GLOHO

Effective Date: March 2018

Your privacy and trust are important to us. This Privacy Policy ("Policy") explains how Gloho Inc. and its affiliates (we refer to these as "Gloho", "we", "us", or "our") collect, use, and share your personal information in connection with the website, application (including a mobile application), product, software, or service that links to this Privacy Policy (we call these our "Services").

This Privacy Policy, however, does not apply to:

Our customers' "content" that is inputted/uploaded and processed, transmitted, stored, or hosted by our customers using our Services in connection with their account with us, in which this personal information is governed by our customers' respective privacy policies; or
Any website, application, product, software, service, or content that are offered by third parties or that link to their own privacy statement, privacy policy, or privacy notice.

Who we are & how to contact us

Gloho Inc. is a Delaware corporation with an office in Miami, FL, United States. Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed through our contact us page.

Information we collect

The type of personal information we collect depends on how you are specifically interacting with us and which Services you are using. Generally, we collect the following categories of personal information:

Contact Information , such as name, alias, address, phone number, social media user ID, email address, and similar contact data.
Organization and Contacts Information , such as your employer or organizations that you are a member of, information about your colleagues or those within your organization, your status with an organization, and similar data.
Account Information , such as security-related information (including user names and passwords, authentication methods, and roles), service-related information (including purchase history and account profiles), billing-related information (including payment, shipping, and billing information), and similar data.
User Content , such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our Services (including information in alerts, folders, notes, and shares of content), and similar data.
Device & Browser Information , such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
Usage Information and Browsing History , such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, API calls, and other logs), content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), and download errors), advertising interactions (including when and how you interact with marketing and advertising materials, click rates, purchases or next steps you may make after seeing an advertisement, and marketing preferences), and similar data.
Location Data , such as the location of your device, your household, and similar location data.
Demographic Information , such as country, preferred language, age and date of birth, marriage status, gender, physical characteristics, personal or household/familial financial status and metrics, military status, and similar data.
Your Image , such as still pictures, video, voice, and other similar data.
Identity Information , such as government-issued identification information, tax identifiers, other government-issued identifiers, and similar data.
Financial Information , such as billing address, credit card information, billing contact details, and similar data.
Social Media and Online Content , such as information in social media and online profiles, online posts, and similar data.
Career, Education, and Employment Related Information ,such as job preferences or interests, work performance and history, salary history, status as a veteran, nationality and immigration status, demographic data, disability-related information, application information, professional licensure information and related compliance activities, accreditations and other accolades, education history (including schools attended, academic degrees or areas of study, academic performance, and rankings), and similar data.

Sources of information

We collect personal information about you either directly from you, from certain third parties (such as your employer or the subscriber providing access to our Services), or from other sources (such as publicly available sources) as follows:

You provide personal information to us when you:

Search for, subscribe to, or purchase our Services.
Use our Services or otherwise interact with us.
Create or maintain a profile or account with us.
Purchase, use, or otherwise interact with content, products, or services from third party providers who have a relationship with us.
Create, post, or submit user content on our Services.
Register for or attend one of our events or locations.
Request or sign up for information.
Communicate with us by phone, email, chat, in person, or otherwise.
Complete a questionnaire, survey, support ticket, or other information request form.
When you express an interest in working with us or apply for a job or position with us.

We collect personal information automatically when you:

Search for, visit, interact with, or use our Services (including through a device).
Access, use, or download content from us.
Open emails or click on links in emails or advertisements from us.
Otherwise interact or communicate with us (such as when you attend one of our events or locations, when you request support or send us information, or when you mention or post to our social media accounts).

We also collect personal information about you from third parties, such as:

Your organization and others with whom you have a relationship that provide or publish personal information related to you, such as from our customers when they arrange access to our Services for you or from others when they create, post, or submit user content on our Services that may include your personal information.
Professional or industry organizations and certification / licensure agencies that provide or publish personal information related to you.
Third parties and affiliates who resell or integrate with our Services.
Service providers and business partners who work with us in relation to our Services and that we may utilize to deliver certain content, products, or services or to enhance your experience.
Marketing, sales generation, and recruiting business partners.
Credit bureaus and other similar agencies.
Government agencies and others who release or publish public records.
Other publicly or generally available sources, such as social media sites, public and online websites, open databases, and data in the public domain.

