Last Updated: May 2, 2022
1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Specific Personal Data we collect
Website Visitors – individuals who visit our Website https://www.gloww.com (“Website”) and who may volunteer certain contact data (such as their email address) to receive communications from Gloww.
Customers – those who register on their own or on behalf of an entity or organization to use any product(s) or service(s) within Gloww’s Website (the “Platform”), including administrators of a Glowws account (the “Gloww Account”). In order to create an account and to sign in to the account Customers will need to provide information such as email address, name or nickname. In addition, while using our Services, Customers may participate in meetings and webinars (“Meetings”), and if such Meetings are recorded, and we may collect such recordings which could include Personal Data of the participants, including names, images and video.
End Users – individuals who visit our Websites and/or use the Platform without registering as a Gloww Customer (“End Users”).
Candidates and Human Resources – individuals who apply for one of the positions offered on our Website, whether by submitting an online form that we make available or by sending an email. These individuals may provide us with certain information such as full name, email address, CV/cover letter, phone number, and any other information they decide to provide us.
Why is the Personal Data collected and for what purposes? Depending on which features of the Platform you use, we collect different kinds of information (including Personal Data) about or from you. This Personal Data is necessary for the performance of our contractual obligations towards you and providing you with our Services, to protect our legitimate interests, as well as for compliance with regulatory obligations to which we are subject. If this information will not be provided, you may not be able to use our Platform (such as opening an Gloww Account), or certain features of our Platform. In certain instances, we will obtain your consent to the collection of your Personal Data, as appropriate (in which case, you can revoke your consent at any time by approaching us).
Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
2. HOW WE PROTECT AND RETAIN YOUR INFORMATION
- Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- Retention of your Personal Data. We retain your Personal Data as follows: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
3. HOW WE SHARE YOUR PERSONAL DATA
We may share your Personal Data as follows:
- With our business partners with whom we jointly offer products or services. We may also transfer your Personal Data to service providers operating on Gloww’s behalf and other third parties in countries which do not have the same level of data protection laws as those in the country where you are located. Gloww uses several legal mechanisms (where required by an applicable data protection law), to help ensure that your rights and protections are respected by all third parties with whom we share your Personal Data. We use efforts to ensure that each business partner and service provider acting on Gloww behalf will comply with the key data protection principles of fair handling of Personal Data and ensuring adequate level of protection of Personal Data.
- To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
- In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
- Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
4. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
- You can exercise your rights by contacting us at [[email protected]].
- You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you.
- When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request.
- Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
- We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
5. USE BY CHILDREN
We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of sixteen (16). Insofar as Personal Data may be collected based on your consent, the data subject must be above the age of 16 (or above the age of 13 if this is the legal requirement in your country). If these age requirements are not met, you are required to obtain the consent of the parent or guardian to provide and process information in accordance with this Policy; lacking such consent, please do not use the Website In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].
6. INTERACTION WITH THIRD PARTY PRODUCTS
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
7. LOG FILES
We use log files. We use such information to analyze trends, administer the Platform, track users’ movement around the Platform, and gather demographic information.
8. COOKIES AND OTHER TRACKING TECHNOLOGIES
When you browse or visit our Website, our Services may utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
9. ANALYTIC TOOLS
- Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices(including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.
- We reserve the right to remove or add new analytic tools.
10. CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected]