Privacy Policy
Updated: May 14, 2025
Who We Are
Michael Ventures LLC, a California limited‑liability company doing business as “Globali” (“Globali,” “we,” “us,” or “our”), operates a talent‑placement and managed‑services platform that matches client businesses with pre‑vetted international professionals (the “Services”). Our headquarters is in Los Angeles County, California, USA.
Jurisdictional scope. We do not intentionally market, sell, or provide the Services to residents of the European Economic Area, Switzerland, or the United Kingdom. If you are subject to EU/UK data‑protection law, do not use the Services or submit personal information to us.
U.S. state privacy expansion. Whenever a U.S. state enacts a comprehensive consumer‑privacy statute that grants rights substantially similar to the California Privacy Rights Act (CPRA)—for example, the laws of Colorado, Connecticut, Virginia, Utah, Florida, Texas, Indiana, Iowa, Tennessee, Montana, Delaware, New Jersey, New Hampshire, Minnesota, Nebraska, Rhode Island, Kentucky, or Maryland—Globali will extend CPRA‑level rights and response timelines to verified residents of that state.
Controller vs. processor roles
When you interact with our website, marketing materials, or talent‑application portal, Globali acts as a data controller: we decide why and how your data is processed (for example, to respond to inquiries or evaluate talent).
When a business client supplies HR or payroll data for us to handle on the client’s behalf, Globali acts as a processor / service provider and follows the client’s documented instructions without determining the purposes of processing.
Personal Information We Collect
We may collect the following categories of personal information:
Identifiers and business‑contact details such as name, company, e‑mail address, telephone number, postal address, and IP address—collected directly from users so we can respond to inquiries and deliver the Services.
Professional and employment‑related information such as résumés, work history, certifications, salary expectations, and interview notes—collected from talent candidates and references for vetting and matching.
Commercial information such as service orders, invoices, and payment status—collected from clients and payment processors to bill and fulfill contracts.
Sensitive personal information (only when a client orders a background check) such as government‑issued identification numbers or criminal‑records reports—collected via a third‑party consumer‑reporting agency with the individual’s consent for optional pre‑employment screening.
Internet or device data such as log files, cookie identifiers, device IDs, and coarse geolocation—collected automatically when you visit our sites for security, analytics, and fraud‑prevention purposes.
Biometric and sensitive‑health data. Globali does not intentionally collect or process biometric identifiers (e.g., fingerprints, facial geometry, retina scans) or consumer health data as defined by state laws such as Illinois BIPA or the Washington and Nevada consumer‑health‑data statutes. Any such information received inadvertently is deleted upon discovery.
How We Use Personal Information (and Legal Bases)
To provide and maintain the Services, including matching talent with client requests – contract performance (GDPR Art. 6 (1)(b)).
To respond to demo requests and customer‑support inquiries – legitimate interests (Art. 6 (1)(f)).
To send marketing newsletters, event invitations, and other promotional communications – consent (Art. 6 (1)(a)) or legitimate interests, with the option to opt out at any time.
To facilitate optional background checks at a client’s request – consent (Art. 6 (1)(a)).
To prevent fraud, secure our Services, and comply with legal obligations – legal obligation or legitimate interests.
Globali does not sell personal information for monetary consideration. Certain analytics or advertising disclosures may constitute “sharing” under the CPRA; see Section 8 for your opt‑out rights.
Cookies and Tracking Technologies
We use strictly necessary cookies for security and session management. With your consent, we also use analytics and advertising cookies. You may control non‑essential cookies through our banner or your browser settings. We honor Do‑Not‑Track signals where required by law.
Legal Bases for Processing (GDPR and International Users)
Service providers and sub‑processors (e.g., cloud hosting, payment processors, analytics vendors, background‑check agencies) bound by written agreements that limit their use of the data to our instructions.
Hiring clients once a talent candidate has consented to be introduced.
Legal or safety reasons, such as compliance with subpoenas, court orders, or protecting the rights and safety of Globali, our users, or others.
Corporate transactions, such as a merger or acquisition, provided the acquiring entity agrees to privacy protections at least as stringent as those in this Policy.
Additional disclosures:
Data‑broker safe‑harbor. Where state law defines and regulates “data brokers” (e.g., Vermont, Texas), Globali does not sell data for profiling; if deemed a broker, we comply with registration and security obligations.
California “Shine the Light.” Globali does not share personal information with unaffiliated third parties for their own direct‑marketing purposes.
