Privacy Policy

Global Smooth System LLC, doing business as Global Smooth and Global Smooth Certification
Effective 1 January 2025 · Last updated 13 October 2026

Introduction

Global Smooth System LLC respects the privacy of individuals and is committed to protecting the information of visitors to our websites and of individuals or entities that register to use our products and services. This Privacy Policy describes the ways we collect, use and share information. It applies whenever you visit globalsmooth.com, globalsmoothcertification.com or our Client Portal, or use our products or services (together, the “Website” and the “Services”).

We take your privacy very seriously and, except where required for our Services, Website or Products to function, we never share your information. If you do not agree with the policies and practices below, your choice is not to use our Website or register to use the Services or Products through our Website.

Definitions and Legal References

This Website

The property that enables the provision of the Service or Product.

Owner

Global Smooth System LLC — the legal entity that provides this Website and/or the Service or Product to Users.

User, Visitor, Customer, or You

The natural person or legal entity that uses this Website.

Service or Product

The service or product provided by this Website as described in our Terms of Use and on this Website.

Personally Identifiable Information

Any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, email address, financial profiles and payment information. Personally Identifiable Information does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected to an identified individual.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns.

Data Controller

For the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Owner and Data Controller

Global Smooth System LLC, San Diego, California, USA.
Privacy contact: [email protected]

This Website collects some Personal Data from its Users. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Services and tells you about your privacy rights and how the law protects you.

What Personally Identifiable Information Is Collected?

We may collect basic user profile information from all of our Users. We collect the following information from Users who create an account or make a purchase: name, email address, phone number, billing address, company name (where given), and the courses, exams or services purchased. Payment card details are collected and processed by our payment provider and are not stored by us.

For the purposes of the GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose for which it has been collected. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

What Organizations Are Collecting the Information?

In addition to our direct collection of information, our third-party service providers — such as our payment processor, our course and customer-relationship platform, our video hosting provider and our email provider — may collect information from Users in the course of providing those services to us. We do not control how these third parties use such information, but we require them to disclose how they use personal information provided to them from Users and to use it only to provide services to us. Some of these third parties may be intermediaries that act solely as links in the distribution chain and do not store, retain, or use the information given to them.

How Does the Website Use Personally Identifiable Information?

We use Personally Identifiable Information to provide the courses and services you purchase, to create and manage your Client Portal account, to process payments and subscription renewals, to send receipts, portal invitations and account notices, to customize the Website, and to make appropriate service offerings. We may email Users about new courses, events, certification opportunities or information related to the subject matter of the Website; you can opt out of marketing email at any time using the unsubscribe link in any such message. We may also use Personally Identifiable Information to contact Users in response to specific inquiries, or to provide requested information.

We may also use your personal information for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

With Whom May the Information Be Shared?

We may share Personally Identifiable Information and/or aggregated information about our Users, including the demographics of our Users, with our affiliated organizations and third-party service providers who help us operate the Website and deliver the Services. We do not sell your personal information. We also offer the opportunity to opt out of receiving marketing information or being contacted by us or by any agency acting on our behalf.

How Is Personally Identifiable Information Stored?

Personally Identifiable Information collected by Global Smooth System LLC is securely stored and is not accessible to third parties or employees of Global Smooth System LLC except for use as indicated above.

What Options Are Available to Users Regarding Collection, Use and Distribution of the Information?

Users may opt out of receiving unsolicited information from or being contacted by us and/or our vendors and affiliated organizations by using the unsubscribe link in our emails, or by emailing us at [email protected].

Are Cookies Used on the Website?

Cookies are used for a variety of reasons. We use cookies to obtain information about the preferences of our Users and the services they select, to keep you signed in to the Client Portal, and for security purposes to protect our Users. Users who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Website, with the drawback that certain features of the Website — including the checkout and the Client Portal — may not function properly without the aid of cookies.

Cookies used by our service providers

Our service providers (for example our payment processor, our course platform and our video hosting provider) use cookies, and those cookies may be stored on your computer when you visit our Website. These are used for payment security, fraud prevention, remembering your sign-in, and video playback, and are governed by those providers’ own privacy policies.

