GlobalEyes Network Inc. Privacy Policy

LAST UPDATE OF THIS PRIVACY POLICY – September 17, 2025

 

Introduction

The GlobalEyes Network Inc. (the “Corporation”, “GlobalEyes,” “we”, “us”, or “our”) recognizes the importance of protecting your personal information. This policy (the “Policy”) explains how we collect, use, and disclose your personal information.

Personal information is any information that allows you to be identified, directly or indirectly.

By providing us with your personal information, you consent to the collection, use, and disclosure of your information in accordance with this Policy.

We will only collect, use, and disclose your information with your consent, which may be express or implied under certain circumstances, or as otherwise required or permitted under applicable law.

We reserve the right to update this Policy at any time, and such modifications will enter into force on the date specified in the update. Please make sure to check for changes to this Policy. We will consider that you have accepted the changes to this Policy if you continue to provide personal information to us once the changes enter into force.

Where Policy is Not Applicable

This Policy applies to the users and customers of our websites, applications, products, and services. It does not apply to our employees or candidates.

This Policy also does not apply to any information we handle on behalf of our customers. Specifically, it does not apply to any student information stored on our platform or information pertaining to students or their parents or guardians as we handle this information on behalf of our customers and program agents.

If you have any questions about or wish to access student information stored on our platform, please contact your school or the administrator of the program.

This Policy also does not apply to any ‘business contact information’ such as an employee’s name, title, business address, telephone number or email address that is collected, used or disclosed solely for the purpose of communicating with that person in relation to their employment or profession.

How We Collect Personal Information

We collect your personal information on our own behalf and on behalf of our clients and service delivery partners.

Your personal information may also be collected on our behalf by third parties, such as: health insurance providers, GlobalEyes travel consultants, marketing consultants contracted through GlobalEyes, customer complaint handling or other agencies working through the GlobalEyes platform.

We collect personal information directly from you when you provide it to us, for example:

  • Online on our website;
  • In emails you send us;
  • When you call or otherwise interact with us.

In addition to the above, we may also collect personal information when you decide to subscribe to a newsletter, enter a contest or take part in a survey.

The information we collect includes the following personal information:

  • First and last name, your mailing/residential address, email address, telephone number, and your communications with us. The type of personal information we collect depends on various factors and on the context. We only collect such personal information that we consider necessary for the conduct of our business and to provide our services.

Personal information may be collected if it is publicly available online, such as in social media accounts. We may also collect personal information from our business partners or other third parties, provided that such third parties confirm that you have authorized them to disclose such information to us or that you expressly consent to such disclosure.

We automatically collect personal information provided by analytical tools or digital markers on our websites and in our applications. These analytical tools only collect a limited set of data, consisting of the Internet protocol address (IP address), date and time of the visit, pages visited, actions on our website, domain used to access the website, the type and version of the browser or operating system you use, as well as the previous and subsequent website accessed. This information is collected using cookies, as described in greater detail below.

We do not collect any information relating to payment cards. Payments made via our websites or applications are processed directly by our service provider, which has sole access to payment card information. Your online transactions are secured in accordance with our service provider’s transmission standards, so that your transactions are routed and processed securely.

We collect personal information for the following purposes:

  • To provide the services or information you request;
  • To enter into contracts with you or your organization;
  • To process your requests;
  • To communicate with you about students or the relevant programs;
  • For research and surveys to gauge user satisfaction, marketing purposes, or for educational purposes;
  • To manage billing and process payments;
  • To process and resolve complaints;
  • To communicate with you in the course of our activities, for the purposes of internal quality assurance or to manage the quality of the information provided;
  • To detect and prevent fraud;
  • For statistical and accounting purposes (in these cases, personal information is aggregated and anonymized);
  • With your consent, to inform you of news, updates, information and special offers concerning our products and services;
  • If we have reasonable grounds to believe that it might be useful as part of the investigation of a violation of applicable federal, provincial or foreign law or to ensure the protection or defence of a legal interest;
  • To administer your account or services, including reward programs, draws and contests;
  • As required or permitted by applicable laws.

In addition to the purposes described above, we will inform you of other purposes for which your personal information is collected at the time of collection.

Automatically Collected Information

We may use cookies. Cookies are fragments of information sent to your computer or mobile device when you view a website. They are saved, temporarily or permanently, on your computer’s or mobile device’s hard drive, leaving a record of your visit. Every time you go to a website, a cookie can be created and stored, which allows us to “recognize” you each time you consult the website.

Cookies that allow you to be identified, located or profiled are deactivated by default. You must first accept them. You may refuse such cookies, but if you do, some functionality will not be available.

Cookies can allow us to analyze your personal preferences, interests or your behaviour when you browse the Internet. They help us to improve your online experience by recording your navigation preferences, analyze the operation of our websites, perform statistical analysis and recommend content to you.

While you are not required to accept cookies, it is possible that certain website functionalities may not work properly if you refuse cookies. Consult the following link for an overview of how to disable or delete cookies in current browsers: https://www.allaboutcookies.org/.

Our website uses Google Analytics, a web analytics service provided by Google LLC. (“Google”). Google Analytics uses “cookies”, which are text files placed on your device, to help us analyze how users use our site.

The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google uses this information to evaluate your use of the website, compile reports on website activity, and provide other services relating to website activity and internet usage.

You can opt out of Google Analytics by installing the browser add-on available at: https://tools.google.com/dlpage/gaoptout.

For more information on Google’s privacy practices, please visit: https://policies.google.com/privacy.

