The GLOBIS Group* (hereafter, GLOBIS or Group) recognizes the importance of complying with laws and regulations governing the protection of personal information and safeguarding privacy to ensure the safe and secure use of our services. Therefore, we have established a system for promoting compliance across the Group and developed internal regulations in our commitment to handle personal information with the utmost care.

Yoshito Hori
Founder and President of GLOBIS

This privacy policy (the “Privacy Policy”) applies to the use of all websites, including, but not limited to, www.globis.eu  (“Websites”), mobile applications (“Mobile Apps”) and other services, products and software provided by GLOBIS Europe BV (“GLOBIS”, “we” or “us”) linking to or posting this Privacy Policy (collectively, our “Services”).

Please read this Privacy Policy to understand how we process personal information about you, including when you visit or use our Services, attend a GLOBIS event, or otherwise interact with us. This Privacy Policy also describes your choices regarding the use, access, and correction of your personal information.

Where this Privacy Policy is incorporated by reference into the privacy policy of a GLOBIS affiliate, it shall apply to that affiliate’s websites, products and services and its processing of personal information of individuals located in the United Kingdom (“UK”) or the European Economic Area (“EEA”) to the extent such processing is subject to the General Data Protection Regulation (the “GDPR”).  In that case, “GLOBIS” as used in this Privacy Policy shall refer to the GLOBIS affiliate processing your personal information and in the event of a conflict between this Privacy Policy and any other privacy policy of the GLOBIS affiliate, this Privacy Policy shall control only with respect to individuals located in the UK or EEA and their personal information.  GLOBIS acts as the EEA representative for its affiliates.

Contact Us

For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”) and other applicable laws globally, GLOBIS Europe BV is the entity responsible for your personal information (the “data controller”).

If you have any questions regarding our Privacy Policy, or the way GLOBIS collects, uses, or otherwise processes your personal information, including the transfer or onward transfer of your personal information outside your jurisdiction of residence, please contact our privacy officer at:

Personal Information We Collect

When you use or access our Services or otherwise interact with us, we may collect a variety of information about you and others, as described below. Such information includes, but is not limited to, information about you which is in a form that permits us to identify you either on its own or in combination with other available information (your “personal information”).

Information you provide to us (direct or via a third party)

We obtain certain information when you provide it to us, or that someone on your behalf (such as your employer) provides to us. For example, when you request information such as via the ordering of a brochure, apply for a MBA or pre-MBA course, access and use our Services, when you sign up for our newsletter, report a problem, apply for a job with us, or communicate with us by phone, email or otherwise. The types of information may include:

  • Identity data, such as information that identifies you or your personal characteristics, including your name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact information, such as billing address, postal address, email address and telephone numbers.
  • Credentials, such as passwords, password hints or similar security information used for authentication and account access.
  • Course information, such as records of inquiries, interviews, applications, entrance application screenings and admissions, records of attendances and course transcripts, records and results of Service use, completed questionnaires, records of graduation, leaves of absence, suspensions and expulsions.
  • Transaction data, such as details about payments to and from you and other details of products and services you have purchased from us.
  • Marketing data, such as your preferences in receiving marketing from us, or your subscription preferences when you sign up to any email alerts, newsletters and other GLOBIS mailing lists.
  • Candidate data, such as employment history, qualifications, academic qualifications and education records, and any other information that you provide to us when applying for a job with us, for example in your curriculum vitae, a covering letter, on an application form or during an interview, or that we have received from a recruitment agency or background check provider.

We may also receive information about you from third parties, e.g., when you choose to access or log-in to a third party service (such as a social media website) from our Services or interact with our us on such third party sites.  If you log-in via Google Sign-In or another third-party service, we ask your permission to access certain information on that account.  For example, we may receive your name and email address.  We do not access or obtain any information beyond the information you decide to give us (via your privacy settings) or that the service shares with us.

Information we collect automatically

When you use or access our Services, we collect certain information about you and you use of our Services through automated means. This information may include (without limitation):

  • Device information, such as your Internet Protocol (IP) address, unique device identifiers, device data (including manufacturer, make and model), operating system, mobile network information, computer and connection information, browser type, existing applications, browsing activity, date and time, and non-precise or general device location information (e.g., city, or region, country, language. We also may collect any telephone number from which you contact us.
  • Log data, including information associated with your activities on our Services, including information about the way you interact with our Services or any content thereon, statistics regarding your page views and traffic to and from our Services, and the number of bytes transferred, hyperlinks clicked, and other actions you take. Our Services may also track information such as the URL that you visited before you come to the Services and the URL to which you next go.

We combine this information with information you give to us and that we collect about you. We will use this information and the combined personal information for purposes set out in this Privacy Policy (depending on the types of information we receive).

