Privacy Policy

Effective: May 25, 2018

Privacy Policy of Glowing, Inc


This Website/Mobile-App.and App collects some Personal Data from its Users.


Owner and Data Controller

Glowing, Inc

279 Valleggia Drive, Unit G

Las Vegas, NV 89138

USA

Owner contact email: happy@glowing.io

Types of Data collected

Among the types of Personal Data that this Organisation collects, by itself, its clients or through third parties, there are: last name, first name, company name, email address, phone number, public profile information on social media platform, message communication data, hotel’s information, Cookies and Usage Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website/Mobile App.

Unless specified otherwise, all Data requested by this Website/Mobile App is mandatory and failure to provide this Data may make it impossible for this Organisation to provide its services. In cases where this Website/Mobile-App.specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Website/Mobile App or by the owners of third-party services used by this Website/Mobile-App.serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website/Mobile-App.and confirm that they have the third party's consent to provide the Data to the Owner.


Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website/Mobile-App.(administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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 fulfill 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 to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Analytics, User database management, Displaying content from external platforms and Heat mapping and session recording.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts

  • This type of service allows this Website/Mobile-App.to access Data from your account on a third-party service and perform actions with it.
  • These services are not activated automatically, but require explicit authorization by the User.

Analytics

  • The services contained in this section enable the Owner to monitor and analyze web and mobile traffic and can be used to keep track of User behavior.

Backup saving and management

  • This type of service allows the Owner to save and manage backups of this Website/Mobile-App.on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Website.

Commercial affiliation

  • This type of service allows this Website/Mobile-App.to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
  • Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Website.
  • For details of which data are collected, please refer to the privacy policy of each service.

Contacting the User

  • Contact form (in Dashboard/Mobile-App)
  • By filling in the contact form with their Data, the User authorizes this Website/Mobile-App.to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
  • Personal Data collected: User Name, Email Address, Phone Number, Size of Business, Business operating stats and numbers

Content commenting

  • Content commenting services allow Users to make and publish their comments on the contents of this Website.
  • Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  • If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Content performance and features testing (A/B testing)

  • The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.

Data transfer outside the EU

  • The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  • Users can inquire with the Owner to learn which legal basis applies to which specific service.

Device permissions for Personal Data access

  • This Website/Mobile-App.requests certain permissions from Users that allow it to access the User's device Data as described below.

Displaying content from external platforms

  • This type of service allows you to view content hosted on external platforms directly from the pages of this Website/Mobile-App.and interact with them.
  • This type of service might still collect Web Traffic/Usage data for the pages where the service is installed, even when Users do not use it.

Handling activity data

  • This type of service allows the Owner to use the activity data collected by your device in order for this Website/Mobile-App.to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
  • Depending on what is described below, third parties may be involved in the activity tracking.
  • Most devices allow for the User to control which Data is accessed or stored.

Heat mapping and session recording

  • Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
  • Some of these services may record sessions and make them available for later visual playback.

Hosting and backend infrastructure

  • This type of service has the purpose of hosting Data and files that enable this Website/Mobile-App.to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Infrastructure monitoring

  • This type of service allows this Website/Mobile-App.to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  • Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.

Interaction with data collection platforms and other third parties

  • This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website/Mobile-App.for the purpose of saving and reusing data.
  • If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Interaction with external social networks and platforms

  • This type of service allows interaction with social networks or other external platforms directly from this Website/Mobile-App.
  • The interaction and information obtained through this Website/Mobile-App.are always subject to the User’s privacy settings for each social network.
  • This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Interaction with live chat platforms

  • This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website/Mobile-App, for contacting and being contacted by this Website/Mobile-App.support service.
  • If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Interaction with online survey platforms

  • This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Website.
  • If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Interaction with support and feedback platforms

  • This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Website.
  • If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.


Managing contacts and sending messages

  • This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  • These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Managing landing and invitation pages

  • This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
  • Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.

Managing support and contact requests

  • This type of service allows this Website/Mobile-App.to manage support and contact requests received via email or by other means, such as the contact form.
  • The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).


Platform services and hosting

  • These services have the purpose of hosting and running key components of this Website/Mobile-App, therefore allowing the provision of this Website/Mobile-App.from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Registration and authentication

  • By registering or authenticating, Users allow this Website/Mobile-App.to identify them and give them access to dedicated services.
  • Depending on what is described below, third parties may provide registration and authentication services. In this case, this Website/Mobile-App.will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Remarketing and behavioral targeting

  • This type of service allows this Website/Mobile-App.and its partners to inform, optimize and serve advertising based on past use of this Website/Mobile-App.by the User.
  • This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  • In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

RSS feed management

  • This type of service allows this Website/Mobile-App.to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.

SPAM protection

  • This type of service analyzes the traffic of this Website/Mobile-App, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Tag Management

  • This type of service helps the Owner to manage the tags or scripts needed on this Website/Mobile-App.in a centralized fashion.
  • This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Traffic optimization and distribution

  • This type of service allows this Website/Mobile-App.to distribute their content using servers located across different countries and to optimize their performance.
  • Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website/Mobile-App.and the User's browser.
  • Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.

User database management

  • This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website/Mobile-App, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
  • Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.

Further information about Personal Data

  • Push notifications
  • This Website/Mobile-App.may send push notifications to the User.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.


Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website/Mobile-App.or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website/Mobile-App.may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website/Mobile-App.and any third-party services may collect files that record interaction with this Website/Mobile-App.(System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website/Mobile-App.does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website/Mobile-App.and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.


Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website/Mobile-App.(or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website/Mobile-App, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Website/Mobile-App.who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website/Mobile-App.(or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website/Mobile-App.as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User's device.

Legal information

  • This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
  • You have the right to complain about the improper processing of your personal data (such as collection, storage, modification, transfer, deletion, etc.) by us with our supervisory authority:

(happy@glowing.io)

  • If you have questions about data protection, please use our contact form or contact our data protection officer directly:

(support@glowing.io)

This privacy policy relates solely to this Website/Mobile-App, if not stated otherwise within this document.