International transfers occur only as incidental, occasional processing of non‑EU/UK data (see Section 11).
Data Retention
Candidate profiles (unsuccessful): kept while reasonably relevant to future openings and deleted upon candidate request or when no longer needed.
Client contract and billing files: kept for the period required by applicable tax and audit laws (currently seven years in the United States).
Marketing and business‑development contact information: kept until you unsubscribe or otherwise request deletion; we impose no fixed time limit while you remain opted‑in.
We make sure to limit the personal information we share to only what is necessary for each purpose and ensure appropriate safeguards are in place. Aside from the scenarios above, DealTrail will not share your personal data with third parties without obtaining your consent, unless we have a lawful basis or obligation to do so.
Security
We use industry‑standard administrative, technical, and physical safeguards, including encryption in transit and at rest, multi‑factor authentication for privileged accounts, role‑based access controls, annual third‑party penetration tests, and employee security training.
Incident‑response commitment. If we confirm a data incident that meets any U.S. state breach‑notification threshold and materially affects personal information, we will notify impacted clients within seventy‑two (72) hours, subject to the liability cap in our Terms and Conditions and any delay requested by law enforcement.
No system is 100 percent secure; Globali disclaims liability for unauthorized access beyond our reasonable control.
Your Privacy Rights
California (CPRA): Right to know, access, correct, delete, and opt out of “sharing” for cross‑context behavioral advertising. Submit requests to [email protected] (subject line “California Privacy Request”) or via our toll‑free number.
Nevada and Utah: Right to direct us not to sell your covered information. E‑mail [email protected] with “Nevada Opt‑Out” or “Utah Opt‑Out.”
Other U.S. states with comparable statutes: Globali extends CPRA‑level rights to residents of the states listed in Section 1; use the same contact methods above.
EEA / UK: Services are not offered in these regions; GDPR rights do not apply.
To opt out of marketing e‑mails, click “unsubscribe” in any message or e‑mail [email protected].
To opt out of cross‑context advertising cookies, use the “Do Not Share / Opt‑Out” link in our banner or e‑mail us.
We will verify your identity before fulfilling any privacy request.
Children
The Services are not directed to anyone under 16, and we do not knowingly collect children’s personal data. If you believe a child has provided data to us, e‑mail [email protected] and we will delete it.
Third‑Party Links
Our websites may include links or integrations to external sites or plugins. Clicking those links may allow third parties to collect data. Globali does not control third‑party privacy practices and disclaims liability for their actions.
Jurisdictional Limitations
Globali is a U.S. company based in California. We do not direct the Services to, or monitor the behavior of, individuals located in the European Economic Area, Switzerland, or the United Kingdom, and we do not maintain an EU/UK representative under GDPR Article 27. Any personal data from those regions that is incidentally received is processed only on an occasional, transitory basis and is promptly deleted. If you nevertheless provide such data, you acknowledge it will be processed in the United States under U.S. law, which may afford a different level of protection than EU/UK law. If you are an EEA, Swiss, or UK resident, do not use the Services
Background‑Check Disclaimer and Waiver
When a hiring client requests a background check, we engage a third‑party consumer‑reporting agency and pass through the cost. If a client elects to forego a background check, the client expressly releases and holds harmless Globali (Michael Ventures LLC) from any liability, claim, or loss arising from the talent’s past employment, qualifications, criminal history, or subsequent misconduct.
Data‑Processing Addendum
Where Globali processes personal information on behalf of a business client, the parties agree to a Data‑Processing Addendum (DPA) that:
designates Globali as a “service provider” / “processor” under applicable law;
incorporates this Privacy Policy by reference;
limits Globali’s aggregate liability to the cap stated in the master Terms and Conditions; and
obligates each party to implement reasonable security measures.
A template DPA is available upon request at [email protected] and is deemed executed upon a client’s first transmission of personal information to Globali unless the parties sign a bespoke DPA.
Changes to This Policy
Globali may amend this Privacy Policy from time to time. Material changes will be announced by e‑mail to account holders and/or via a notice atop this page 30 days before they take effect. Continued use of the Services after the effective date constitutes acceptance.
Contact Us
E‑mail: [email protected]
Mail: Michael Ventures LLC d/b/a Globali – Privacy Office, 915 N La Brea Ave #534, Los Angeles, CA 90038, USA
Attn: Privacy Officer
By using Globali’s Services, you acknowledge that you have read, understood, and agree to the data‑handling practices described above.
© Michael Ventures LLC d/b/a Globali. All rights reserved.