relay Communications Inc.
Attn: Privacy or Legal
45 Cannon Street
London, UK EC4N 5SH
Phone: +44 (0) 203.139.9064
Email: privacy@globalrelay.net