Glympse’s Privacy Policy

Last Revised: May 19, 2020

This privacy policy (“Policy”) applies to the Website located at www.Glympse.com (the “Site”) owned and operated by Glympse Inc. (“Glympse” “we” or “us”) and the Glympse service accessed through our mobile application (the “service” or “app”).  The Glympse Site and app are owned and operated by Glympse Inc., located at 113 Cherry Street, Suite 60215, Seattle, WA 98104-2205, United States.

The Policy is designed to tell you how we collect and use personal information (as defined below) so you can make an informed decision about using our Site and the Glympse service. Please read this statement before submitting any personal information to us. By using our Site and service, you represent that you:

• are 16 years old or older,
• you are using our app for lawful purposes,
• and you consent to the information collection, use and retention practices described in this Policy.

EU-U.S. and Swiss-U.S. Privacy Shield

Glympse complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Glympse has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Glympse commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Glympse at:

privacy@glympse.com

Glympse, Inc.
Attn: Legal Department
113 Cherry Street
Suite 60215
Seattle, WA 98104-2205
USA

Glympse commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner, and comply with the advice given by the panel and Commissioner with regard to data transferred from the EU and Switzerland.

Glympse is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, there is the possibility for an individual to invoke binding arbitration.

The EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework allows the transfer of personal information to a third party, who acts as a service provider or a vendor, if certain steps are taken to assure privacy and security protections. Under these circumstances, we will take all reasonable steps to require any third-party recipient to protect your personal information relevant to the Privacy Shield Framework. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, Glympse is potentially liable.

EU Residents’ Rights Under the General Data Protection Regulation

The General Data Protection Regulation (GDPR) provides data subjects (you, if you use the Glympse service) who reside in the European Union with certain rights. These rights are:

1) The right to be informed. You have the right to know the purposes for processing your personal data, how long your data will be kept and who your data will be shared with.

2) The right of access. You have the right to access your personal data.

3) The right to rectification. You have the right to have inaccurate personal data rectified or completed if it is incomplete.

4) The right to erasure. You have the right to have your personal data erased in certain circumstances, also known as “the right to be forgotten.”

5) The right to restrict processing. You have the right to request the restriction of processing of your personal data in certain circumstances.

6) The right to data portability. You have the right to receive personal data that you have provided to one controller and have it transmitted to another controller.

7) The right to object. You have the right to object to the processing of your personal data in certain circumstances.

8) Rights related to automated individual decision making and profiling.  Glympse does not engage in automated individual decision making or profiling.

You can exercise the above rights by emailing  privacy@glympse.com.

What is personal information?

As used herein, the term “personal information” means information that identifies an individual, or from which an individual could be identified (such as a name, address, telephone number, mobile number, email address, credit card number or other account number), and information about that individual’s location or activities, such as information about his or her use of the Glympse service. Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies you. Personal information does not include “aggregate” information, which is data we collect about the use of the Site or service or categories of Site and service users, from which any personal information has been removed. For example, information that forty-seven percent of the Site’s registered users identify themselves as male, is aggregate information. We collect aggregate data for a number of purposes, including to help us understand trends and user needs so that we can better consider new publications, products and services, and tailor existing publications, products and services to user desires. This Policy in no way limits or restricts our collection of aggregate information.

What personal information do we collect?

Personal information may be collected in a number of ways when you use the various services and activities available through the Glympse Site and service. At several places on our Site or within our mobile application, we may collect certain information you voluntarily provide to us which may contain personal information, such as your recipient’s contact information, e.g. first name, last name, email address and/or phone number. When you use our app, you have the option to provide us with a username and profile picture, which will be sent along with any “Glympse” you send. If you register for the mobile application or service, send us an email, or submit content, we may collect your name, photo, and demographic information that you provide. In addition, from time to time we may collect contact or other personal or demographic information you provide in connection with your participation in surveys or promotional offers.

We will never post to any social network or contact anyone on your behalf without your permission. We may provide the option of connecting to the Glympse service through Facebook, Twitter, Google+ or other social networks as a faster, easier way for you to create a profile on the Glympse service.

When turned on and with an active Glympse, the Glympse app will automatically collect location information from your mobile device and/or your mobile carrier. When you use the service, via your mobile device, some information is also automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring website, and your activity on the application and through the service.

We treat the information collected in conjunction with the app as personal information if we combine it with or link it to any of the identifying information mentioned above. Unless you direct us to act otherwise, your personal location information is only stored by Glympse for up to 48 hours after which location information is disassociated from personal information. From this point onwards, it is used in the aggregate only. If you no longer wish to allow us to collect and use your location information, you may discontinue the use of the service.

