Privacy Policy

1. Scope

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This privacy policy ("Policy") explains how we process personal data of customers and visitors to our websites ("Sites") and users of our services ("Services") as a controller or company under applicable privacy laws.

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When we collect personal data as processors, i.e. on behalf of our business customers, we process personal data in accordance with our contract with them, and in that case their privacy policy will apply.

This Policy does not apply to personal data of employees or job candidates, or to information exempt under applicable laws. We will provide additional notices when necessary to clarify our privacy practices in specific circumstances.

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2. Personal Data We Collect

 

While the personal data we collect varies depending on your use of our Services and our interactions with you, we may collect personal data from you, from third-party sources, and automatically in the following circumstances:

 

Personal Data We Collect Directly From You. We may collect the following personal information from you:

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• Customer service and technical support. When you contact us for technical support or other customer support requests, tickets and other records of your related requests/communications are recorded. For example, when you use our "Contact Us" form, we may collect details, such as name, country, email address, and the nature of your request. We may also collect information about your company, job title, and industry, if you choose to provide it.

• Communications. We collect the information you provide, such as contact information and records of our communications.

• Transaction and billing information. We collect information when you purchase one of our products or services. 

• Surveys. When you respond to a survey, we collect the response, which depends on the type of survey, but may include contact information and satisfaction with a product or service.

• Events. We also collect personal data related to registration and participation in events we organize or sponsor.

• Sweepstakes, contests and promotions. If you participate in sweepstakes, contests, and promotions that we offer, we will collect your name, age, country of residence, email address, and other registration information related to these activities. In some jurisdictions, we are required to disclose the name and other personal information of winners.

• Image/video recording and transcriptions. Video surveillance/security systems may take your image when you enter Globant's premises or during marketing or public events or filming sessions, and we obtain audio and video recording and transcription during meetings.

• Other information. We may collect other personal data if you consent or if reasonable in the nature of the circumstances.

 

Personal Data Collected by Third Parties. We may collect personal data about you from third-party sources, such as public databases, advisors and agents, related companies and subsidiaries, internet service providers, operating systems and platforms, data brokers and data analytics providers, advertising and marketing companies, business partners, customers, social media platforms, or others.

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Personal Data Collected Automatically. When you visit our Sites or use our Services, we and third parties may collect personal data, including through the use of cookies, tracking pixels, and other similar technologies, such as:

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• Device and browsing information. When you visit our Site, we may collect information, which certain laws consider personal data, such as IP address, browser type, domain names, access times, date and time stamps, operating system, language, device type, unique or online identifier, Internet service provider, referring and exit URLs,   clickstream data and other similar types of device and browsing information.

• Activities and use. We also collect activity information related to your use of the Site, such as information about the links you select, the searches you make, the features you use, the items you view, the time you spend on certain pages, interactions with our content, log file information, and other types of activity and usage information.

• Location information. We may also collect or derive general location information about you, for example, through your IP address.

 

For more information, please see section 7: Cookies and Other Tracking Mechanismsand ourCookie Policy page.

 

3. What we use personal data for

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In general, we use personal data for the following purposes:

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• Provide customer support and technical assistance. To provide our Services and operate our Site, provide you with useful information about your use of the Services, troubleshoot and provide you with technical support, respond to your inquiries, fulfill your orders and requests, communicate with you, and for similar support and support purposes.

• Communications. To respond to your inquiries and fulfill your orders and requests; send you communications that you have requested or that may be of interest to you; and notify you about changes to our Services.

• Analytics and improvements. To better understand how users access and use the Site and Services, as well as our other products and offerings; and for other research and analysis purposes, such as evaluating and improving our Site, Services, and business operations, developing our Site, Services, and functionality, and for internal quality assurance and training purposes.

• Customization and adaptation. To tailor the content we submit or present on the Site and Services, such as offering location personalization and personalized help and instructions, and to otherwise personalize your experiences.

• Marketing and advertising. To send you information about our Services, such as offers, promotions, newsletters, and any other information you agree to receive; and to manage, analyze, measure, and improve our advertising campaigns.

• Event planning and organization. For the planning and organization of events, including registration, attendance, contact with other attendees and the possibility of offering you relevant events and Services.

• Research and surveys. To administer surveys and questionnaires, for example, for market research or customer satisfaction purposes.

• Sweepstakes, contests and promotions. To facilitate your participation in sweepstakes, contests, and promotions, to contact you about your participation in the sweepstakes, contest, or promotion.

• Security and protection of rights. To protect the Site, the Services, and our business operations; to prevent and detect fraud, unauthorized access and activities, and other types of misuse; when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party,   or violations of our terms or this Policy.

• Legal actions and obligations. To comply with the law and our legal obligations, respond to legal process and for issues related to legal action.

• General support to the administrative and operational aspect. To perform tasks related to the general administration of our company, accounting, auditing, compliance, recordkeeping, and legal capabilities.

 

4. Disclosure of Personal Data

 

In general, we disclose and allow third parties to access personal data in the following ways:

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• Corporate affiliates. We may disclose personal data to our corporate affiliates as part of our global business operations, and for purposes and uses that comply with this Policy.

• Processors and Service Providers. We may disclose personal data to vendors who provide services on our behalf, such as IT service providers, web hosting providers, email service providers, chatbot providers, call center providers, etc.

• Third parties, platforms and services. We may disclose or make available personal data to third-party platforms and vendors that we use to provide or offer certain functionalities or portions of the Site and Services, or as necessary to respond to your requests.

• Marketing and advertising networks. We may disclose information you provide to advertising networks, search engines, social media platforms, sponsors, and/or traffic measurement services, which use this data to improve and measure the efficiency of our ads, and to show you ads on third-party websites and platforms. For more information, including how to opt out of interest-based advertising, please seeSection 7: Cookies and Other Tracking MechanismsandSection 11: Your Privacy Preferences below.

• Third-party analytics providers. We may also hire third-party analytics companies to collect information about how you access and use our Site and Services for the purpose of improving our Site and Services, and for other research and analysis purposes.

• Compliance, governance and legal requirements. We may disclose personal data to comply with legal and compliance obligations, and to respond to legal process and events related to legal actions. For example, we may disclose personal data in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement authorities. We may also disclose information related to litigation and other legal claims or actions, including personal data, to perform internal accounting, auditing, compliance, recordkeeping, and legal capabilities. In addition, we may disclose the names of winners of sweepstakes and contests, in accordance with applicable law.

• Corporate transactions. We may disclose personal data as part of corporate transactions (e.g., mergers, acquisitions, bankruptcies, or other similar transactions) and in contemplation of such transactions (e.g., due diligence).

• Business partners. We may disclose your personal data with partners who are organizing or co-organizing an event with Globant.

• Other cases. We may disclose your personal data for other purposes, for which we will notify you and ask for your consent where necessary.

 

Aggregated and/or anonymized data. We may use and disclose aggregated, anonymized, and other non-identifiable data relating to our company and the Services for quality control, analysis, research, development, and other purposes. When we use, disclose, or process anonymized data, we will maintain and use the de-identified information and will not attempt to re-identify it, except as permitted by law. 

 

5. International Data Transfers

 

Your personal data may be processed inside and outside the European Economic Area (EEA) given Globant's international dimension, all in compliance with contractual limits on confidentiality and security and in accordance with applicable laws and regulations related to the protection of personal data. Under no circumstances will your personal data be communicated to subjects or entities that do not have the authorisation for their legitimate processing.

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In addition, due to service efficiencies, some of our suppliers (processors) are located in countries outside the EEA, or, being located in the EEA, share information with other entities located outside the EEA.

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When we transfer your personal data outside the EEA, to be processed by Globant's affiliates and affiliates established outside the EEA, we will do so in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR). Specifically, transfers will be made in compliance with the appropriate guarantees required by the applicable regulations.

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6. Legal bases

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We have the right to use your personal data based on (i) our legitimate interest, such as for research and development, to market and promote our Services, to protect our legal rights and interests, to the extent that your interests or fundamental rights do not prevail; (ii) your consent to do so for a specific purpose; or (iii) the need to process your data to comply with a legal obligation.

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7. Cookies and other tracking mechanisms

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We and other third parties use cookies, tracking pixels, and other similar tracking mechanisms to automatically collect information about browsing activity, device type, and other similar information within our Site and Services. We use this information, for example, to analyze and understand how you access, use, and interact with our Site and Services; to identify and resolve errors and failures on our Site and Services; to evaluate, secure, protect, optimize, and improve the performance of our Site and Services; for marketing, advertising, measurement and analysis purposes; and to personalize content on our Site and Services. We may also anonymize or aggregate such information to analyze trends, administer our Site and Services, gather broad demographic information for aggregate uses, and for any other lawful purpose.

