BeGlobali Privacy Policy

1. Who we are and what this policy covers

DA Global Access Network LLC ("DA Global," "we," "us") operates BeGlobali, a subscription platform licensed to colleges, universities, and other education organizations ("Partner Institutions"). Access is limited to students, faculty, and staff authorized by a Partner Institution ("Authorized Users"). BeGlobali is not open to the general public.

This policy explains how we handle personal information through the BeGlobali web platform, any BeGlobali mobile app, and related support communications (together, the "Platform"). DA Global’s other websites, events, and services have their own privacy notices.

If this policy and a Partner Institution’s agreement with us (including any Data Processing Agreement) differ, the agreement controls for that institution’s users.

2. Our role and your institution’s role

Your Partner Institution decides how the Platform is used and who gets access. We process Authorized User information on the institution’s behalf and follow its instructions, as set out in our agreement.

For education records covered by the Family Educational Rights and Privacy Act (FERPA), we act as a "school official" with a legitimate educational interest, under the institution’s direct control. We use those records only for purposes the institution authorizes and do not re-disclose them except as FERPA and our agreement allow.

Questions about how your institution uses the Platform, or requests about your records, can go to your institution. We will help it respond.

3. Information we collect

We collect only what we need to provide the Platform to Partner Institutions and their users.

Beyond your name and email address, onboarding and profile questions are optional. We use optional information, including identity-related resource selections, to tailor content for you, and your institution may see it in aggregated or de-identified reports. Where your institution enables advisor access, authorized advisors at your institution may also view individual student profiles, including optional information you choose to share, so they can support you.

Courses that touch on sensitive topics, such as mental health or identity, ask you to keep personal reflections outside the Platform. Notes you write during a quest are used to create a PDF summary for you when you finish, and are not stored after the quest is complete.

We do not collect payment card or bank information from students, faculty, or staff. Partner Institutions pay under their agreement with us.

If we collect other information, we will describe it when we collect it and use it only as this policy allows.

4. How we use information

We use personal information to provide the Platform under our agreements with Partner Institutions, including to:

• Create and secure accounts, including sign-in through Google or LinkedIn, and confirm affiliation with a Partner Institution.
• Deliver and personalize Platform content, tools, and features.
• Provide usage and progress reports to your institution, as its agreement describes.
• Send service messages, such as account notices, updates, reminders your institution has enabled, and support replies.
• Maintain, secure, troubleshoot, and improve the Platform.
• Prevent fraud, misuse, and security incidents, and protect the rights and safety of users and others.
• Comply with law, audit compliance with our agreements, and enforce them.

DA Global programs and events. Where your institution permits it, we may also email you about DA Global programs and events, such as the Global Impact Conference and Global EDGE. You can unsubscribe at any time, and doing so never affects your access to the Platform.

What we do not do. We do not sell personal information. We do not use Authorized User information for targeted or interest-based advertising, build advertising profiles, or send marketing on behalf of third parties. We do not use it to train AI models.

We may create aggregated or de-identified data to improve the Platform and for research and benchmarking. We do not attempt to re-identify it, and we do not publish data that identifies an institution without its permission.

5. Partner content in the Platform

The Platform may display content from organizations we work with, such as study abroad program providers and resource sponsors. This content follows four rules:

• It is placed by topic or page (for example, a country guide), not by your profile, identity, or activity.
• Partners do not receive your name, email, or any other personal information, and cannot contact you through the Platform.
• Partners may receive aggregate figures, such as total views of their content, that do not identify any individual.
• Partner Institutions can turn partner content off for their users.

If you follow a link to a partner’s website, that site’s privacy policy applies.

If we ever offer a way for you to hear from partners directly, we will ask for your separate opt-in consent and your institution’s approval first, and update this policy before it launches.

