GLOBALSTAR PRIVACY NOTICE

Effective Date: March 26, 2020
 
This policy explains how Globalstar collects, uses and shares information about you when you purchase or use our products, services, websites or apps that link to this notice (“Globalstar services”).  When we say “Globalstar”, “us”, “we”, or “our/ours”, we generally mean Globalstar, Inc. but, in the specific cases set out in Who is responsible for my information, it means another Globalstar entity.

Table of Contents
1. Personal Information We Collect
2. Use of Your Personal Information
3. Disclosure of Your Personal Information
4. Cookies and tracking technologies
5. Data Retention
6. International Transfer
7. Our Policy Toward Children
8. Notice to EU and Other Non-U.S. Residents
9. Notice to California Residents
10. Notice to Nevada Residents
11. Other Websites
12. Who is responsible for my information?
13. Joint control of EU data
14. Policy Changes


1.Personal Information We Collect

Globalstar collect various kinds of personal information depending on the circumstances, such as: 

  • Contact information. We collect information such as your name, title, postal and delivery addresses, telephone number and fax and e-mail address through our service and credit application forms, from business cards or electronic equivalents that you provide to us at trade shows or through our website (such as when you purchase or request further information about our products or services or create an account) or when you contact customer support. Where an individual is an employee of a Globalstar business customer, the contact or other personal information collected by Globalstar may include the name that person’s employer, title and related business contact information.
  • Service preferences and related information. We collect information as a part of the service application process, including your service, billing and payment preferences / selections, as well as the identity and other details of your dealer.  We get this information from you or your dealer.
  • Billing and payment information. When you purchase products or services from us, we assign you an account number and collect payment information such as your credit card number or other payment-method details, and your account, billing and payment status and history. 
  • Credit and related financial information. We collect credit information and your financial history directly from you on our credit application form as well as from your creditors and your financial institutions, credit bureaus and reporting agency reports, trade credit references or organizations with whom you have had or may have a financial relationship. We also compile credit information relating to your transactions or account history with us. Credit-related information includes in this regard information you provide to us that we use for matching credit information with the above organizations, such as your date of birth or other identifiers you provide us.
  • Product and service usage information. When you use our products or services or contact our customer assistance services, we process information such as your past orders, current type of satellite phone and Globalstar service (to ensure compatibility), service phone number, frequency, duration, traffic and other related information regarding your use of our products and services and customer support history, including inquiries or complaints or records of other customer services we may provide.
  • Job information. When you apply for a job with us, we collect the information you provide us including your contact details and information contained in your CV. We also collect information recorded during any interviews or obtained from references you provide.
  • Information we collect by automated means. When you visit our website, our server logs automatically record information such as IP address, operating system, browser type, domain of visitor, time and duration of visit and pages requested. These statistics are collected and used only on an aggregate basis. 

Some information may be necessary for us to provide certain products or services or required by law. We will inform you at the time of collection whether the information we request is mandatory.

2. Use of Your Personal Information

We use the personal information we collect (including by combining information collected in different ways) for a variety of purposes depending on the Globalstar products and services you use and how you use them.  We use your personal information for:
 
