Privacy Policy

This Privacy Policy (“Policy”) explains how Globain, LLC, ("Globain,” "we,” “us,” “our”) collects, uses, and discloses information from and about you, and your choices regarding such information. This policy only applies to Eddifi.com (the “Website”).

By using or otherwise accessing the Website, you acknowledge the applicability of this Policy. Please read this Policy carefully to understand our practices regarding your information. You can contact us by clicking here if you have questions about these practices.

Information we collect

Depending on how you interact with the Website, we may collect information directly from you, automatically, and/or from other sources.

a. Information you provide to us

We collect information directly from you when you use the Website, such as when you respond to questions in our screening tools, you enter your email to have report of your results emailed to you, or you submit a contact request. The following describes common types of information you may provide to us.

Information about your conditions, issues, challenges, interests, or experiences. This information is anonymous and not personally identifiable.
Location information, which may include your ZIP code or general location, inferred from your IP address. This information is anonymous and not personally identifiable.
Demographic information, such as your gender, age range, highest education level, income range, relationship status and race. This information is anonymous and not personally identifiable.
Contact information, such as name, email address, phone number, and physical address.
Any other information you provide to us.

You are not required to provide us with any information about yourself. However, if you do not provide us with certain information, the Website will not function as intended or you will be unable to access certain features. For example:

You will not be able to access localized recommended next steps from organizations we partner with (“Website Partners”) in your geographical area if you do not provide your ZIP code.
You cannot have the Website email you PDF reports of your results if you do not enter an email address.
you cannot submit a contact request if you do not provide us with your name and email address.

Some of the information we collect, such as health-related information, may be considered “sensitive” under some laws. Where relevant, this is discussed in Regional Privacy Notices. Please consult the privacy notice for your region for more information.

b. Information we collect automatically

We collect some information automatically when you use the Website, including, but not limited to:

IP address. Other information about your device such as operating system, browser etc. is used to secure your session but that information is neither transmitted to us nor stored by us.
Usage information about how you interact with the Website, such as the date and time you interacted with the Website, pages viewed, links clicked, the time spent on each page. Note that users are anonymous to the Website and usage information cannot be traced to a specific user. Usage information is primarily used to improve and optimize the performance of the Website.

We and other parties may use cookies and similar technologies to collect and store some of this information. For more information about the use of cookies and similar technologies on the Website, see information in the section “Cookies, analytics, and advertising” below.

How we use your information

We use the information we collect for a variety of purposes, which may vary depending on the type of information and how you interact with the Website. These purposes may include to:

Determine the results of your screening and provide you with generic recommended next steps.
Personalize your results by providing comparative analysis of your results.
Personalize your results by providing localized recommended next steps.
Personalize your experience by remembering your language preference, if applicable.
Conduct analysis and research related to how the Website is used and how it performs.
Provide our partners access to anonymous responses for analysis, research, and policy evaluation purposes.
Improve and enhance the Website, including by developing new features.
Develop new products and services, including by introducing new screening tools.
Communicate with you about your contact requests.
Secure access to your in-progress screening.
Maintain security and prevent fraud.
Comply with applicable laws, regulations, and other legal processes and procedures.
Exercise our legal rights (including by enforcing our terms and policies), detect and prevent illegal activity on the Website, or protect the rights, property, or safety of Globain, our users, our employees, or others.

We do not combine the information we collect through the Website with information we collect automatically. We do not manipulate or process any of the information we collect to link it to you or your device. Beyond the purposes listed above, we do not disclose or sell any of the information we collect to any third party.

Cookies, user experience monitoring, and advertising

a. Cookies

We and other parties may use cookies to collect your data. A cookie is a small text file that web servers place on your device, designed to store basic information and to help websites and apps recognize your browser. Cookies serve a variety of purposes, such as helping you navigate and interact with the Website, making your experience of the Website more relevant and personalized, helping us analyze use of the Website, and saving your preferences. The cookies on the Website may be set by us (first-party cookies) or by third parties (third-party cookies). We may use session cookies (which are deleted when you close your browser) and persistent cookies (which stay on your browser or device for longer).

