Online Privacy Policy

This Privacy Policy describes the way that Globoforce, Inc. and Globoforce Limited (collectively, “Globoforce”) will treat personal information collected through the Globoforce corporate website at www.globoforce.com (the “Site”). We do not sell, trade or rent your personal information to third parties. This Privacy Policy explains how we collect your personal information on the Site , how we protect such information, and the choices you have concerning the use of such information.

Please remember that this Privacy Policy applies only to information collected through the Globoforce corporate website. This Policy does not apply to information collected through the www.globogift.com website, nor information collected through the websites we operate for our customers to manage employee incentive award programs; those websites have their own privacy policies, which are displayed on each website. We may amend this Privacy Policy from time to time. By using the Site you agree to the terms of this Privacy Policy.

U.S. – EU Safe Harbor Privacy Statement

For personal information of customers that Globoforce receives from the European Economic Area, Globoforce has committed to handling such personal information in accordance with the Safe Harbor Principles. Globoforce's Safe Harbor certification can be found at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce's website at http://www.export.gov/safeharbor/sh_overview.html. If users feel we are violating the Safe Harbor Principles, they should contact us at If contacting us does not resolve the complaint, users may contact the European Union Data Protection Authorities (“DPAs”). If DPAs finds us to be in violation of the Principles, we will correct the situation and stop processing the data of the user bringing the complaint.

Type of Information Collected

We collect two types of information: personally identifiable information and non-personally identifiable information.

Personally identifiable information is information that identifies you or can be used to identify or contact you and may include your name, address, email address, or telephone number. Such information is only collected if you voluntarily submit it to us.

Non-personally identifiable information is information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Site.

The Use of Information

We collect personally identifiable information from users of this Site if you choose to submit the information to us, such as by registering for a webinar, downloading a white paper, or submitting a “Request Information” form. We will use the information you submit to respond to your inquiry. We may also add your information to our marketing database and may send you email or hard copy marketing materials about Globoforce and its services.

We occasionally provide aggregated information regarding the use of the Site to partners, but these statistics never include personal information.

The Use of Cookies

Cookies are small pieces of information that are stored by your browser on your computer's hard drive. Globoforce uses cookies to personalize your shopping experience. For example, cookies allow us to recognise you when you return to the Site. Most web browsers are automatically set to accept cookies. You do not have to accept cookies to use the Site although this may impair the functionality of the Site. You may reset your browser to notify you when you receive a cookie or to reject cookies generally.

Consent

By submitting information to Globoforce, you agree to the information practices described in this Privacy Policy. If you are submitting information on behalf of a third party (for example, registering a fellow employee for a webinar), Globoforce expects that you have received appropriate consent, according to applicable privacy laws, before transferring, in printed, electronic, facsimile or any other format, personally identifiable information to Globoforce.

Disclosure of Information to Third Parties

When you submit information to the Site, we will store and process your Personally Identifiable Information only for the purposes of responding to your query and sending you marketing information on Globoforce. Your Personally Identifiable Information will not be shared with third parties other than for these purposes (unless a transfer is necessary in the context of a change of ownership of Globoforce’s assets or business).

We may provide to third parties information about you that does not allow you to be identified or contacted, including where such information is combined with similar information of other users of the Site. For example, we might inform third parties regarding the number of unique users who visit the Site, the demographic breakdown of our community users of the Site or the activities that visitors to the Site engage in while on the Site. The third parties to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.

We may also disclose your information (including Personally Identifiable Information) if we believe in good faith that we are required to do so in order to comply with an applicable law, a subpoena, a search warrant, a court or regulatory order or other valid legal process.

Amending of Personal Details

If you have submitted Personally Identifiable Information to Globoforce through the Site, and you wish to:

• update or correct your Personally Identifiable Information,
• verify what Personal Identifiable Information we maintain about you,
• change your preferences with respect to communications and other information you receive from us, or
• delete the Personally Identifiable Information maintained about you on our systems,

please contact us directly at

We undertake that promptly after receiving your request, all Personally Identifiable Information stored in databases we actively use and other readily searchable media will be updated, corrected, changed, deleted or confirmed to you, as appropriate, as soon as reasonably practicable.

Security

Globoforce is committed to taking reasonable steps to ensure the security of your information. To prevent unauthorised access, maintain data accuracy and ensure the appropriate use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We maintain data security systems that ensure specific information will not be made available to any unauthorized person and in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Our employees are made aware of and are accountable for compliance with our privacy policy. Any information collected by us on behalf of our clients is stored on our Web server or databases but is not publicly accessible from our Web site or otherwise. When applicable, we use a multi-level, password protected security system to control access to information stored about users. We also maintain physical security of our properties and facilities and only provide access to authorized personnel.

Changes to the Privacy Policy

If we decide to change this Privacy Policy, we will post those changes on the Site so you are always aware of what information we collect, how we use it, and the circumstances, if any, we disclose it. If at any point we decide to use Personally Identifiable Information in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you, at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your Personally Identifiable Information in the new manner. We may also make non-significant changes to our Privacy Policy that generally will not affect our use of your Personally Identifiable Information.

Concerns and Comments

You may email us with any further questions or concerns regarding this Privacy Policy at:

Effective Date of this Policy: August 15, 2007