Cookies and similar technologies 

GLOBIS and our service providers use cookies and similar technologies (such as pixel tags and web beacons). A “cookie” is a piece of data that web servers install on a user’s system. The GLOBIS website uses cookies for the following purposes:

  • To confirm membership for exclusive services that require log-in
  • To analyze website access, including the numbers of visitors
  • To display customized website content

In addition, advertisements such as banner ads may also place third party cookies.   For more information about our practices in this area, and for a list of the cookies we use, please see our Cookie Policy.

Use of Personal Information

GLOBIS’s businesses include a graduate school of management, a non-degree business school, corporate training, publications, management research, venture capital, G1, and KIBOW.

While providing our Services, performing associated tasks, and hiring or contracting individuals in these businesses, GLOBIS makes use of personal information for the purposes set out in this Privacy Policy only where we have a valid legal ground for doing so under applicable data protection law. The legal ground will depend on the purpose for which we process your personal information and the data protection law that applies with respect to our activities in your jurisdiction.

Providing Services and performing associated tasks in our business as is necessary for the performance of our obligations under our customer contracts, or to answer questions or take steps requested prior to entering a contract with a customer, such as confirming applications and handling the payment of fees:

  • To confirm applications to our Services
  • To screen applicants for qualifications
  • To provide the Services for which customers have applied
  • To deliver books, instructional materials and other products to customers
  • To send invoices to customers for Services purchased
  • To send documents requested by customers
  • To confirm registrations for events and seminars
  • To confirm subscriptions to email communications such as newsletters

Improving our Services and developing new Services as is necessary for certain legitimate interests, or where customers’ have given their consent to such processing to the extent required by applicable law (such consent can be withdrawn at any time):

  • To improve existing Services (such as improvements in effectiveness and efficiency of service delivery, quality of contents, materials as well as methodologies in the area of teaching and learning) and develop new Services by measuring and analyzing quality, customer satisfaction, and customer needs and requirements
  • To measure the effectiveness of advertising and analyze marketing strategies
  • To communicate with customers and to conduct research about use of our Services
  • To request that customers complete surveys and/or research questionnaires related to current or future Services that we may offer

Conducting advertising and marketing as is necessary for certain legitimate interests, or where customers’ have given their consent to such processing to the extent required by applicable law (such consent can be withdrawn at any time):

  • To advertise our Services to students and customers via email, SMS, direct mail (by paper) and/or other means of delivery
  • To deliver targeted online advertising via third party websites or social media platforms based on certain demographic/behavioural attributes which we think may indicate potential interest in our business or Services. In doing so, we may provide personal data such as email addresses to social media ad platforms

Providing information and related Services that may be useful to customers, as is necessary for certain legitimate interests, or where customers’ have given their consent to such processing to the extent required by applicable law (such consent can be withdrawn at any time)

  • To provide information on related Services, events and seminars targeting previous users of our Services (e.g., providing email newsletters and pamphlets)
  • To provide information on Services, events and seminars that may be useful to customers and business partners who have provided their business cards when participating in our events, seminars, or business meetings. (e.g., providing email newsletters and pamphlets)
  • To share aggregated, non-personal information on demographics and characteristics of previous service users to explain our Services to third parties

Operating business related to investment, as is necessary for certain legitimate interests:

  • To review investment in and sale of stock, etc.
  • To undertake due diligence and money laundering checks as required by applicable law
  • To manage securities held
  • To perform other associated tasks

Screening and contacting candidates in the process of hiring or contracting staff and independent contractors, and managing human resources after hiring or contracting, as necessary in our legitimate interests:

  • To provide information to, contact, and notify applicants for hiring or contracting as well as hiring/staffing agents/companies regarding employment at or contracting with GLOBIS
  • To make hiring and contracting decisions in the process of screening applicants
  • To assess skills, qualifications, and suitability of a candidates for the roles applied for
  • To carry out background and reference checks, where applicable
  • To keep records related to our hiring processes
  • To comply with legal or regulatory requirements
  • To conduct tasks related to human resources management after an applicant is hired by or enters into contract with GLOBIS

Jointly Using Personal Information Among GLOBIS

GLOBIS may jointly utilize personal information it has acquired, as shown below, among affiliates and global offices, including GLOBIS Corporation; GLOBIS Capital Partners & Co.; the Educational Corporation of GLOBIS University; GLOBIS China Co., Ltd.; GLOBIS Asia Campus Pte Ltd.; GLOBIS Asia Pacific Pte. Ltd.; GLOBIS Thailand Co., Ltd.: GLOBIS USA Inc.; G1 Institute, and General Incorporated Foundation KIBOW.