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Cookies. "Cookies" are alphanumeric identifiers used for tracking purposes. Some cookies allow us to make your navigation easier, while others are used to enable a faster login process, support the security and performance of the Site, or allow us to track activity and usage data within the Site and on other websites.

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Tracking pixels and other similar technologies. Tracking pixels (sometimes called web beacons or clear GIFs) are tiny graphics with a unique identifier, which have a similar function to cookies. We sometimes use these tracking technologies to understand user activity, help manage content and collect usage statistics, and in emails to know when they have been opened or forwarded, so that we can track response rates and evaluate the efficiency of our communications.

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Analytical tools provided by third parties. We use third-party tools, such as Google Analytics, operated by third-party companies to evaluate the use of our Site. These analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Site and provide us with reports and metrics that help us evaluate the use of our Site, optimize it, and improve performance and user experience. For more information about Google's privacy practices, please review Google's Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-Out Browser Add-on on https://tools.google.com/dlpage/gaoptout.

 

8. Security

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No data transmission over the Internet is 100% secure. Therefore, while we strive to protect your personal data, we cannot guarantee the security of information collected through our Site and Services. You use our Site and Services, and you provide us with your personal data at your own risk.

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9. How long we retain your personal data

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Your personal data will be retained for as long as necessary to fulfill the purposes and uses for which it was collected as set out in this Policy. If you request that we remove your personal data from our databases, please note that we may still retain your personal data as necessary to comply with our legal obligations, regulatory requests, resolve disputes, and enforce our agreements.

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10. What rights you can exercise in relation to the processing of your personal data

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You can exercise your rights of access, rectification, deletion, portability, limitation of processing and opposition by letter addressed to the company's registered office, or by email addressed to privacy@tibcoinsights.com accompanying, if necessary to prove your identification, a copy of your national identity document or equivalent identification document.

We also inform you that if you do not consider that your personal rights have been duly addressed, you may file a complaint with the competent supervisory authority.

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However, we recommend that before filing any complaint or claim with the competent supervisory authority, you contact us, and especially Globant's DPO (privacy@tibcoinsights.com ) in order to analyse the specific situation that corresponds, and try, where appropriate, to seek an effective and amicable solution.

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11. Your Privacy Preferences

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Communications for marketing actions. We may send promotional emails or other similar communications on a regular basis. You may opt out of receiving these communications by following the instructions provided in the communication, for example, by using the "unsubscribe" option. If you opt out of receiving promotional content from us, we may still send you communications about your account or any Services you have requested or received from us.

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Industry ad choice programs. You can also control how third-party advertising companies use the information they collect about your visits to our Site and those of third parties in order to show you more relevant targeted advertising. If you are located in the U.S., you can learn more and opt out of receiving targeted ads from third-party ad networks in aboutads.info/choices (Digital Ads Alliance, DAA). You can also download the DAA AppChoices tool to control interest-based advertising in apps on your mobile device.

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Cookie settings. You can adjust your cookie settings by clicking on "Cookie Preferences" at the bottom of our website. Visitors to our Site who disable cookies will be able to navigate the site, but some features may not work. If you access our Site from a different device or from a different browser on the same device, you will also need to apply cookie settings for that browser and/or device.

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Browser signals. To the extent required by applicable law, if our Site detects that your browser is transmitting an opt-out preference signal, such as a "global privacy control" (GPC) signal, we will consider that signal to opt that browser out of targeted cookies on our Site. If you access our Site from a different device or browser, you will also need to apply the GPC for that browser and/or device. We don't respond to "do not track" signals. 

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12. Personal data of minors

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Our Website is aimed at the general public. The Site and Services are not designed for children, and we do not voluntarily collect personal data from children.

 

13. External links

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Our Sites and Services may contain links to third-party websites or features. This Policy does not govern your access to and use of such websites or features, but is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including the collection of your personal data. You should review the privacy policies and terms of any third-party websites before accessing those websites or using those features.

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14. Collection Notice and California Privacy Rights

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This section of the Policy (the "California Privacy Notice") provides additional information for California residents ("you") and describes our information handling practices in accordance with applicable California privacy laws, including the California Consumer Privacy Act and the regulations set forth therein, as amended (the "CCPA").

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In this section, "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific Florida resident or household. This section does not refer to or apply to our handling of publicly available information or Personal Information that is otherwise exempt under the CCPA.

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Categories of Personal Information We Collect and Disclose. The table below specifies the categories of Personal Information that we may collect about you (and that we may have collected in the past 12 months), as defined by the CCPA, as well as the categories of third parties to whom we may disclose this information to fulfill corporate or business purposes. Depending on how you use the Services, we may collect and disclose the following categories of Personal Information. For more information, please see Section 3: What We Use Personal Data for and Section 4: Disclosure of Personal Data presented above.  

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Personal Information Collected

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Disclosure to third parties to meet corporate or business objectives

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Includes name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or similar information.

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Ad Networks

• Data Analytics Providers

• Social Media

• Internet Service Providers

• Operating Systems and Platforms

• Company Clients

• others, as permitted or required by law (such as disclosure of sweepstakes and contest winners)

It also includes identifiers such as passport number, driver's license number, or local ID card number.

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• others, as permitted or required by law

Categories of Personal Information Described in California Civil Code § 1798.80

It includes records that contain Personal Information, such as name, product reviews, address, and phone number.

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Internet Service Providers

• Operating Systems and Platforms

• Company Clients

• others, as permitted or required by law

Commercial information

Includes products or Services purchased, obtained, or considered, or other purchase or usage histories or tendencies.

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Ad Networks

• Data Analytics Providers

• Social Media

• Internet Service Providers

• Operating Systems and Platforms

• Company Clients

• others, as permitted or required by law

 

Information about activities on the network or other electronic media

 

It includes information about your use of our Site, such as browsing history, clickstream data, search history, and information about interaction with our Sites, advertisements, including access logs, and other activity information related to your use of our Services.

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Ad Networks

• Data Analytics Providers

• Social Media

• Internet Service Providers

• Operating Systems and Platforms

• Company Clients

• others, as permitted or required by law

 

Geolocation data

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It includes general information about the location of a particular person or device.

 

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Internet Service Providers

• Operating Systems and Platforms

• others, as permitted or required by law

Information about audio, electronics, image, thermal or similar issues

It includes audio, electronic, image, thermal or similar information such as photographs and images (e.g., provided by you) and calls (e.g., technical support calls).

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• others, as permitted or required by law

Features of Protected Classifications

It includes characteristics of protected classifications under California and federal law, such as date of birth, gender, nationality, citizenship.

• Advisors

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Internet Service Providers, Operating Systems, and Platforms

• Data Analytics Providers

• others, as permitted or required by law

Profiles and inferences

It includes inferences drawn from other Personal Information that we have collected to create a profile that reflects an individual's preferences.

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Ad Networks

• Data Analytics Providers

• Social Media

• Internet Service Providers

• Operating Systems and Platforms

• Company Clients

• others, as permitted or required by law

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Sensitive Personal Information

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It includes precise geographic location, passport number, driver's license or ID card number, age, and gender.

• Advisors & Agents

• government institutions and law enforcement

• Related Companies and Subsidiaries

• Internet Service Providers

• others, as permitted or required by law

 

Sale and Disclosure of Personal Information. In addition, the CCPA defines "sale" as disclosing or making available to a third party Personal Information in exchange for monetary compensation or other valuable benefit, while "disclosure" includes disclosing or making available Personal Information to a third party for the purpose of cross-context behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we do occasionally disclose the following categories of Personal Information: identifiers, profiles and inferences, and information about network or other electronic media activities to third-party advertising networks, data analytics providers, and social media for marketing and advertising purposes. We do not sell or disclose Sensitive Personal Information, nor do we sell or disclose Personal Information of individuals we know to be under the age of sixteen (16).

 

Sources of Personal Information. As described in detail in Section 2: Personal Data We Collect, we collect Personal Information from the following sources: directly from you; from advertising networks; from data analytics providers; from social networks; from internet service providers; from operating systems and platforms; from affiliated entities; and from government entities.