  • Provision of services / products. In order to provide you with our products / services and perform our contract with you, we may use your personal information in a number of ways. This includes using your personal information to:
    • provide, administer and activate (or deactivate) the products and services you request;
    • process billing and invoices and manage, administer and collect or otherwise enforce your account;
    • calculate and evaluate service usage, including for the purposes of calculating commissions owing to your dealer;
    • provide requested customer service, respond to your service, billing or other inquiries about our products and services and contact you regarding your service or account;
    • ensure compatibility among the products and services you purchase; and
    • confirm the identity of our customers that call for customer service (for instance, by verifying account number, address or other unique identifiers such as Social Security Number or date of birth).
  • Business purposes. We also use your personal information where it is necessary as part of our day-to-to-day commercial activities and is in our or others’ legitimate interests as a business. This includes using your personal information to:
    • evaluate your application and determine your initial and ongoing eligibility for our services / products;
    • verify and evaluate your current and ongoing creditworthiness and, in the case of personal identifiers you provide us, to match credit information with information collected through credit bureaus or reporting agencies;
    • provide credit references to other creditors who have a legitimate interest in that regard;
    • keep our products and service secure;
    • learn about our customers’ interests and preferences and undertake internal aggregate market and other analysis so we can improve our products and services;
    • prepare, tailor and send marketing materials that directly relate to your use of our products or our service or that we think interest you;
    • respond to your requests for more information about our products and services;
    • enable you to review past orders and make subsequent purchases more conveniently;
    • contact referrals that you have lawfully provided to us; 
    • manage our business and partner relationships;
    • maintain business records for reasonable periods, and generally manage and administer our business; and
    • provide information to our professional advisers where necessary, such as our accountants and lawyers.
  • Marketing. Globalstar may also use your marketing preferences and contact information and information about your past purchases or service options to send you information about other products and services of Globalstar that we think would be of interest to you, based upon the information we hold about you. We do this based upon our legitimate interest in sending you information about products and services we think will interest you and, where required by law, with your consent. You can unsubscribe from marketing communications at any time by contacting us or using the unsubscribe link in the message. 
  • Recruitment. If you have applied for a job with us, we use information about you to consider whether you are suitable for a position with us and to verify the accuracy of the information you have provided use.  We do this based upon our legitimate interest in employing and engaging suitable and well qualified people.
  • Fraud, compliance and legal reasons. We may also need to use your personal information in order to prevent fraud, defend or exercise our legal rights or in order to comply with legal obligations, i.e. to meet legal, regulatory, security, audit and processing requirements or otherwise as permitted or required by law.  We do this based upon those legal requirements or our legitimate interest in that regard.

3. Disclosure of Your Personal Information

We may disclosure your personal information to:
 
  • Affiliates. Your personal information may be disclosed to our parent corporation or certain other affiliates for internal audit, management, billing or administrative purposes. Globalstar, Inc. and some of its affiliates are located outside of the European Economic Area, so Globalstar may transfer and process your personal information to countries other than your country of residence. For more information, please see the "International Transfer" section below.
  • Your Dealer. Your dealer may have access to the information you provide in your service application form which it collects from you as a part of the sign-up process. In addition, certain account and usage information, such as service phone number, traffic details and/or activation status may be disclosed by Globalstar to your dealer for the purpose of determining and verifying commissions and maintaining business records. Our dealers are independent businesses and responsible for how they use your information – you should check their privacy notice for more information on how they use your information. Globalstar does not control and is not responsible for what they do with your personal information. If you have questions or concerns how those independent businesses use or disclose your personal information, you need to contact them directly. 
  • Service Providers and Professional Advisers. Globalstar may transfer personal information to outside agents or service providers (including affiliates of Globalstar acting in this capacity) that perform services on our behalf, for example billing, mailing, collection or information technology hosting or processing services, as well as our professional advisers (who are often independent ‘data controllers’) such as lawyers and accountants. Some of these may be located outside of the European Economic Area and your personal information may be collected, used, disclosed, stored and processed in the U.S. or other jurisdictions outside of the European Economic Area for the purposes described in this notice. 
  • Process payments. We transmit your personal information via an encrypted connection to our payment processors.
  • Mergers and Business Transactions. Your personal information may be used by Globalstar and disclosed to parties connected with the contemplated or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets (including, for example, your service account with us), for purposes related to the evaluation and performance of these transactions or to give effect to them, including: 
    • permitting such parties to determine whether to proceed or continue with the transaction;
    • fulfilling reporting, inspection or audit requirements or obligations to such parties; and
    • the use and disclosure of your personal information by such parties for substantially the same purposes as described in this statement.
  • Other Recipients. Globalstar may otherwise disclose personal information as necessary to meet legal, regulatory, insurance, audit, processing and security requirements as permitted or required by law. This may include disclosing personal information to law enforcement authorities where Globalstar has a legal obligation to do so or it is otherwise permitted by applicable law or we considered it appropriate to do so.  We do this to comply with our legal obligations and in our and others’ legitimate interests in protecting the property, rights, name and safety of us and others.