Personal information that may be jointly utilized among GLOBIS:

  • For students and customers: A record of Services provided by GLOBIS; contact information; dates of birth; records of inquiries,; records and results of service use; records of questionnaires; records of graduation.
  • For prospective staff members: Contact information; dates of birth; academic records; career records; certifications held; reason for application; records of inquiries and interviews; and other information related to the individuals subject to the process of hiring or contracting.

Purpose of jointly utilizing personal information:

  • For students and customers: To provide appropriate information and guidance, to facilitate application procedures, to provide Services to students and customers, and to make improvements in relation to the Graduate School of Management, the GLOBIS Management School, corporate training, events, seminars, and all related Services.
  • For prospective staff members: To screen and contact candidates in the process of hiring or contracting staff and independent contractors, and to manage human resources after hiring or contracting.

Transfers of Personal Information

The personal information collected by GLOBIS is hosted in Japan and is subject to Japanese law.  The transfer of your personal information from the EEA or UK to Japan is conducted in reliance on the European Commission Decision 2019/419 on the adequate protection of personal data by Japan under the Act on the Protection of Personal Information (link).

By using our Services, you acknowledge your personal information will be accessed by or transferred to GLOBIS in the jurisdictions where we operate (including, but not limited to, Japan), and accessed by or transferred to our personnel, affiliates, partners, and service providers who are located around the world, in accordance with this Privacy Policy.

Where required by applicable laws, we will take appropriate measures to ensure adequate protection of your personal information when transferred internationally and, if necessary, seek your prior consent. Such measures may include use of data transfer agreements or official transfer mechanisms such as data authority approved contractual clauses.

If you have any inquiries about our handling of your personal information or would like to obtain a copy of the respective data transfer tool, please contact the person in charge of each Service or using the information provided in the “Contact Us” section above.

Provision of Personal Information to Third Parties

GLOBIS may share personal information with trusted third-party service providers, including those providers who perform services on GLOBIS’s behalf in connection with our Services. The services provided by such third parties include services in the following categories: processing payments on our behalf, sending marketing communications on our behalf, authenticating identities on our behalf, helping us to create or maintain our databases, helping us to research or analyze data relating to visitors to our Services and maintaining the security of our Services, backend support services, data analysis and visualization support services, insurance services, and commissioned mailing house services.

GLOBIS shall not provide personal information to any third party apart from trusted third-party service providers under contract, as well as the aforementioned GLOBIS entities, except under the following circumstances:

  • When GLOBIS has received consent from the customer in advance
  • When GLOBIS needs to confirm the authenticity and validity of accounts with financial institutions, etc., for settling payment for services
  • When GLOBIS is required to do so under the law or regulations, or when necessary to protect human life, body, or property
  • When sharing personal information in conjunction with succession of business due to merger, financing, acquisition or dissolution, transition, sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or other reason

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Anonymously Processed Information

GLOBIS may provide personal information it acquired to third parties in the form of anonymously processed information. When creating and handling anonymously processed information, GLOBIS complies with standards set by applicable law, implements measures for safe management of personal information, and performs the necessary and appropriate supervision.

Security Measures

To ensure appropriate handling and protection of personal information, GLOBIS has policies, rules and procedures in place to handle personal information, appoints persons in charge of handling and protecting personal information, and establishes a system for swiftly reporting and communicating within the organization and to its management of information incidents, violations (and signs of violations), as well as to the governmental authorities of the applicable jurisdiction as required.

GLOBIS takes every reasonable action including appropriate physical and technical security control measures to protect personal information from unauthorized access, loss, destruction, change, and leakage.

GLOBIS may provide personal information to business partners or operators to whom GLOBIS entrusts a whole or part of the handling of personal information by contract in which they have agreed to properly handle said information strictly for the purposes mentioned above.

GLOBIS provides necessary training to ensure proper handing and protection of personal information to its staff. GLOBIS exercises necessary and appropriate supervision over its staff, independent contractors, and business partners. Furthermore, we regularly conduct reviews and continually improve our internal system and organizational structure to ensure compliance with laws and regulations related to personal information, take preventive measures and the supervision of staff, independent contractors, and business partners to whom GLOBIS may entrust its operations.

GLOBIS Websites use SSL encrypted communication to ensure secure data transmission for pages in which personal information has been provided for inquiries, applications or member log-in pages. SSL is a transmission protocol for data transmission between a web server and client browsers.

Regarding member log-in pages, users are strongly urged to carefully manage their IDs and passwords. Careless misuse or disclosure of IDs and/or passwords can lead to the leaking of your information.

Please exercise appropriate judgment whenever disclosing your personal information or any other important information when using Services that are open to other users, such as message boards and mailing lists offered by GLOBIS.