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Retention. We retain the Personal Information we collect only to the extent reasonably necessary for the purposes described above or specified at the time of collection. We retain Personal Information as necessary to comply with our tax, accounting, and registration obligations, to provide you with the services you have requested, as well as an additional period of time necessary to protect, defend, or enforce our rights, defend against potential claims, and comply with our legal obligations. In some cases, instead of deleting your Personal Information, we may anonymize or aggregate it and use it in accordance with the CCPA.

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Purposes for Collection, Use, Disclosure, and Processing of Personal Information. As described in detail in Section 3: What We Use Personal Data For, we collect, use, and process the above categories of Personal Information to provide our Services to you, respond to and fulfill your requests, as available or agreed to by you, and for the following business purposes: provide services and technical support, communications, analytics, and improvement,   personalisation, marketing and advertising, events, research and studies, security and protection of rights, legal actions and obligations, and general support for the administrative and operational aspects.

 

Sensitive Personal Information. We do not use or disclose Sensitive Personal Information beyond the purposes authorized by the CCPA.

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Florida Residents' Rights. The CCPA gives you certain rights with respect to your Personal Information. Please note that these rights are subject to certain conditions and exceptions.

 

Right to know/request access. With respect to the Personal Information we have collected about you in the past twelve (12) months, you have the right to know the following:

• The categories of Personal Information we collected about you;

• The categories of sources from which we collected your Personal Information:

• The corporate or commercial purposes for collecting, selling, or disclosing your Personal Information;

• The categories of third parties to whom we have disclosed your Personal Information; and

• What specific Personal Information we collect about you.

 

Right to delete. You have the right to request that we delete your Personal Information

 

Right to correct. You have the right to request that we correct data that is not accurate within your Personal Information

 

Right to Opt Out of Sales and Disclosure of Information. You have the right to opt out of the "sale" and "disclosure" of your Personal Information, as defined in the CCPA. To exercise the right to opt-out of the "sale" or "disclosure" of your Personal Information, please click on the Cookie Preferences link  at the bottom of the Site or on this link. Please note that the opt-out request will only opt you out of disclosures considered "sales" or "disclosures" under the CCPA and will not exclude you from other disclosures, such as to our service providers.

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You also have the right to opt out of the "sale" and "disclosure" of your Personal Information by using an opt-out preference signal. If we detect that your browser or device is transmitting an opt-out preference signal, such as the "global privacy control" or "GPC" signal, we will exclude for that browser or device cookies that generate the "sale" or "disclosure" of your Personal Information. If you access our Site or use our Services from a different device or browser, you will also need to opt-out or use an opt-out preference signal for that browser and/or device.

 

Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of "Sensitive Personal Information" that would give rise to the right to limit the use of Sensitive Personal Information under the CCPA.

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Right to non-discrimination. You will not be discriminated against for claiming any of the rights described in this section.

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nforce your rights. If you are a California resident and wish to exercise your rights under the CCPA, you may do so through the following methods:

• Emailing us at privacy@tibcoinsights.com

 

Verification. Before responding to your request, we must first verify your identity using the Personal Information you have recently provided to us. To verify your request, we will compare the information provided with information in our records. In some cases, we may request additional information to verify your identity, or where necessary, to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, we will explain the reason for this rejection.

Authorized agents. You may designate another person as an authorized agent to submit applications and act on your behalf. Authorized agents will be required to provide evidence of authorization, and in addition, we may require the same consumer to directly verify the identity and authority of the authorized agent.

 

15. Confidentiality Statement for Brazil and Colombia

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Data collected and/or processed in Brazil, or any other processed information relating to individuals or Services located in Brazil, must be subject to the provisions of Brazil's General Law on the Protection of Personal Data (Law No. 13.709/2018, Lei Geral de Proteção de Dados Pessoais or LGPD). All requests regarding data protection in Brazil should be sent to the email privacy@tibcoinsights.com. The person "in charge" (the person responsible, in accordance with Art. 41, §1º, LGPD) is Bryan Longo, lawyer at Clasen & Casado Filho Sociedade de Advogados.

 

16. Changes to this Policy

 

If we change or update our Policy, we will post those changes on this page. Your continued use of the Site and Services is subject to our most recent Policy, posted here. If we make significant changes, we may post a notice on our Site.

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17. Contact

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If you have any questions or concerns about the way we process your personal data or about this Policy, please email us at privacy@tibcoinsights.com or contact us at the following postal address:
 

Tibco Analytics Inc,

Coral Gables, FL, 33134