Privacy Policy for Globi

1. Collection of Personal Data

We collect the following categories of personal data:

• Identity and Contact Data: Information provided during account setup or access provisioning, which may include your name, chapter affiliation, and email address provided by your chapter or Global Chamber.
• Inputs and Outputs: When you interact with the Globi AI assistant, you provide questions or prompts ("Inputs"). The Platform generates responses ("Outputs") based on these Inputs and the indexed Global Chamber knowledge base. If you include personal data in your Inputs, it will be processed to generate Outputs.
• Feedback: If you provide feedback, such as rating an Output using thumbs up/down icons or submitting comments, we collect this feedback including the related conversation context (Inputs and Outputs) to help us improve the Platform.
• Communication Information: If you contact us directly (e.g., via email for support), we collect your name, contact information, and the content of your messages.
• Technical Information: We automatically collect certain technical data when you use the Platform, such as IP address (and inferred location), device type, browser type, operating system, usage times, pages viewed, and general usage patterns. This helps us understand how the Platform is used and maintain its security and performance. We may use cookies or similar technologies for essential functions like session management and security.

2. Use of Personal Data

We use your personal data for the following purposes:

• To provide, maintain, and improve the Globi Platform for Global Chamber chapters.
• To administer your access and manage your relationship with the Platform.
• To respond to your inquiries and provide support.
• To analyze usage patterns and improve the Platform's functionality, relevance, and user experience specifically within the Global Chamber context.
• To ensure the security and integrity of the Platform and prevent misuse or violations of our Terms of Use or Global Chamber policies.
• To comply with legal obligations and protect the rights of Global Chamber and its members.

Important Note on Model Training: We will not use your Inputs or Outputs to train the underlying large language models for general purposes outside of the specific Globi/Global Chamber context. We may use Feedback (including related conversation context) you explicitly provide to improve the Globi Platform. If Inputs or Outputs are flagged for trust and safety reviews (e.g., potential policy violations), they may be analyzed to improve our safety mechanisms within the Platform, potentially including training specific safety-focused models for internal use.

3. Disclosure of Personal Data

We disclose personal data to the following categories of third parties:

• Service Providers: Companies that provide services on our behalf, such as hosting providers, platform infrastructure providers, and analytics providers. These providers are contractually obligated to protect your data and use it only for the services they provide to us.
• Global Chamber Internal: Relevant Global Chamber staff or departments who require access for administrative, support, or oversight purposes related to chapter activities and Platform management.
• Legal Requirements: We may disclose personal data if required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is necessary to protect the rights, property, or safety of Global Chamber, our users, or the public.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets related to Global Chamber, personal data may be transferred as part of that transaction, subject to standard confidentiality arrangements.

4. Your Rights and Choices

Depending on your location and applicable law, you may have rights regarding your personal data, including:

• Access: The right to request access to the personal data we hold about you.
• Correction: The right to request correction of inaccurate personal data. Please note that while we can correct factual inaccuracies in data we hold about you, we cannot guarantee the factual accuracy of AI-generated Outputs.
• Deletion: The right to request deletion of your personal data, subject to certain exceptions (e.g., legal obligations, ongoing investigations).
• Objection/Restriction: The right to object to or request restriction of certain processing activities.
• Withdrawal of Consent: Where processing is based on consent, the right to withdraw it at any time.

To exercise your rights, please contact Global Chamber at global@globalchamber.org. We may need to verify your identity before processing your request. We will respond to requests in accordance with applicable law.

5. Data Transfers

The Globi Platform is operated primarily in the United States. By using the Platform, your personal data may be transferred to, processed, and stored in the United States or other locations where our service providers operate. We take appropriate measures to ensure that data transfers comply with applicable data protection laws.

6. Data Retention and Security

We retain personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g., for legal or auditing purposes). When data is no longer needed, we securely delete or anonymize it.

We implement reasonable technical and organizational security measures designed to protect your personal data from unauthorized access, use, alteration, or disclosure. However, no internet-based service is 100% secure.

We may aggregate or de-identify data (removing information that identifies you) for purposes such as analyzing Platform usage, improving services within the Global Chamber context, and reporting on Platform performance.

7. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have inadvertently collected such data, we will take steps to delete it.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post any changes on this page and update the "Effective Date" at the top. For significant changes, we may provide more prominent notice (e.g., via email or a notification within the Platform).

9. Contact Information

The data controller for your personal data is Global Chamber®.

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

Email: global@globalchamber.org

You may also have the right to lodge a complaint with your local data protection authority. For users in Arizona, this may involve the Arizona Attorney General's office.