Storage of Personal Information

We will store your personal information in a form which permits your identification for no longer than is necessary for the purpose for which such personal information is processed. Please note, however, that we may retain and use your personal information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and/or reasonably feasible to remove it. Consistent with these requirements, and to the extent required or permitted (as the case may be) by applicable law, we will try to delete your personal information quickly upon request.

Children

GLOBIS does not knowingly collect or maintain personal information on our Services from persons under 16 years of age, and no part of our Services are directed to persons under 16. If you are under 16 years of age, then please do not use or access our Services at any time or in any manner. If GLOBIS learns that personal information of persons under 16 years of age has been collected on our Services GLOBIS will take the appropriate steps to delete such information.

Privacy Policy Changes

GLOBIS may, in its sole discretion, change this Privacy Policy from time to time. If we make any changes, we will notify you by posting the revised Privacy Policy on this page and by revising the revision date at the bottom of this Privacy Policy.

Where the changes are material, we may also choose to provide you with additional notice (such as by adding a notice to our Services prior to the changes becoming effective, or by sending you an email notification).

Disclosure, Correction, and Suspension of Use, etc.

GLOBIS makes every effort to maintain the accuracy and currency of personal information we have obtained, and we promptly respond to customer requests to disclose, correct, or suspend the use of information once the identity of the customer has been verified.

Some of the Services provided by GLOBIS permit users to access and update their personal information on a Website specifically set up for this purpose.

In certain circumstances you may have rights under data protection laws in relation to your personal information that we hold about you—specifically:

  • Request access to your personal information. You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
  • Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.
  • Request erasure of your personal information. You may have the right to request that personal information held about you be deleted.
  • Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information.
  • Request transfer of your personal information. You may have the right to request transfer of your personal information directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligations under this Privacy Policy or applicable data protection law, we ask that you contact us first to see if we can resolve the issue. However, you have the right to make a complaint to a supervisory authority, such as the UK Information Commissioner’s Office.

For more information or to exercise your rights, please contact the person in charge of each Service or using the information provided in the “Contact Us” section above.

Administrators

  • Sonoko Igarashi, GLOBIS Group Compliance Committee Administrator GLOBIS Corporation
    Sumitomo Fudosan Kojimachi Bldg., 5-1 Niban-cho, Chiyoda-ku, Tokyo 102-0084
  • Satoshi Hirose, Compliance Committee Administrator
    The Educational Corporation of GLOBIS University
    Sumitomo Fudosan Kojimachi Bldg., 5-1 Niban-cho, Chiyoda-ku, Tokyo 102-0084
  • Yoshito Hori, Managing Partner, GLOBIS Capital Partners & Co.
    Sumitomo Fudosan Kojimachi Bldg., 5-1 Niban-cho, Chiyoda-ku, Tokyo 102-0084
  • Yoshito Hori, President, G1 INSTITUTE
    Sumitomo Fudosan Kojimachi Bldg., 5-1 Niban-cho, Chiyoda-ku, Tokyo 102-0084
  • Yoshito Hori, President, General Incorporated Foundation KIBOW
    Sumitomo Fudosan Kojimachi Bldg., 5-1 Niban-cho, Chiyoda-ku, Tokyo 102-0084
  • Lihua Zhao, President, GLOBIS China Co., Ltd.
    04-162, 4/F, No.328 Tiantong Rd., Hongkou District, Shanghai, 200008, China
  • Tomoko Katsurayama, President & CEO, GLOBIS Asia Campus Pte Ltd.
    12 Marina View #29-02, Asia Square Tower 2, Singapore 018961
  • Tomoko Katsurayama, President & CEO, GLOBIS Asia Pacific Pte. Ltd.
    12 Marina View #29-02, Asia Square Tower 2, Singapore 018961
  • Tomoko Katsurayama, President & CEO, GLOBIS Thailand Co., Ltd.
    M Thai Tower, All Seasons Place 23Fl., 87 Wireless Road, Lumpini, Phatumwan Bangkok 10330 Thailand
  • Tomoya Nakamura, President, GLOBIS USA Inc.
    95 Third Street, 2nd Floor, San Francisco, CA 94103, USA.
  • Toru Takahashi, President & CEO, GLOBIS Europe BV
    Pegasuslaan 5, 1831 Machelen, Belgium

External Links

GLOBIS Websites may contain links to external websites. Clicking on one of these links will transfer the visitor to the websites of our partners, advertisers and others. Be aware that the privacy policies of these other parties may differ from ours, and GLOBIS bears no responsibility for them. Please read the privacy policies of each website which is linked to ours.

Date of last revision: 03/07/2023

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