Gluetrail Inc. (together with its affiliated companies – “Gluetrail”, “Gluetrail”, “we”, “our” or “us”) puts great efforts in making sure that the personal data processed by us is safe and used properly, and that our data practices are properly communicated to our customers, users and prospects.
This Privacy Policy describes how we collect, store, use and disclose personal data relating to our “Customers” – Gluetrail’s business customers and users of Gluetrail services (“Services”), participants at our events, any other prospective customers or partners, and any individuals who visit or otherwise interact with any of our websites and web pages (such as www.gluetrail.com), online ads, content, social media profiles, emails or communications under our control (collectively, “Sites”).
Our Sites and Services are designed for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our website, as pertaining to individuals acting as business representatives, rather than in their personal capacity.
If you are a Customer (“you”), please read this Privacy Policy carefully and make sure that you fully understand it.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use of our Services. If you are a user of the Services on behalf of any of our business customers, we suggest that you contact your account administrator with any questions.
We collect and generate the following types of personal data relating to our Customers:
We collect such data either automatically, through the data subject’s interaction with us or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
We use Customers’ personal data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, users, visitors, prospects, ourselves and our Services.
If you reside or are using the Sites or Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services), your acceptance of our Terms of Service and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at [email protected].
Specifically, we use our Customers’ personal data for the following purposes:
We retain Customer personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services, Sites and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data for such limited purposes as determined in our agreements with them.
We have a strict OAuth 2 policy where customers have to explicitely grant access through an OAuth 2 Flow. The user can delete and revoke at any time this access and access will be deleted from our systems.
We do not unless explicitely configured to do so. Our platform is designed to ensure that no data is shared with AI platforms or any other third-party services unless you, the user, have explicitly configured it to do so. When you choose to integrate with third-party services, we strictly limit the data shared to only what you have specified in your configuration. This means you have full control over what information is shared, ensuring that your data is used only in ways you have directly authorized. We are committed to providing a transparent and user-driven experience, guaranteeing that your data privacy preferences are respected and upheld at every level of our operation.
Gluetrail AI Functions From time to time, Gluetrail may include Gluetrail AI Functions as part of the Service. This section of the Terms applies to Gluetrail AI Functions where you provide information (“Input”) and receive output generated and returned by the Gluetrail Al Functions based on the Input (“Output”, and together with Input, “Al Content”). For purposes of clarity, Output shall exclude the Service, Third-Party Services, Documentation, and Usage Information. (i) When you use such Gluetrail AI Functions, as between the parties and to the extent permitted by applicable law, you own the AI Content. You are solely responsible for your AI Content, including compliance with applicable laws and these Terms. Other users providing similar Input to Gluetrail Al Functions may receive the same or similar Output. Responses received by other users are not your AI Content. (ii) YOU UNDERSTAND AND AGREE THAT ANY INFORMATION OBTAINED THROUGH USING GLUETRAIL AI FUNCTIONS IS AT YOUR SOLE RISK. DO NOT RELY ON FACTUAL ASSERTIONS IN OUTPUT WITHOUT INDEPENDENT FACT-CHECKING. DO NOT RELY ON DESIGNS, WORKFLOWS/PROCESSES, OR CODE IN OUTPUT WITHOUT INDEPENDENT REVIEW OF FUNCTIONALITY AND SUITABILITY FOR YOUR NEEDS. NO SUCH INFORMATION, SUGGESTIONS, OR OUTPUT OBTAINED BY YOU FROM GLUETRAIL OR THROUGH GLUETRAIL AI FUNCTIONS SHALL CREATE ANY WARRANTY NOT EXPRESSLY MADE HEREIN. (iii) You may not use Gluetrail AI Functions or Output: (1) to develop foundation models or other large-scale models that compete with Gluetrail or the Gluetrail AI Functions; (2) to mislead any person that Output from the Service was solely human-generated; (3) in a manner that violates any technical documentation, usage guidelines, or parameters; (4) to make automated decisions that may have a detrimental impact on individual rights without appropriate human supervision; or (5) in a manner that infringes, violates, or misappropriates any of our rights or the rights of any third party.
Google API Services User Data Policy: Gluetrail use use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements
When our Service Providers contact you in order to offer or promote our Services, they may additionally interest you in their own services. Should you decide to engage in such activities with the Service Provider, please note that such engagement is beyond the scope of Gluetrail’s Terms and Privacy Policy and will therefore be covered by our Service Provider’s Terms of Service and Privacy Policy.
Business Customers: Our business customers have access to any data we process on their behalf in our capacity as a “processor” or a “service provider.”
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Third Party Websites and Services: Our Sites and Services may include links to third party websites, and integrations with third party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services.
Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Gluetrail, any of our users or customers, or any members of the general public.
Gluetrail Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Gluetrail or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
For the avoidance of doubt, Gluetrail may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools. We may also use HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
We also use web analytics tools, including Google Analytics. These tools help us understand users’ behavior on our Sites and Platform, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/, Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. If you are registered as a user to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, user or prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, Platform or Sites, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Gluetrail at any time by sending an e-mail to:[email protected], changing your communications preferences in your profile settings whilst being logged as a user to our Services, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
We implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, although we make efforts to protect your privacy, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
Regarding the security measures implemented to protect personal data from any risk of violation, unauthorized disclosure or attack on their integrity, Gluetrail has deployed all the necessary means with its teams and service providers to minimize the risk of security breaches, in particular:
When certain services require the use of a third party (subcontractor), Gluetrail selects its service providers on the basis of strict security and confidentiality criteria previously defined with regard to the issues, and systematically requires from its subcontractors a level security that guarantees a sufficient level of protection of the personal data that they process on our behalf.
Individuals have rights concerning their personal data. Please contact us by e-mail at: [email protected] if you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as – to the extent applicable – the right to request access to, and rectification or erasure of your personal data held with Gluetrail, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).
We may redact from the data which we will make available to you, any personal data related to others.
Our processing of personal data on behalf of our business customers as part of the Services is governed by our agreements with such customers. We process this data on behalf of our customers in our capacity as service providers (or “data processors”) to our customers. Our customers are “data controllers” (under the EU or UK GDPR and similar laws) or “business” (under the CCPA or similar laws) with respect to that data.
Our business customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using Gluetrail on the customers’ behalf or at their request have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the business customers, including specifically in the context of an employment relationship. Our business customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services.
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Sites and/or Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Sites and/or Services. After such notice period, all amendments shall be deemed accepted by you.
External Links: While our Sites and/or Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Sites or Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Sites or Services.
Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Sites, Platform and/or Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected].
Data Protection Officer: If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your Privacy, or if you wish to make a complaint about how your personal data is being processed by Gluetrail, you can contact [email protected].
Contacting Us: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact Gluetrail’s support at [email protected].
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Gluetrail Privacy Policy ("Gluetrail Web Privacy Policy” or “this Policy”) and Gluetrail Terms of Use constitute the Gluetrail Web Agreement, which is legally binding between the End User and Us with respect to Your use of Our Website and Services.
This Policy explains how We treat End User Data and protect End Users’ privacy when You use the Services. End User agrees that We may access, collect and use the End User Data according to this Policy.
“End User” means You and Your Authorized Representative (if any), as the case may be. “End User Data” means the data that We collect from the End User.
Any capitalized terms used in this Policy will have such meaning as assigned under the respective Clauses or under the Gluetrail Web Terms of Use.
1. Background
2. Information That We Collect
3. Use of the Information Collected
4. Confidentiality, Disclosure and Transfer
5. Security
6. Changes to this Policy
7. Your Acceptance and Rights
8. Disclaimer