You can adjust your cookie preferences by changing the settings on the cookie consent banner which appears when you first access the Website or at any time by clicking the “Cookie preferences” link in the footer of the Website. If you block or disable certain cookies, the Website may not function as intended and you may not have access to certain features or functions. Some cookies are strictly necessary for the Website to function, meaning that you cannot opt out of them.

b. User experience monitoring

We use a third party, New Relic, for user experience monitoring. This information helps us understand how users interact with the Website, giving us valuable insights on how to improve the Website and deliver more value to users. New Relic uses cookies and similar technologies on the Website for analytics and application monitoring purposes. You can adjust your preferences for New Relic’s cookies by changing the settings on the cookie consent banner.

c. Advertising

The Website does not allow third party cookies and third-party advertising technologies that use cookies and similar technologies to deliver relevant and targeted advertisements and other content to you on the Website and on other websites you visit and applications you use. Advertising on the Website is limited to the logo of organizations (“Tool Sponsors”) that are sponsoring specific screening tools along with a brief description of the applicable products and services of these organizations.

How We Disclose Your Information

As a rule, we do not disclose information we collect from and about you except for the following:

Personnel. Our employees, contractors, and other personnel have access to personally identifiable information that you provided for the purpose of corresponding with you. Information that personally identifies you is required when you submit a contact request.
Website Partners. Website Partners have access to anonymous responses in the screening tools for which they provide localized recommended next steps. Access to this data is primarily intended for analysis and research purposes.
Tool Sponsors. We disclose the following data elements to Tool Sponsors to support their efforts to continue to sponsor tools published on the Website: number of times their logo appeared on a page segmented by type of screening tool, the number of times users clicked their logo.
Business transfers. In the event of a sale of some or all our assets, merger, reorganization, dissolution or similar event, including during negotiations of such an event, your data may be part of the transferred assets.
Legal compliance. We may disclose your information if required to do so by law or legal process, or in the good faith belief that disclosure is reasonably necessary to (1) comply with a legal obligation, (2) protect and defend the rights, property, or personal safety of ourselves, our personnel, users of the Website or the public, (3) obtain legal advice, or (4) protect against legal liability. This includes disclosures for fraud prevention.
With your consent. If you consent for us to disclose your information, we may do so consistent with your consent. You have the right to revoke consent at any time by clicking here and explaining the information and disclosure(s) for which you want to revoke consent.

Rights and choices

a. Rights regarding your information

Depending on your jurisdiction, you may have the right to make certain requests of us regarding your “personal information” or “personal data,” as defined in applicable law. This includes, but is not limited to, the right to request that we:

Provide you with access to and/or a copy of certain personal information we hold about you.
Inform you about the categories of personal information we collect or disclose about you, the categories of sources of this personal information, the business or commercial purpose for collecting this personal information, and the categories of parties to which we disclose this personal information.
Correct inaccurate personal information we hold about you.
Delete certain personal information we hold about you.

You may have different or additional rights depending on your jurisdiction of residence. For example, you may have the right to object to, restrict, or opt out of our processing of certain information. Please see Regional Privacy Notices, below, for more information about region-specific rights.

You may exercise the rights provided to you by applicable law by clicking here.

Please note that certain information may be exempt from your requests under applicable law. For example, we need to retain certain information to make the Website available to you, and we would be unable to continue providing the Website’s services requested by you if we deleted that information. We may also need to retain certain information to comply with applicable law or exercise our legal rights.

We may need to take reasonable steps to verify your identity before responding to certain requests, which may include, at a minimum, depending on the type of request and the sensitivity of the information involved, verifying your [name and email address]. If provided in applicable law, you may designate an authorized agent to make requests on your behalf. To do so, you or the agent must provide us with written authorization or power of attorney, signed by you, for the agent to act on your behalf. You still need to verify your identity directly with us.

If we ask for and rely on consent to process information, you have the right to revoke this consent at any time by clicking here and explaining the information for which you want to revoke consent. Please be advised that revocation of consent will not affect the validity of consent prior to revocation.

Depending on your jurisdiction, you may also have the right to contact the applicable data protection authority with complaints regarding our practices. Please consult the website of your jurisdiction’s data protection authority for more information. However, we encourage you to contact us first to resolve any questions or complaints.

b. Right to opt out of “sales” and “sharing”

If you are a resident of California and certain other jurisdictions, you may have the right to opt out of a “sale” or “sharing” of your information, which may be characterized by some laws as “targeted advertising.” As mentioned in the “How we disclose your information” section above, we do not provide your information to parties such as advertising providers and partners to, for example, provide you with more relevant ads offers that may be of interest to you. Under certain laws, these disclosures may be considered a “sale,” “sharing,” or “targeted advertising.”

