2. Who are we?
We, The Global Pioneers Inc. (“we,” “us,” “our”), 1476 Highland Circle, Clearwater, FL 33755, United States of America are committed to protecting the privacy and security of your personal data at all times.
3. Who is The Global Pioneers Inc.?
The Global Pioneers Inc. is an independent associate of the The Way to Happiness Foundation International.
The views and opinions expressed by independent associates are not necessarily the views of The Way to Happiness Foundation International. Independent associates are responsible for their own content, including the truth and legality of the statements made, and represent that they have the legal right and authority to provide the content or graphics provided.
The Way to Happiness Foundation International does not independently investigate the content an associate places on his or her webpage(s) or any other promotional materials, and it expressly disclaims liability for same.
4. Who is responsible for your personal data?
The Global Pioneers Inc. acts as the data controller for the processing of the personal data that you provide at this Website and is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
5. Which of your personal data do we process
When you use our Website we may process the following categories of personal data:
- Technical information, such as information concerning your device, IP-address, browser type, geographical location and operating system.
- Browsing behavior, such as the length of your visit, the links you click, the pages you visit and the frequency with which you visit a page.
When you communicate with us by filling out forms on our Website, or via e‑mail or telephone, we may process the following personal data:
- Identity information you provide us with, such as your first name and last name.
- Contact details you provide us with, such as your e‑mail address and mobile telephone number.
- Content of the communication, such as your request or question.
- Technical information of the communication, such as with whom you communicate at our end, date and time of the communication..
- Any other personal data you provide us with.
6. Why and on what legal basis do we use your personal data
In the table below, we explain the purposes for which we process your personal data and on the basis of which legal basis we do so. We rely on the following legal bases:
- Your consent, in which you are informed of what this consent means before you freely give your consent.
- A contract with you, in order to perform that contract or in order to take steps prior to entering into a contract with you.
- A legal obligation that we have to comply with.
- Our legitimate interest, such as improvements of our Website, materials and services to ensure that you have the best experience possible, to keep them safe from misuse and illegal activity, to disseminate and promote them and to make them available to you.
|1||We process your personal data to send you promotional information for our materials and services, such as communications, promotions, offerings and newsletters, via e‑mail or other person-to-person electronic communication channels if you explicitly consented to receiving such promotional information.||Your consent|
|2||In the framework of sending you promotional information, such as communications, promotions, offerings and newsletters, via e‑mail or other person-to-person electronic communication channels, we process your personal data to collect information to analyse our promotional information, such as which of our content in those promotional information you have accessed or on which links in those promotional information you have clicked (e.g. via tracking technologies such as web beacons in our e‑mails).||Your consent|
|3||We process your personal data to create a unique profile of you to enhance your experience based on your location, your order history, your preferences, your interests and the content in our promotional information you have accessed.||Your consent|
|4||We process your personal data in order to be able to process your order and to be able to deliver to you the materials or information you request or to provide you with the services you request.||A contract with you|
|5||We process your personal data to provide you, in a personalized and efficient way with the materials, services or information you request via one our Website, e‑mail or telephone.||Our legitimate interest
A contract with you
|6||We process your personal data:
||A legal obligation|
|7||We process your personal data to send you promotional information for materials or services similar to those you previously purchased or received from us, such as communications, promotions, offerings and newsletters, via e‑mail or other person-to-person electronic communication channels. You may opt out from receiving such mailings by clicking the opt-out link in the e‑mail, or you can object to further receiving these mailings at any time by contacting email@example.com.||Our legitimate interest|
|8||We process your personal data to perform statistical analyses in order to be able to improve our Website, promotional information, materials and services or to develop new materials and services.||Our legitimate interest|
|9||We process your personal data to preserve our legitimate interests or to preserve the legitimate interests of a third party in case your use of our Website or other communication channels can be considered:
||Our legitimate interest|
7. Do we share your personal data?
We will never disclose your personal data to third parties outside The Global Pioneers Inc. without your consent or another lawful basis, unless legally obliged to do so. For example, we may rely on service providers to:
- provide you our Website (such as a hosting provider); or
- target our promotional information (such as a marketing company).