6. How we share information

We do not sell or rent personal information, and we do not share it for cross-context behavioral advertising. We share it only as follows:

• Your Partner Institution, as its agreement describes, including usage and progress reports.
• Service providers (sub-processors) that host, secure, and support the Platform, such as hosting, learning management, email delivery, analytics, and customer support. They are bound by contract to use the information only to serve us and to protect it. Our current list is available on request.
• Affiliates, meaning companies under common control with DA Global, which must handle the information under this policy.
• Sign-in providers. If you sign in with Google or LinkedIn, we exchange the information needed to verify your identity. Their own privacy policies govern how they use it.
• Legal and safety needs, when required by law or legal process, or to protect someone’s safety. Where lawful, we notify the affected institution first.
• Corporate transactions, such as a merger or acquisition. Any successor must honor this policy and existing institutional agreements, and we will notify Partner Institutions.
• Professional advisors, such as lawyers, auditors, bankers, and insurers, under confidentiality obligations.
• With your consent or at your direction, for example if you choose to share a certificate on LinkedIn.

Some information is visible to other users at your institution. Administrators can post announcements and content. Staff and student ambassadors who offer meetings have profiles, including their name, photo, and details they choose to add, that students can see. Those meetings take place outside the Platform, through tools such as Zoom or Google Meet. Users cannot message each other on the Platform. If we add messaging or other ways for users to post content, we will update this policy first.

7. Cookies and similar technologies

We use two kinds of cookies: strictly necessary cookies for sign-in, security, and preferences, and analytics cookies (Google Analytics) to understand how the Platform is used. Analytics is configured with advertising features turned off.

We do not use advertising cookies, advertising pixels, or third-party advertising SDKs, and we do not track users across other websites. Because we do no cross-site tracking, Do Not Track and Global Privacy Control signals do not change how the Platform operates.

You can block cookies in your browser settings, though sign-in may not work without necessary cookies. You can opt out of Google Analytics with Google’s browser add-on at tools.google.com/dlpage/gaoptout.

8. Retention and deletion

We keep Authorized User information for as long as the Partner Institution’s agreement is in effect, and only as long as needed for the purposes in this policy.

When an agreement ends, or when an institution asks, we delete or return its users’ information within 60 days. Backup copies are overwritten within a further 90 days. We keep information longer only where the law requires it.

You can ask your institution or us to delete your account. Where your institution’s agreement requires its approval, we will coordinate with it.

9. Security

We protect personal information with administrative, technical, and physical safeguards, including encryption in transit and at rest, role-based access limited to staff who need it, multi-factor authentication for administrative access, activity logging, and security review of our service providers.

If we confirm a security incident involving a Partner Institution’s data, we will notify that institution without undue delay and within 72 hours, and support any notices it must send. No system is completely secure, so we cannot guarantee absolute security.

10. Your choices and rights

• Access and correction. You can review and update much of your information, including your profile photo and social media handles, in your account settings, or ask us for help.
• FERPA. Students exercise their FERPA rights through their institution. We support institutions in responding.
• US state privacy laws. Where they apply, you may have rights to know, correct, and delete your information. We do not sell personal information or share it for targeted advertising, so no opt-out is needed.
• Emails. You will receive service messages while your account is active. You can unsubscribe from DA Global program and event emails through the link in any such email or by contacting us.
• Sign-in providers. You can disconnect Google or LinkedIn in that service’s settings. This does not delete information we already received.
• Declining to provide information. Questions beyond your name and email address are optional, though some features may not work as well without certain information.

We will not treat you differently for exercising any of these rights. To make a request, email [email protected]. We may need to verify your identity first.

11. International transfers

DA Global is headquartered in the United States and currently serves only US institutions. Platform data is stored in the United States. If we begin serving institutions outside the United States, we will update this policy with the safeguards that apply to international transfers.

12. Minors

The Platform is designed for postsecondary institutions and is not directed at children under 13. If a Partner Institution gives access to users under 18, such as dual-enrollment students, the institution is responsible for obtaining any required consent.

13. Changes to this policy

We will post any update here with a new effective date. Before a material change that affects how Authorized User information is used, we will notify Partner Institutions at least 30 days in advance. We will not expand how we use that information without the institution’s agreement.

14. Contact us

Email: [email protected]