4. Cookies and tracking technologies

Our site makes use of cookies and similar technologies in accordance with our Cookie Notice.

5. Data Retention

We retain your information for the period necessary to fulfil the purposes outlined in this notice or such longer retention period as may be required or permitted by applicable law. For instance, we may keep your information to comply with our legal obligations (e.g. tax laws), to resolve disputes, to enforce our contracts or as otherwise permitted by law.

The precise periods for which we keep your personal information vary depending on the nature of the information, why we need it, and applicable law. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to a contract or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, where we are using your personal information in order to provide you with services / products and perform our contract with you, we normally retain the relevant information for the duration of the contract and a period of 7 years after that. After that period, we normally anonymize or depersonalise and aggregate the data and then use it in its anonymized or aggregated form for internal research and analysis. Where personal information are provided to request direct marketing and similar materials from Globalstar, we keep that personal information until you ask us not to send any further such materials. We will keep a record of any request not to receive these materials to ensure we do not send you marketing emails in the future. When you apply for a job, we keep your CV and other information for 10 years after the date of application or termination to comply with regulatory requirements. 

6. International Transfer

Your information may be transferred to and maintained outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. For instance, as Globalstar, Inc. is a US company, information about our customers is kept in the US. We therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfers. For transferring personal information from the EU to countries outside the EU, Globalstar is using agreements based on EU Model Clauses, as well as the Privacy Shield. Globalstar ensures that personal information processed in this way is protected, in accordance with applicable law. If you want a copy of the standard EU Model Clauses you can ask us by email to the email address below. 
 
Globalstar, Inc. participates in the EU-US and US-Swiss Privacy Shield in the manner described in our Privacy Shield Certification, which can be accessed here [link]. We are committed to processing any personal data received from the EU or Switzerland in reliance on Privacy Shield in accordance with the Privacy Shield Principles including notice, choice, accountability for onward transfers, security, data integrity and purpose limitation, access, recourse, enforcement and liability. All Globalstar companies are required to follow the privacy practices set forth in this Privacy Statement.
 
If you have a Privacy Shield-related complaint or inquiry, please contact us at privacy@globalstar.com. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Privacy Shield Principles, we will seek to resolve it through our internal complaint resolution process, or alternatively through the independent dispute resolution body, JAMS Alternative Dispute Resolution, and under certain conditions through the Privacy Shield arbitration process.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield . Under certain conditions (more fully described at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration where other dispute resolution procedures have been exhausted.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other US authorized statutory bodies. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Under certain circumstances, Globalstar, Inc. may be liable for the transfer of personal data from the EU or Switzerland to third parties outside the EU and Switzerland. Further information on Privacy Shield is available here (https://www.privacyshield.gov/welcome).
 
Under the Privacy Shield Principles, you have the right, with respect to any personal information subject to our certification under the Privacy Shield, to opt out of: (i) disclosures of your personal information to third parties (other than our agents that are performing tasks on our behalf under our instructions); or (ii) uses of your personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.
 
If we receive personal information subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the personal information in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.



7. Our Policy Toward Children

We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without his/her consent, he or she should contact us at privacy@globalstar.com (see 'Your Rights and Contacting Us' below) in order to confirm our authorization or to object to the processing. We may follow up by phone or other means in some circumstances.  If we become aware that a child under 18 has provided us with personal Information, we will delete such information from our files.  