How we use information

This section includes details of the purposes for which we use personal information and the different legal reasons for processing that personal information.

Lawful Basis

First, some laws require us to explain the lawful basis upon which we process your personal information. With respect to these laws, we process personal information about you for one or more of the following basis:

To Perform a Contract. Where the processing is necessary for the performance of contract.
Legitimate Interests. Where the processing is necessary for legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information.
Your Consent. Where you have given us consent to process your personal information for specified purposes, such as to provide our Service and other items requested by you.
Comply with the Law. Where the processing is necessary for compliance with a legal obligation.

Processing of Personal Information

We process your personal information in connection with our Services and for other business purposes, including to:

Provide, deliver, analyze, and administer our Services (including in connection with the performance of a contract).
For internal research and development purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our current Services.
Process transactions related to our Services and administer accounts or profiles related to you or your organization (including registrations, subscriptions, purchases, billing events, royalty calculations, and payments).
Personalize and make recommendations related to our Services and other offerings.
Contact and communicate with you in connection with our Services or other notifications, programs, events, or updates that you may have registered for.
Send you offers, advertising, and marketing materials, including to provide personalized advertising to you.
Conduct and communicate with you regarding recruiting and human resources administration.
Comply with your instructions or to fulfill other, specified purposes for which you have given your consent.
Detect and prevent fraud and abuse to ensure the security and protection of all customers and others, as well as to identify and authenticate your access to our Service or to identify and authenticate you before we provide you with certain information.
Exercise our rights and to protect our and others' rights and/or property, including to take action against those that seek to violate or abuse our Services.
Comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or authority, as well as to fulfill our contractual obligations with our customers when they arrange access to our Services for you.
Effectuate the sale, merger, acquisition, or other disposition of our business (including in connection with any bankruptcy or similar proceedings).

How we share information

We share personal information for the purposes set out in this Privacy Policy and with the following categories of recipients:

Gloho, Inc . We may share your personal information with its affiliates.
Your Organization and Contacts. We may share your personal information with your organization and others with whom you have a relationship in order to fulfill or perform a contract or other legal obligation, including with our customer that arranges access to our Services for you and pays us in connection with your access. We may also share your personal information with your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s).
Business Partners. We may share your personal information with our business partners to jointly offer, provide, deliver, analyze, administer, improve, and personalize products or services (including these Services) or to host events. We may also pass certain requests from you or your organization to these business providers.
Third Party Content Providers. We may share your personal information with our third party content providers to perform tasks on our behalf and to assist us in providing, delivering, analyzing, administering, improving, and personalizing content that are delivered as part of our Services. We may also pass certain requests from you or your organization to these content providers.
Social Media Services. We may work with certain third party social media providers to offer you their social networking services through our Services. These social networking services may be able to collect information about you, including your activity on our Services. These third party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies.
Third Party Service Providers. We may share your personal information with our third party service providers to perform tasks on our behalf and to assist us in offering, providing, delivering, analyzing, administering, improving, and personalizing our Services. For example, service providers who assist us in performing, delivering, or enhancing certain products and services related to our delivery and operation of our Services, who provide technical and/or customer support on our behalf, who provide application or software development and quality assurance, who provide tracking and reporting functions, research on user demographics, interests, and behavior, and other products or services. These third party service providers may also collect personal information about or from you in performing their services and/or functions on our Services. We may also pass certain requests from you or your organization to these third party service providers.
Advertisers. We may share your personal information with advertisers, advertising exchanges, and marketing agencies that we engage for advertising services, to deliver advertising on some of our Services, and to assist us in advertising our brand and products and services. Those advertising services may also target advertisements on third party websites based on cookies or other information indicating previous interaction with us and/or our Services.
Users. For some of our Services, we aggregate information from public records, phone books, social networks, marketing surveys, business websites, and other sources made available to us to create listings and profiles that become a part of our content in these Services. These listings and profiles may be made available to all users of these Services. As described above, we may also share your personal information with other users who are your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s). Additionally, if you choose to include your personal information in any reviews, comments, or other posts that you create, then that personal information may be displayed other users as part of your posting.
In the Event of Merger, Sale, or Change of Control. We may transfer this Privacy Policy and your personal information to a third party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control (such as the result of a bankruptcy proceeding).
Other Disclosures. We may disclose your personal information to third parties if we reasonably believe that disclosure of such information is helpful or reasonably necessary to comply with any applicable law or regulation, to comply with or respond to a legal process or law enforcement or governmental request, to enforce our terms and conditions or other rights (including investigations of potential violations of our rights), to detect, prevent, or address fraud or security issues, or to protect against harm to the rights, property, or safety of Gloho our users, or the public.

Location of information

Gloho Inc. is located in the United States and its affiliated entities are located throughout the world. During your use of our Services and your interactions with us, your personal information may be transferred outside of the United States and may be stored in and accessed from multiple countries.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection laws.

Security of information

The security of your personal information is important to us. Taking into account the nature, scope, context, and purposes of processing personal information, as well as the risks to individuals of varying likelihood and severity, we have implemented technical and organizational measures designed to protect the security of personal information.

However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable measures designed to protect personal information, we cannot guarantee its absolute security.

Our security procedures also means that we may request proof of identity before we disclose personal information to you or before we process your other requests.

Retention of information

We retain personal information in accordance with our enterprise records retention schedule, which varies by Service, business function, record classes, and record types.

We calculate retention periods based upon and reserve the right to retain personal information for the periods that the personal information is needed to: (a) fulfill the purposes described in this Privacy Policy, (b) meet the timelines determined or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.

Children's privacy

Our Services generally provide information solutions and, as such, our Services are intended for professionals and/or individuals over eighteen (18) years of age. We do not target children and do not knowingly collect any personal information from children under the age of thirteen (13). When a user discloses personal information on our Services, that user is representing to us that he or she is at least eighteen (18) years of age.

Online advertising and cookies

We deliver advertising and marketing across various platforms, such as on our Services or via email, telephone, text messaging, direct mail, and various online channels. Our Services and marketing materials may also include third party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services.

We also collect certain information (automatically) through the use of "cookies" and similar tracking technologies. Cookies are small data files that are stored on a user's computer or device at the request of a website to enable the website to recognize previous visitors and retain information such as user preferences and history. If you wish to block, erase, or be warned of cookies, please refer to your browser instructions or "help screen" to learn about these functions. However, if your browser is set to not accept cookies or if you reject a cookie, you will not be able to sign in to your Gloho account or use certain parts of the Services.

We may also use third parties to display and target ads, provide certain functionality (such as maps), or to place their own cookies and other tracking technologies to collect, track and analyze usage and statistical information from users. We are not responsible for the information collection practices of any third parties.

Managing your preferences

1. Managing online advertising preferences

We respect all browser instructions for setting or rejecting cookies on generally available browsers. This is one way to manage your preferences regarding the collection of information by Gloho. Additionally, and because data acquired across the internet is often associated with information about you acquired in other places online, you can manage online advertising preferences via these links:

Google Ad Preferences Manager

Google Analytics Opt-out Browser Add-on

Facebook Ad Preferences Manager

Network Advertising Initiative

Digital Advertising Alliance

While Gloho will follow any such preferences, we make no representations regarding whether third parties, including third-party ad platforms, will do so.

2. Special Messaging Consent

By submitting a request or inquiry about (or a request or inquiry for information about), or a request or authorization to be contacted about any user content, or related product, service, offerings, procedures, detail or matters you are providing your consent to be contacted for marketing, informational and related purposes in connection with such request, authorization or inquiry by one or more users, service providers and third parties or by Gloho, by telephone device (including, but not limited to, being contacted on a recorded line and potentially by use of automated dialing systems and artificial or prerecorded voice messaging), text messages, email, mail or otherwise, based on the phone number, email address and/or other data you have provided. This consent applies even if your phone number, email address or other data is on a corporate, federal, state, local or other do-not-contact type of list or directory (such as the U.S. National Do Not Call Registry). You are not required to consent to receiving autodialer calls, or to otherwise provide this consent, as a condition of purchasing any products or services from users, service providers and third parties or Gloho. You agree that your submitted request, authorization or inquiry (as described above) acts as your electronic signature for this consent. You acknowledge that for text, SMS, calls and other electronic messages that message and data rates (for example, from your network provider) may apply. You may, however, contact us to opt-out. When sharing personal information in accordance with this Privacy Policy, we may also share your computer's Internet Protocol (IP) address, identification number or location.