These third parties are only allowed to process your personal data on our behalf and upon our written instruction. We also warrant that all those third parties are selected with due care and are committed to observing the safety and integrity of your personal data.
We may be legally obliged to share your personal data with competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
We do not send your personal data in an identifiable manner to any other third party than the two mentioned in this sub-section without your explicit consent to do so.
8. Where do we process your personal data?
We process your personal data both within and outside the European Economic Area (EEA), including in the USA. In order to process your personal data for the purposes outlined above, we may also transfer your personal data to third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data.
For The Global Pioneers Inc., such safeguards result from the fact that we are directly bound by compliance with EU legislation in the context of personal data protection. For third parties, such safeguards may be the consequence of:
- The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
- A contractual arrangement between us and that entity; or
- An approved certification mechanism, such as the EU-US Privacy Shield decision adopted by the European Commission on 12 July 2016.
9. What quality assurances do we comply with?
We do our utmost best to process only those personal data which are necessary to achieve the purposes mentioned above.
Your personal data are only processed for as long as needed to achieve the purposes listed above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. We will de‑identify your personal data when they are no longer necessary for the purposes outlined above, unless there is:
- An overriding interest of The Global Pioneers Inc., or any other third party, in keeping your personal data identifiable; or
- A legal or regulatory obligation or a judicial or administrative order that prevents us from de‑identifying them.
We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss tampering or destruction. Access by our staff members or third parties’ personnel will only be on a need-to-know basis and be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.
If you are registered to receive promotional information, such as communications, promotions, offerings and newsletters, via e‑mail or other person-to-person electronic communication channels, you can change your preferences for receiving such promotional information by clicking the opt-out link provided in such promotional information.
10. What are your rights?
You may at any time request information about your personal data, rectification, erasure or restriction of your personal data and you may object to further processing thereof by contacting the Data Protection Officer via firstname.lastname@example.org or the contact details below.
More specifically, you have the right to request access to all personal data processed by us pertaining to you, meaning that you have the right to ask us for a copy of your personal data. We reserve the right to charge a reasonable administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request must specify which data categories you wish access to and for what processing activities.
You have the right to rectification, i.e. to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.
You have the right to withdraw your earlier given consent for processing of your personal data.
You have the right to erasure, i.e. to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against:
- Our and a third parties’ interests which may override your interests; or
- Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
You have the right to restriction instead of deletion, i.e. to request that we limit the processing of your personal data if:
- We are verifying the accuracy of your personal data; or
- The processing is unlawful and you oppose the deletion of your personal data; or
- You require your personal data to establish, exercise or defend a legal claim, while we do no longer need your personal data for the purposes listed above; or
- We are verifying whether our legitimate interests override your interests if you exercise your right to object (see below).
You have the right to object to the processing of personal data for direct marketing purposes and, in addition, if:
- There are justified reasons connected with your particular situation that warrant such objection; and
- The processing is based on our legitimate interest and our legitimate interests do not override your interests.
You have the right to data portability, i.e. to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us if the processing is based on your consent or a contract with you and the processing is carried out by automated means.
If you wish to submit a request to exercise one or more of the rights listed above, you can contact our Data Protection Officer by sending an e‑mail to email@example.com. An e‑mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should meet the following conditions:
- State clearly which right you wish to exercise; and
- State clearly the reasons for exercising your right if such is required; and
- Your request should be dated and signed; and
- Your request should be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, we may ask you for your signed confirmation and proof of identity.
We will promptly inform you of having received your request. If the request meets the conditions above and proves valid, we will honor it as soon as reasonably possible and at the latest thirty (30) days after having received your request. If you have any complaints regarding the processing of your personal data by us, you may always contact our Data Protection Officer by sending an e‑mail to firstname.lastname@example.org. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority (see the list of national authorities at edpb.europa.eu/about-edpb/board/members_en).
11. Data Protection Officer