8. Notice to EU and Other Non-U.S. Residents

If you are located in the EEA or Switzerland, you may have certain additional rights in certain circumstances (though these are subject to various limitations and exceptions). These include:
  • right to access and to obtain information regarding the processing of your personal information we control;
  • right to rectify your personal information where it is inaccurate;
  • right to have your personal information erased (right to be forgotten);
  • right to restrict processing of your personal information;
  • right to lodge a complaint with a supervisory authority;
  • right to object to processing, including for direct marketing purposes; and
  • right to data portability, 
  • right to withdraw any consent you give us or unsubscribe from marketing messages,

You should note that the withdrawal of your consent (including for marketing purposes) does not affect the lawfulness of processing based on your consent before its withdrawal. If you withdraw your consent in some cases, it may impact upon our ability to provide certain services to you.

If you wish to contact us or exercise your rights, you may write to the address set out in section 10, attention Privacy Officer, contact us at privacy@globalstar.com, contact Customer Relations here, or complete the form linked to the ribbon labeled “Data Subject Request” on the right side of this screen.

The Irish Data Protection Commission is the lead supervisory authority of Globalstar under EU data protection law. Its contact details are:

Office of the Data Protection Commissioner
Canal House, Station Road
Portarlington, Co. Laois, R32 AP23, Ireland
Phone: +353 (0761) 104 800
LoCall: 1890 25 22 31
Fax: +353 57 868 4757
Email: info@dataprotection.ie


9.  Notice to California Residents
 
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities to which we share such information in the Personal Information We Collect, Use of Your Personal Information, and Disclosure of Your Personal Information sections of this Privacy Notice. We provide additional information below.  Categories of personal information we collect, use and disclose.  Throughout this Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and share such information.  See “Personal Information We Collect” for more details. The following are the “categories” of personal information under the CCPA that we collect and that we may, as discussed throughout this Policy, use and disclose for our business purposes: 
 

Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history or app usage (such as your notes and highlights in the Services)); physical characteristics or description (such as voluntarily submitted profile photo); audio information (such as recorded calls with our Customer Relations team); limited medical information (Such as voluntarily provided medication allergies to be used in an emergency situation, or details related to an S.O.S. call);  general and precise geolocation data; any user-generated content or feedback you provide; professional or employment related data; and other information that identifies or can be reasonably associated with you. 

How we use these categories of personal information.  We use the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy.  See “Use of Your Personal Information” for more details.
 
California Privacy Rights

CCPA Rights.  California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you may request that we:
  • provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information.  Such information is also set forth in this Notice.
  • provide access to and/or a copy of certain information we hold about you;
  • delete certain information we have about you; and/or
  • provide you with information about the financial incentives that we offer to you, if any.

California residents can also designate an authorized agent to make access and/or deletion requests on their behalf. We will take reasonable steps to verify your identity before responding to a request for access and/or deletion from you or your designated agent. 

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. 

Please note that certain information may be exempt from such requests under California law.  For example, we need certain information in order to provide the Globalstar services to you. 

If you would like to exercise any of legal rights under the CCPA, please contact us at privacy@globalstar.com or complete the form linked to the ribbon labeled “Data Subject Request” on the right side of this screen.

Sale of personal information.  The CCPA sets forth certain obligations for businesses that “sell” personal information.  Pursuant to the definition of sell under the CCPA and current guidance, we do not engage in such activity and have not engaged in such activity in the past twelve months, including for minors under 16 years of age without affirmative authorization. Please note, we do share certain personal information with our service providers and certain other entities as set forth in “Disclosure of Your Personal Information.”

Shine the Light: California Law permits visitors who are California residents to request once per year certain information regarding our disclosure of personal information to third parties for such third parties’ direct marketing purposes.  To make such a request, please send an email to privacy@globalstar.com or write to us at Globalstar, 1351 Holiday Square Blvd., Covington, LA  70433.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals. We do not recognize or respond to browser-initiated Do Not Track (“DNT”) DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT and a common approach to responding to DNT. Visit All about DNT to learn more about Do Not Track.

10.  Notice to Nevada Residents
 
Under Nevada law, certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information to additional persons.  “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. 