Tracking Technologies

Glympse and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Behavioral Advertising / Re-Targeting

We may partner with a third party to either display advertising on our Website or within our apps or to manage advertising on other sites or within other apps. Our third-party partner may use technologies such as cookies to gather information about your activities on this site or within our app and on other sites or within other apps in order to provide you advertising based upon your browsing activities and interests.

Log Files

As true of most websites, we gather certain information automatically and store it in log files.  This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  We do not link this automatically collected data to other information we collect about you.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and from where the application was downloaded. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Push Notifications

We may send you push notifications from time-to-time in order to update you about any updates, events or promotions that we may be running. If you do not wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Usage and Disclosure

In general, we use personal information we may collect (such as your name, location or social network information) to facilitate your use of the mobile application and Glympse service, to provide you with information, products and services you request, to administer and assist us with the operation of the Site, our app, and for any other purpose for which the information was provided. For example, we may use the information we collect:

– to respond to your emails, submissions, comments, requests or complaints;

– to ensure that the application is working correctly and that you are being served the most recent version;

– to allow other users of the service that you designate to temporarily view your whereabouts in real-time;

– to request feedback and to enable us to develop, customize and improve the Site and our information and services; and

– for the specific purpose for which the information was provided.

In addition, if you so indicate in the event of sharing your contact information with us, we may use the information we collect to send you news and product and service updates, including contacting you about our services, products, activities, special events or offers and for other marketing, informational, product development and promotional purposes, including notifications about new features and or improvements to the Site or our products and services.

We may also receive information from third parties with whom we have business relationships, and may combine this information with the other personal information we have about you. In such cases, this Policy governs our use and disclosure of such information.

What personal information do we share with third parties?

We do not sell, share, or rent any personal information to third parties in any ways different from what is disclosed in this Policy. However, we may provide other non-personal information and aggregate information to third parties without your authorization. With regard to SMS functionality, when Glympse sends location information from your mobile device to those recipients chosen by you, your phone number will be provided to them along with such identifying information as you choose, such as your username and/or photo. We may share your contact information with third parties, but only if you have indicated to us that you wish to receive information from such parties. In the event that we engage or partner with third party vendors, consultants or other service providers in connection with the operation of the Site and our services (“Service Providers”), we may share personal information with such Service Providers who need access to such information to carry out their work for us. Service Providers include network operations and service monitoring (NOC) providers, server hosting companies, customer support service providers, and analytics services.  In addition, we may offer various features through a third party service provider. When you use these services, you would be providing information directly to the provider of these services, and the provision of such information would be subject to such party’s own privacy policy. We are not responsible for any information you provide to these parties directly, and we encourage you to become familiar with their practices before disclosing information directly to such third parties with which you come into contact.

You should only share your location with people you know and trust not to convey your location to others. You should also note that personal information you share with others may be forwarded, and any information you post to public areas of the Site or in connection with third party sites (including social media sites such as Facebook) may become publicly available. For example, information you display online or post to social media groups (including any interactive or public forums offered within the Site) may be made publicly available and can potentially be viewed by anyone. Your posting to such public areas of the Site constitutes your consent to share such information publicly.

We also may disclose personal information when we are required to comply with the law (e.g. a lawful subpoena, warrant or court order); to enforce or apply this privacy policy or our other policies or agreements; to initiate, render, bill, and collect for amounts owed to us; to protect our or our customers’ rights, property or safety; to protect our customers from fraudulent, abusive, or unlawful use of our Site; or if we believe that an emergency involving the danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of personal information. In addition, information about our customers, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personally identifiable information could be transferred to third parties as one of the business assets of the Company.

Please note: The Site and service may provide links to other sites, or other interactive forums hosted by a third party. Please be aware that although we may participate in or utilize such other sites, we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy policies of any Website that collects personally identifiable information. Similarly, if you entered the Glympse Site through another Web site, we are also not responsible for the privacy practices of that site, and you should review the privacy policy of the originating site before providing any personal information to that site. This privacy policy applies solely to information collected by us.

Where is your information stored?

Glympse Inc. is based in the United States of America, and any information which we collect about you or which you provide to us may therefore be transferred to the United States. Some of our Service Providers may also be located in the United States or in other countries. If you are using the Site and the app in the European Economic Area (EEA), you consent to your personal information being transferred outside the EEA, including to countries where you may have fewer legal rights.  However, we will take steps to ensure that your personal information is treated securely and in accordance with this Policy, wherever it is handled.

What steps do we take to protect your information online?

Glympse endeavors to secure your personal information from unauthorized access, use or disclosure by putting into place measures to safeguard the information we collect. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and that we cannot guarantee that the Site or services will be free of any defects or flaws that affect your use of it or the security of your information.