As discussed in the “Cookies, user experience monitoring, and advertising” section above, we do not provide your information to advertising providers for purposes of targeted advertising, and to show you more relevant and tailored ads. Under applicable law, the disclosure of your personal information to these parties to provide these services may be considered a “sale” of personal information, a “sharing” of personal information, or the processing of personal information for targeted advertising purposes.

Bottom line: we do not sell or share your information for targeted advertising purposes.

c. No marketing and promotional communications

Email. You provide us with your email address when you submit a contact request and enter your email so PDF reports of your screening can be emailed to you. We do not use the email address you provided for marketing and promotional communications on behalf of ourselves and other parties. We do not share your email address with any of our partners.

Text/SMS. You provide us with your mobile phone number when you submit a contact request. We do not use the mobile phone number you provided for marketing and promotional communications on behalf of ourselves and other parties. We do not share your mobile phone number with any of our partners.

Direct Mail. You may provide us with your physical address when you submit a contact request. We do not use the physical address you provided for marketing and promotional communications on behalf of ourselves and other parties. We do not share your physical address with any of our partners.

Bottom line: you should not receive any communication from us unless you have requested such a communication from us.

d. Retention

We retain your information for as long as is necessary for the purposes for which it is collected and processed. These periods vary depending on the nature of the information, your interactions with us, and the purposes for collection and processing. When the purposes for which we processed your information have concluded, we will either permanently delete or destroy the relevant information or anonymize it such that it no longer identifies you. Please note that the bulk of the information we collect is anonymous and cannot be traced to you. The only identifiable information we collect are contact requests.

e. Security

We use reasonable efforts to protect your information from unauthorized access, use, or disclosure, but we cannot guarantee the absolute security of your information because no method of transmission over the Internet or electronic storage is fully secure.

f. Miscellaneous

International users. We are located and process your information in the United States and elsewhere. We and our vendors may process your information in the United States and other locations, where privacy protections may not be the same or as strict as the protections in your country of residence. By using or otherwise engaging with the Website, you acknowledge and consent to us transferring and processing your information in the United States and anywhere else that we and our personnel, affiliates, or vendors are located.

Third-party links. The Website may contain links to third-party websites, apps, or other services. This Policy does not apply to the privacy practices of other parties or their websites, apps, or other services. Before engaging with another party, please review their privacy policy.

Children’s privacy. The Website is not intended for use by children. We do not knowingly collect “personal information” (as defined in the U.S. Children’s Online Privacy Protection Act) from children under the age of 13. If we learn that someone under 13 has provided us with their personal information, we will use reasonable efforts to remove that information from our databases as required by applicable law.

Changes to this Policy. We may update this Policy from time to time. When we do so, we will post the updated Policy here with a new “Last updated” date. By continuing to use or otherwise interact with the Website after an update to this Policy is posted, you agree that we may process your information in accordance with the updated Policy.

Regional privacy notices

This section contains information for users from specific regions as required by the applicable laws of those regions.

California privacy notice

This California Privacy Notice applies solely to residents of California and supplements the Policy. Under the California Consumer Privacy Act (as amended, the “CCPA”), we are required to provide you with the following information about our practices regarding “personal information,” as defined in the CCPA (“PI”).

Categories of PI we collect. In the past 12 months, we have collected the following categories of PI from and about California consumers:

Identifiers, such as name, email address, physical address, telephone number, IP address.
Anonymous geolocation data, such as your general location inferred from an IP address.
Anonymous legally protected classification information, such as gender and marital status.
Anonymous sensitive personal information, such as information concerning your health, sex life, or sexual orientation.