Globalstar does not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from Globalstar, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at privacy@globalstar.com.  Please add “Nevada” in the subject line. Note we will take reasonable steps to verify your identity and the authenticity of the request.  Once verified, we will maintain your request in the event our practices change.  

 
11.  Other Websites

Our website may contain links to other websites.  These websites have different privacy notices and practices to Globalstar's. Globalstar has no responsibility for such third party websites. You should review the privacy notice of any third party website you visit.

12. Who is responsible for my information?

Globalstar is responsible for your personal information.

When we say “Globalstar”, “us”, “we”, or “our/ours” in this notice, we mean Globalstar, Inc. unless:
  • you have a contract with Globalstar Europe Satellite Services Limited, in which case we mean both Globalstar, Inc. and Globalstar Europe Satellite Services as joint controllers – see section 13 for more information in this regard;
  • you work for a supplier to another Globalstar entity and we accordingly hold limited information about you such as your job title and contact details, in which case we mean that other Globalstar entity; 
  • you have applied for a job with another Globalstar entity, in which case we mean that other Globalstar entity; or
  • you are on our payment processing page which is operated by CyberSource.com.
Spot LLC, a subsidiary of Globalstar, Inc.  contracts with certain Globalstar customers.  Globalstar, Inc. is the main decision maker with respect to how any such customers’ personal information is handled and is the point of contact with respect to personal information of Spot LLC’s customers.
Globalstar Europe Satellite Services Limited’s registered company number is 361768 and its registered office is at Unit 10, The Hyde Building, The Park, Carrickmines, Dublin 18, Ireland.  Globalstar, Inc., which holds your personal information, is accessible at 1351 Holiday Square Blvd., Covington, LA  70433.


13. Joint control of EU data

Globalstar Europe Satellite Services Limited (“Globalstar Ireland”), an Irish company established in the EU, contracts with certain Globalstar customers whose related personal data is within the scope of the GDPR (“EU Data”). Globalstar, Inc. and Globalstar Ireland jointly control EU Data. 
 
As between Globalstar, Inc. and Globalstar Ireland, Globalstar, Inc. is the main decision maker with respect to the processing of EU Data and is primarily responsible for fulfilling the controller responsibilities with respect to EU Data, with assistance from Globalstar Ireland where required.  For example, Globalstar, Inc. is the primary decision maker regarding what and why EU Data is collected, how it is used, how long it is retained and other decisions regarding it and, as between it and Globalstar Ireland, primarily responsible for making sure this is done in accordance with the GDPR. Globalstar, Inc., as between Globalstar, Inc. and Globalstar Ireland, is also primarily responsible for informing you how Globalstar processes your EU Data (including by providing this notice), deciding how to implement data subject requests and, where necessary, primarily engaging with data protection supervisory authorities and making notifications to them and data subjects. Globalstar Ireland assists Globalstar, Inc. in this regard.
 
Globalstar Ireland implements the decisions of Globalstar, Inc. with respect to the processing of EU Data and acts as the main establishment in the EU of Globalstar, Inc. and Globalstar Ireland with respect to the processing of jointly controlled EU Data.  The Irish Data Protection Commission is the lead supervisory authority with respect to EU Data.  Globalstar Ireland also engages direct with customers with respect to certain functions such as billing and customer services.  
 
Globalstar Inc. is the main point of contact for data subjects with respect to EU Data so, for example, it is best to contact Globalstar Inc. if you want to exercise your data subject rights under the GDPR with respect to EU Data.  Its contact details are set out in section 12 above. Irrespective of this arrangement, you can exercise your rights under the GDPR against either Globalstar, Inc., or Globalstar Ireland with respect to EU Data.


14. Policy Changes

We’ll update this notice from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “effective date” text at the top of the notice and post it on our sites. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).

We encourage you to check back periodically to review this notice for any changes since your last visit.  This will help ensure you better understand your relationship with us, including the ways we process your personal information.