When you enter sensitive information or we automatically collect sensitive information on our forms, we encrypt the transmission of that information using transport layer security (TLS).

What choices and means do you have for limiting the use and disclosure of your personal information?

When you use the application to send an invitation to a third party to view your location, the invitation remains in your user history as a “sent” request. Such invitation will remain in your user history regardless of whether it is accepted or rejected by the invitee. You may delete your user history, and each sent invitation, at your discretion within the “user history” section of the app.

If you use the features within the app that allow you to designate a particular individual as a “favorite,” the app will associate the designation with the selected individual(s) within the app. It is not necessary to use the “favorites” feature to use the app. You may change your designated “favorites” or otherwise delete a “favorite” within the app at your discretion.

Your personal information is kept strictly confidential and will not be shared or sold to third parties other than (a) as expressly described in this Privacy Policy (see “What personal information do we share with third parties“), (b) to your Glympse invitees or (c) only if you have affirmatively agreed (opt-in) that you wish to receive information from any such third parties. For example, you may choose to use certain features that we offer through a third party service provider. That is “opt-in” sharing or disclosure. You can opt out of the sharing or disclosure by discontinuing the use of the features offered through the third party service provider.

If you provide us with your contact details as part of your use of the Site or the app, we may send you news and product updates relating to Glympse.  You may “opt out” of receiving marketing or promotional email from Glympse by following unsubscribe instructions or using unsubscribe links within communications we send. Please note, however, that as long as you receive the Glympse service, you may not “opt out” of receiving service-related emails from Glympse.

If Glympse intends to use your personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you, Glympse will only do so after notifying you and giving you an opportunity to opt out of the use.  Glympse will provide you with a reasonable, clear and conspicuous, readily available mechanism to exercise your choice.

Glympse limits the use of your personal information to the purposes indicated in this Privacy Policy.

Unless you have requested us to do otherwise, we do not keep your personal Glympse location data for longer than 48 hours after which we disassociate it from your personal information for future aggregate use.

How can you correct and update your personal information or obtain additional information?

Upon request, we will provide you with information about whether we hold any of your personal information. If you have any questions or comments about this Policy or the practices relating to this Site or our service, please contact us at privacy@glympse.com. If you wish to verify, correct or delete any of your personal information that may be collected by Glympse, please email your request to privacy@glympse.com. All requests sent to privacy@glympse.com will be processed within a reasonable timeframe.

Data Retention

Any information supplied by you in connection with a Glympse user account will be retained as long as your account is active or as needed to provide you services.

If you created a user account with Glympse for your mobile device and you wish to delete it, you can click the “delete my account” button within the application.

We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Glympse may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Facebook Connect or other OpenID providers

You can log in to our mobile application using sign-in services such as Facebook Connect or an OpenID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities and locations on this Website to your profile page to share with others within your network.

Social Media Features

Our website and apps may include Social Media Features, such as links to Facebook or Twitter.  These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly.  Social Media Features are hosted by third parties.  Your interactions with these Features are governed by the privacy policy of the company providing it.

California Residents:

Starting January 1, 2020, under the California Consumer Privacy Act (CCPA), California Residents have the right to request the following information from Glympse by emailing Glympse at privacy@Glympse.com and Glympse will provide such information to you upon verification of your request:

• The categories of personal information Glympse collects about you;
• The categories of sources from which your personal information is collected;
• The business purpose for collecting your personal information;
• The categories of third parties with whom Glympse shares your personal information; and
• The specific pieces of personal information Glympse has collected about you.

In addition, you can find the following information in the corresponding Glympse Privacy Policy Sections:

If you elect to exercise any of your rights under CCPA, Glympse will not deny services, provide a different price or rate for our services, or provide a different level of service to you because you exercised such rights. Under the current definition of CCPA, Glympse does not sell your personal information.

Sales of personal information

In the preceding twelve (12) months, Glympse has not sold personal information, including any personal information of minors under 16 years of age. Under the current definition of CCPA, Glympse does not sell any personal information.

Deletion Request Rights

You have the right to request that Glympse delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, Glympse has disclosed certain user data to the following categories of third parties: Service Providers.
Refer to the following section in our Privacy Policy: “What personal information do we share with third parties?”

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
• Emailing us at privacy@glympse.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may use an authorized agent to submit a request to know or a request to delete on your behalf. An authorized agent is a person or business registered with the California Secretary of State that you have authorized to act on your behalf to make a request to know or a request to delete according to the California Consumer Privacy Act.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes in this Privacy Statement

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by posting the revised privacy policy on our Site or, if you have established a Glympse user account, we will send a notification to the email address specified in your account. Any revisions to our privacy policy will become effective after such notification. We encourage you to periodically review this page for the latest information on our privacy practices.