Categories of sources from which we collect PI. We collect the categories of PI listed above directly from you and automatically from your activities on the Website.
Purposes for collection and disclosure. In the past 12 months, we or our vendors have collected the categories of PI listed above for the business or commercial purposes (as defined in the CCPA) listed above in the section, “How we use your information.” Our purposes for using PI may vary based on the circumstances and the nature of the PI.
Categories of parties to which we disclose PI. In the past 12 months, we or our vendors have disclosed the categories of PI listed above for a business or commercial purpose to the categories of parties listed above in the “How we disclose your information” section. To whom we disclose PI varies based on the nature of the PI and the purposes for which we use it.
Categories of PI we have “sold” or “shared”. In the past 12 months, we have not “sold” and/or “shared” (as such terms are defined in the CCPA) IP addresses (an “identifier”) and internet, electronic network, and device activity and device information and related identifiers (such as information collected via advertising cookies). As mentioned in the “Rights and choices” section, we do not sell or share your information for targeted advertising purposes.
Retention. See the “Rights and choices” section above for our retention practices.
Your California rights. California consumers have the rights listed in the “Rights and choices” section of this Policy, in addition to the right to:

Ask that we provide you with the categories of personal information we have “sold” or “shared,” the categories of parties to whom we “sold” or with whom we “shared” such personal information, and the business or commercial purpose for such “sales” or “sharing.”
Opt out of “sales” and “sharing” of PI as described in the “Rights and choices” section of this Policy, if any.
Receive information about the financial incentives that we offer to you, if any.
Not be discriminated against (as provided for in the CCPA) for exercising certain of your rights.

To exercise your rights, please click here.

The CCPA also allows you to limit the use or disclosure of your “sensitive” PI (as defined in the CCPA) if your sensitive PI is used for certain purposes. Please note that we do not use or disclose sensitive PI other than for purposes for which you cannot opt out under the CCPA.

EEA/UK privacy notice

This EEA/UK Privacy Notice applies solely to residents of the EEA and UK and supplements the Policy.

Our status and contact information. For purposes of EEA and UK law, we are the “controller” of the “personal data” we collect under this Policy, as such terms are defined in EEA and UK law.
Legal bases for processing personal data. We rely on the following legal bases to “process” the personal data described in Section 1 of the Policy (where “process” and its cognates refer to collection, use, disclosure, and other operations performed on personal data):

Contractual obligations. We may process personal data to honor our contractual obligations to you.
Legitimate interests. In some cases, we process personal data on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Website, preventing fraud, and managing legal issues.
Legal compliance. We need to use, share, and disclose information in certain ways to comply with our legal obligations. This includes processing personal data subject to tax, financial, or other governmental regulations.
With your consent. Where required by law and in some other cases, we process personal data based on your consent. You may withdraw your consent at any time by clicking here and explaining the personal data and processing activities for which you want to revoke consent.

Your rights. EEA and UK residents have the rights listed in the “Rights and choices” section of this Policy. In addition, as provided in applicable law, you may have the right to request that we:

Provide you with a copy of the personal data that you have provided to us in a commonly used, machine-readable format, and/or transmit such personal data directly from us to another controller, where technically feasible.
Restrict our processing of personal data (i) if the processing is unlawful, (ii) if we no longer need to process the personal data, (iii) while we verify the accuracy of personal data when you have contested its accuracy, or (iv) when you object to processing based on legitimate interests.

To exercise any of your rights, please click here.

As with requests to exercise other rights, please note that certain personal data may be exempt from these requests. We may need to take reasonable steps to verify your identity before responding to certain requests, as described in the “Rights and choices” section of this policy.

If you believe our processing of your personal data infringes EEA or UK privacy laws, you also have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work or place of the alleged infringement. However, we encourage you to contact us first to resolve any questions or complaints.

Our use of cookies. EEA and UK law requires us to provide you with more detailed information about the types of cookies we use on the Website.

Strictly Necessary cookies. These cookies enable you to use our Website. These cookies are essential to enable you to browse our Website and use certain features. Disabling them may prevent you from using certain parts of the Website. Without these cookies, services such as maintaining your in-progress screening cannot be provided. These cookies also help keep our Website safe and secure.
Functionality cookies. These cookies store information such as your language selection. Without these cookies, our Website may not be able to remember certain choices you've previously made (such as a saved language preference). These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
Performance cookies. Performance cookies are cookies used specifically for gathering data on how visitors use our Website, which pages of our Website are visited most often, or if they get error messages on web pages. These cookies monitor only the performance of the Website as the user interacts with it. These cookies don’t collect identifiable information on visitors, which means all the data collected is anonymous and only used to improve the functionality of our Website.

Last updated: December 21, 2025