How Does Global Smooth System LLC Use Login Information?

Global Smooth System LLC uses login information, including, but not limited to, IP addresses, ISPs, and browser types, to analyze trends, administer the Website, track a User’s movement and use, and gather broad demographic information.

What Partners or Service Providers Have Access to Personally Identifiable Information?

Global Smooth System LLC has entered into and will continue to enter into partnerships and other affiliations with a number of vendors. Such vendors may have access to certain Personally Identifiable Information on a need-to-know basis for providing the Services. Our Privacy Policy does not cover their collection or use of this information.

Disclosure of Personally Identifiable Information to comply with the law

We will disclose Personally Identifiable Information in order to comply with a court order or subpoena or a request from a law enforcement agency to release information. We will also disclose Personally Identifiable Information when reasonably necessary to protect the safety of our Users.

How Does the Website Keep Personally Identifiable Information Secure?

All of our employees are familiar with our security policy and practices. The Personally Identifiable Information of our Users is only accessible to a limited number of qualified employees who are given a password in order to gain access to the information. We audit our security systems and processes on a regular basis. Sensitive information, such as payment card numbers, is handled by our payment processor and protected by encryption protocols in place to protect information sent over the Internet. While we take commercially reasonable measures to maintain a secure site, electronic communications and databases are subject to errors, tampering, and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to Users for any such occurrences.

GDPR Privacy — Your Rights Under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to:

• Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
• Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
• Request the transfer of your Personal Data. We will provide to you, or to a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising your GDPR data protection rights

You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

CCPA Privacy — Information We Collect

The Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the Website has collected the following categories of personal information from its consumers within the last 12 months:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, address, telephone number, education, employment, bank account number, credit card number, debit card number, or any other financial information.	YES
C. Protected classification characteristics under California or federal law	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.	NO
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g, 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include publicly available information from government records; deidentified or aggregated consumer information; or information excluded from the CCPA’s scope, like certain health or medical information and other categories of information protected by different laws.

We obtain the categories of personal information listed above from the following categories of sources: directly from you (for example, from forms you complete or products and services you purchase) and indirectly from you (for example, from observing your actions on our Website).

Use of personal information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfil or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates’ assets in which personal information held by us or our affiliates about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing personal information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties: service providers.

Your rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to request. Under the CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and sharing of personal information. Once we receive and confirm your request, we will disclose to you: the categories of personal information we collected about you; the categories of sources for the personal information we collected about you; our business or commercial purpose for collecting or selling that personal information; the categories of third parties with whom we share that personal information; the specific pieces of personal information we collected about you; and, if we sold your personal information or disclosed your personal information for a business purpose, the categories of personal information sold and disclosed.
• The right to say no to the sale of Personal Data (opt-out). You have the right to direct us not to sell your personal information. We do not sell personal information. To submit an opt-out request please contact us.
• The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to: complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.); engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer rights, including by: denying goods or services to you; charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising your CCPA data protection rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by email at [email protected]. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. Your request to us must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with the required information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Your California privacy rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us at [email protected].

California privacy rights for minor users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account. Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

How Can Users Correct Any Inaccuracies in Personally Identifiable Information?

Users may update their Personally Identifiable Information in their Client Portal profile, or contact us to correct any inaccuracies by emailing [email protected].

Can a User Delete or Deactivate Personally Identifiable Information Collected by the Website?

We provide Users with a mechanism to delete/deactivate Personally Identifiable Information from the Website’s database by contacting us. However, because of backups and records of deletions, it may be impossible to delete a User’s entry without retaining some residual information. An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.

User Rights

These are summarized rights that you have under data protection law: the right to access; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority; and the right to withdraw consent.

What Happens if the Privacy Policy Changes?

We will let our Users know about changes to our Privacy Policy by posting such changes on the Website. However, if we are changing our Privacy Policy in a manner that might cause disclosure of Personally Identifiable Information that a User has previously requested not be disclosed, we will contact such User to allow such User to prevent such disclosure.

Links to Other Websites

Our Website contains links to other websites. Please note that when you click on one of these links, you are moving to another website. We encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours.