GlobalLogic Extension Privacy Policy

Effective Date: Oct 23rd, 2023

This GlobalLogic Extension Privacy Policy describes how GlobalLogic Inc., a Hitachi Group Company, including GlobalLogic Inc., its subsidiaries and affiliated entities (together, “GlobalLogic,” “we,” “us,” “our”) collects, uses, shares, and protects personal information received through our extensions that are offered on Adobe’s Commerce Marketplace. This Extension Privacy Policy also describes your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions, when it is the case that GlobalLogic is the appropriate party to contact.

Applicability and Scope

GlobalLogic offers two categories of extensions on Adobe’s Commerce Marketplace:

1. Extensions that are developed and offered by us on our own behalf, e.g., an extension that may be downloaded by merchants to add features to one of their products, such as a gift card, to add engraving to a product, or to implement CAPTCHA (“GL Extensions”). As described more fully below, for GL Extensions, merchants implement the extensions on their own online stores, and data collected from a GL Extension is not shared with GlobalLogic.  Rather, only basic information pertaining to the merchant’s own registration with Adobe Commerce (e.g., the merchant’s contact information such as business contact name, phone number and email) is shared by Adobe with us; and
2. Extensions that are developed for and published by GlobalLogic on behalf of a client that hosts the extension on the client’s own servers, e.g., extensions to assist with a GlobalLogic client’s customizations, such as to assist one of its customer’s account owner validations, for add-ons to a webstore (such as augmented reality), or to offer a plugin to obtain a shipping address for an order (“Client Extensions”). As described more fully below, all personal information collected via a Client Extension is managed by the GlobalLogic client, and not GlobalLogic itself, and all inquiries and rights in relation to such personal information collected or transferred via a Client Extension should be directed to the GlobalLogic client.

GlobalLogic as Controller (this Privacy Policy applies)

This Extension Privacy Policy applies to our processing of your personal information both when you choose a GL Extension as a merchant, as well as when you are a GlobalLogic client instructing us to build a Client Extension. In this case, we are considered the controller of your personal information under privacy law that may be applicable in your jurisdiction of residence.

GlobalLogic as Processor (this Privacy Policy does not apply)

When you are an end user of a GlobalLogic client and are using a Client Extension, in any limited cases where we process personal information on behalf of a GlobalLogic client, we are considered the processor of your personal information on behalf of our client, who is considered the controller of your personal information under privacy law that may be applicable in your jurisdiction of residence. In such cases, we kindly request that you visit and consult the privacy policy of the named client to learn more about the personal information that is processed about you and what your rights are.

Information We Collect

Only limited personal information is collected or received from GL Extensions and Client Extensions.  This includes information collected:

• Directly from you when you provide it to us, such as when you as a merchant or end user contact us via an extension’s feedback or support form, and we ask that you only provide information strictly required to resolve your issue.
• From other sources, such as from merchants that purchase a GL Extension on the Adobe Commerce Marketplace, who provide their business contact information collected by Adobe while registering for Adobe’s Commerce Marketplace.

The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

If you are not comfortable with our collection and use of personal information for the purposes stated below, please discontinue use of the extension immediately.

How We Use Information.

In addition to the purposes and uses described above, we use information in the following ways:

• To provide services.
• To improve our service offerings.
• To streamline the checkout process.
• To conduct analytics.
• To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
• To send marketing and promotional materials including information relating to our products, services, sales, or promotions.
• To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
• To debug, identify and repair errors that impair existing intended functionality of our GL Extensions and Client Extensions.
• To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
• For internal administrative purposes, as well as to manage our relationships.
• For such other purposes as you may consent (from time to time).

Although the sections above describe our primary purpose in collecting your information, in some situations we have more than one purpose.

To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.

How We Share Information.

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

• Affiliates and Acquisitions. We may share information with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).
• Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
• Service Providers. We may share your information with service providers who are limited by contract to using personal information to provide services solely on our behalf and pursuant to our instructions. Service providers may help us to administer our website, conduct surveys, provide technical support, customer relationship management, hosting/storage, process payments, accounting, provide analytics, and assist in the fulfillment of orders.
• Corporate Transactions. We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our extensions users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your personal information, unless you contact us at the information below and request to be opted-out of any such transfer.
• Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.

We do not sell or share your personal information for money or for cross context behavioral advertising purposes, as defined in the California Consumer Privacy Act as amended by the Consumer Privacy Rights Act.

Your Rights, Data Retention, Security, Additional Information for Other Jurisdictions

GL Extension Merchants and Client Extension Clients.  If you are a merchant purchasing a GL Extension, or a client engaging GlobalLogic to create an extension on the client’s behalf, then in relation to the personal information provided to GlobalLogic by Adobe or that you provide to GlobalLogic for administration of your client account, you may exercise the following privacy rights:

• Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
• Right to Correct. You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate. In addition to the methods described below, you can correct your personal information through your account settings.
• Right to Delete. Under certain circumstance, you may have the right to request that we delete the Personal Information that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your personal information, for legitimate purposes, or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable laws and their exceptions.

Please note that your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.

For more general information about our data retention policies, our security policies, and additional information that may apply depending on your location of residence, please consult the relevant sections in our General Privacy Policy.

You may contact us at any time with inquiries or to make privacy requests, as described below.  If you are not satisfied with our response, and you are a resident of the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.

Residents of California may be entitled to additional rights and disclosures under the California Consumer Privacy Act, as amended.  If you are a California resident, please see the section titled “ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA” in our General Privacy Policy.

Client Extension End Users.  If you are an end user of a Client Extension, please see the privacy policy of the client to learn of the client’s personal information collection, use, and sharing practices, as well as your privacy rights.  GlobalLogic is not responsible for collection of your personal information and is not able to assist with your privacy requests, only the GlobalLogic client is.

Transmission Of Personal Information To Other Countries

As a multi-national company, we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the Contact Information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.

Third-Party Applications/Websites

For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.

Changes To This Privacy Policy

We may update this Extension Privacy Policy from time to time to reflect changes in the law or as we update or expand our extensions and offerings. When we make a change, we will provide you with notice of such updates as required by applicable law, and we will revise the “Last Updated” date at the top of this Policy. All changes will be effective as of the “Last Updated” date. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access or use our extensions. If you have any questions about this Extension Privacy Policy, please reach out to us anytime as described in the contact information included within the “Contact Information” section below.

Contact Information

You can contact us at privacy@globallogic.com, or at our postal address:

GlobalLogic’s headquarters
2535 Augustine Dr 5th Floor

Santa Clara California 95054, United States of America

Attention: Chief Legal Officer

A list of companies of the GlobalLogic group, including their contact details and information regarding data protection officer (if applicable) can be found here.