Please note that, even if you opt-out of receiving marketing, informational and related purposes, we may still send you transactional emails or text messages related to the performance of our Services or your account with us, including administrative, maintenance, or operational communications (for example, in connection with a password reset request), and responses to any "contact" request you initiate.

You consent to Gloho (including any designee of Gloho) contacting you in any manner consistent with information (including Personal Information) you have provided or we otherwise have pertaining to you or consistent with other instructions, requests, inquiries or consents that have been given by you or on your behalf (whether by way of this Privacy Policy or otherwise). If for a particular contact we determine we need consent from you we currently do not have (or are not sure we have), Gloho (including any designee of Gloho) may contact you by any available communication means to seek such consent. Gloho is not restricted as to information, including Personal Information, except as described in this Privacy Policy.

Changes to the policy

We may change the provisions of this Policy at any time, and we will always post the most up-to-date version on our website. If we determine, in our sole discretion, that a modification to this Policy materially affects your rights, we will notify you (by, for example, sending a message to your account email or posting on the Gloho Blog).

If you have any questions or comments about this Policy or the practices relating to our Services, or you wish to verify, correct or delete any Personal Information we have collected, please contact us via contact page.

California privacy rights

This section is provided pursuant to the California Consumer Privacy Act of 2018 (the "CCPA"). This section applies solely to our users who are California residents as defined under the CCPA.

1. Information we collect

Within the last twelve (12) months, we have or may have collected the following categories of information from our users and/or consumers: identifiers; personal information listed under Cal. Civ. Code § 1798.80(e); characteristics of protected classifications under California or federal law; commercial information; biometric information; internet or other similar network activity information; geolocation data; professional or employment-related information; and inferences drawn from such information.

2. Categories of sources from which information is collected

We obtain the categories of personal information from the following categories of sources: directly from you and publicly posted information; indirectly from other users of the Services; indirectly from third-parties that interact with us in connection with the services that we perform; and directly and indirectly through cookies and other technologies.

3. Sharing of personal information

We disclose your personal information for a business purpose to service providers and third parties to whom you authorize or direct us to disclose your personal information in connection with the Services. We also may share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your consent.

4. Personal information "sold" to third parties

In the preceding twelve (12) months, we have made available to our third-party marketing partners personal information included in the following categories: identifiers; commercial information; internet or other similar network activity information; and inferences drawn from such information.

We do not sell the personal information of consumers that we know are minors under 16 years of age without affirmative authorization as required under the CCPA.

5. Your rights under the CCPA

As of January 1, 2020, California residents, as defined under the CCPA, may take advantage of the following rights:

a) Subject to certain exclusions under the CCPA, you have the right to opt-out of the sale of your personal information.

b) You may request, up to two (2) times each year, that we disclose to you, once we receive and confirm your verifiable consumer request, the: (1) categories and specific pieces of personal information that we have collected about you; (2) categories of sources from which your personal information is collected; (3) business or commercial purpose for collecting your personal information; (4) categories of personal information that we disclosed for a business purpose; (5) categories of personal information that we sold about you; (6) categories of third-parties with whom we have shared your personal information; and (7) business or commercial purpose for selling your personal information.

c) Subject to certain exceptions and up to two (2) times each year, you may request that we delete any of your personal information that we collected from you. Once we receive and confirmed your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.

To opt-out of the sale of your personal information, please refer to the "Managing online advertising preferences" section above.

To exercise the access and deletion rights described above, please submit a request through our contact page with "California Privacy Rights" in the subject line.

Please provide certain identifying information, such as your name, email, and residency. While processing your request, we may ask you to provide further verifying documentation. We will only use personal information provided in a request to verify the requestor's identity or authority to make the request. 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 also make a verifiable consumer request on behalf of your minor child. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.

6. Non-discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Accordingly, and unless permitted by the CCPA, we will not: deny you services; charge you different prices or rates for services; provide you a different level of service; or suggest that you may receive a different price or rate for services or a different level for services. We may charge a different price or rate or provide a different level of service if the difference is reasonably related to the value provided by your personal information.