Refusing the Collection of Personal Information

You can refuse to consent to the collection of your personal information. However, doing so could limit our ability to offer you services or sell you products. If you withhold such consent, we will not deny you products or services unless they cannot be provided without such collection.

Information of Minors

It is our intention to comply with all applicable laws regarding children’s privacy and advertisements that target them. We do not seek to collect personal information about minors under 14 years of age without the verified consent of the parent/legal guardian. However, if you believe that we do so, please let us know. If we wish to collect personal information about minors under 14 years of age, we will obtain consent directly from the parent/legal guardian, in accordance with applicable laws.

All student information and information of minors stored on our platform is handled in accordance with Canadian privacy law and the policies and instructions of our clients and local agents. Our clients and local agents are subject to the laws of the local jurisdiction and are not subject to this privacy Policy.

Who Can Access Personal Information Inside and Outside the Corporation

We will never sell your personal information to anyone. We will only transfer or disclose personal information about you to third-parties as follows:

  • You have authorized us to disclose the information to a third party for a specific purpose;
  • The third parties are acting on our behalf as agents or service providers (for example, information technology service providers, health insurance providers, hosting providers, marketing solution providers, transportation and shipping providers handling products you order from us, and our affiliates with whom we share services, infrastructure, systems and technology). We have contractual or other means in place with these service providers that oblige them to protect your information and only handle your information in accordance with our instructions;
  • If a person is acting as your representative or if we reasonably believe that the person has appropriate authorization to act (for example as tutor, holder of parental authority, etc.), or is a person who owns a service or product jointly with you;
  • To satisfy legal requirements;
  • If we are required to provide personal information in response to a legitimate court order, subpoena to submit documents or investigation by authorities or as otherwise required by applicable laws;
  • If the Corporation sells its business or assets, in whole or in part, or is involved in a merger, as required by such a transaction, or as part of due diligence;
  • As required or permitted by applicable laws.

How We Safeguard Personal Information

We have implemented reasonable physical, technical, and administrative security measures to protect personal information from being lost or stolen, or from being accessed, disclosed, copied, used or modified without authorization. The nature of these security measures varies by the sensitivity, quantity, distribution and format of the personal information collected, as well as by the storage methods used.

International Transfer of Information

Depending on the nature of the personal information, it may be stored and processed in our offices, as well as in the various computer systems in our offices, in our storage facilities, or in those of our service providers.

While your information will be stored in Canada, your personal information may be transferred outside Canada, specifically, to the United States, for the purposes described above, including its collection, use, disclosure and storage. Please note that information stored outside Canada will be subject to the laws of that local jurisdiction.

Retention of Personal Information

We retain the personal information we collect for as long as required to meet identified purposes, as long as it is reasonable to do so for customer service, legal or commercial reasons. The retention period depends on the purposes and the nature of the information. On the expiry of this period, we permanently and securely destroy or anonymize the information in compliance with applicable legislation.

Third Party Sites

Our websites and applications may contain links to third party websites or applications (collectively, “Third Party Sites”). We are not responsible for the privacy practices of Third Party Sites, which are not under our control. Any personal information transmitted through Third Party Sites is subject to the privacy policy of those Third Party Sites. It is your responsibility to review those policies to ensure your personal information is protected.

We may use Third Party Sites of social media sites (such as Facebook and Instagram). Our social media accounts are public and we do not operate the sites that host them. If you decide to interact with us through one of these social media sites, you should first review their privacy policy.

The personal information provided to us through social media accounts is collected to capture conversations (for instance, questions and answers, comments, “Likes,” and shared tweets) between us and you. It may be used to respond to requests, carry out analyses or create reports and for all other purposes set out in this Policy.

Your Privacy Rights

Subject to the limits and provisions of applicable laws, you have the right to:

  • Access your personal information;
  • Rectify or update your personal information;
  • Withdraw your consent at any time (the withdrawal of consent is binding on us with regard to the personal information the use of which was based on such consent; the withdrawal of consent will not affect the lawfulness of use based on your consent before its withdrawal);
  • Request the deletion of your personal information if it is outdated or not justified for the purposes it was collected.

If you submit a request to withdraw your consent to use or disclose your personal information, how we handle that request will depend on the situation and reasons:

  • You may withdraw your consent, but we will no longer be able to provide you a service or product that requires such consent; or
  • You may not withdraw your consent because processing your personal information is necessary or mandatory.

In either case, we may be legally required to retain certain personal information.

You may exercise the foregoing rights at any time by contacting our Privacy Officer (see below).

Any such request must contain sufficient details for us to be able to address it. We undertake to respond to any such request within a reasonable period of time, and to the extent possible, within a maximum of thirty (30) days, as set out in the applicable laws. We must, however, first verify the identity of the person making such a request.

We will ensure that your personal information is as accurate, complete and up-to-date as possible for the purposes for which it is used. However, it is your responsibility to advise us of changes to your personal information, such as your contact information.

Challenging Compliance and Complaints

If you have any questions, concerns, or wish to complain about our privacy practices, you may contact our Privacy Officer (contact details below). If you are not satisfied with our handling of your concerns, you may contact the Office of the Privacy Commissioner of Canada (federal), toll free at 1-800-282-1376.

Contacting Us

You may contact us by writing to our GlobalEyes Privacy Officer, Paul Millman, at [email protected] or via regular mail: The GlobalEyes Network, 2458 James Street, Halifax, Nova Scotia, B3K 3W7.

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