Privacy Policy – March 13th 2020

LAST UPDATED | March 13, 2020

Protecting your privacy is really important to us at Glint Inc (collectively “Glint”, “we”, “us”, or “our”). Accordingly, we are providing this Privacy Policy to explain our practices regarding the collection, use, security, and disclosure of personally identifiable information (“PII”) that we receive when you use our website available at www.glintinc.com (the “Site”), our mobile applications (the “App”) or our services available via the Site and App (collectively, the “Services”), whether you are a Survey Respondent (defined below) or a Glint administrator (“Administrator”) (defined below).

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Any information that we collect is subject to the Privacy Policy in effect at the time that information, including your PII, is collected. We may, however, modify and revise this Privacy Policy from time to time to reflect changes to our information practices. If we make any material changes to this Privacy Policy, we will notify you of those changes by posting them on the Services or by sending you an email or other notification, and we will indicate when those changes will become effective. Also, please note that, unless we define a term in this Privacy Policy, all capitalized words used in this Privacy Policy have the same meanings as in our Terms of Service, which are located at https://www.glintinc.com/terms/.

HOW DO WE COLLECT AND USE INFORMATION?

Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your account on the Services (an “Account”), if you are an Account holder), and to enable you to enjoy and easily navigate our Services.

Information Collected Through Our Services.

If you visit our Site, you may choose to provide us with your first and last name, email address, phone number, business info such as company name, and number of employees, in order to obtain information about our Services or respond to customer service requests. We collect this information only for our marketing purposes and will not share this information with third parties.
If you respond to a survey administered via our Services you are a “Survey Respondent”, and we may collect PII about you in connection with such survey responses on behalf of the Glint Client (defined below), as described under the Section entitled “Survey Information”.
If you are an Administrator, we will collect PII about you that you provide to us in connection with your use of the Services.
When you download and use our App, we automatically collect information about the type of device you use, operating system type and version, to improve, personalize and enhance our Services.

Information Collected Using Cookies and other Web Technologies. We and our marketing partners, affiliates, or analytics or service providers, like many website owners, use automated data collection tools such as Cookies and similar technologies to collect certain information, in order to, among other things, analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We may change this Policy at any time in order to reflect changes to the Cookies we use or for other operational, legal, or regulatory reasons. If you have questions regarding this Policy, please contact our Data Protection Officer (“DPO”) by email at privacy@glintinc.com, or write to us at: 1000 West Maude Avenue, Sunnyvale, CA 94085 USA.

What is a Cookie? “Cookies” are small text files that are placed on your hard drive by a Web server when you access our Services, whether you are Survey Respondent or an Administrator. We may use session Cookies, persistent Cookies, and Web Beacons (defined below).
Why do we use Cookies? We use Cookies to identify that you’ve accessed the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor analytics such as aggregate usage and web traffic routing on our Services and to customize and improve our Services. Cookies also enable us to market our services to you through our partners (further described, below).
What Cookies do we Use? Below is a list of the different types of Cookies that we may use with examples to illustrate each type.
Controlling Advertising and Analytics Cookies: Our partners may use cookies or similar technologies to help us market our services to you off of Glint’s website or help us understand how visitors are using and accessing our site. If you wish to opt-out of these cookies, you may be able to do so using the opt-outs available on our partners’ websites, such as those we have listed below. If you are in the European Union or the United Kingdom, you also can control these cookies using the cookie banner at the bottom of your screen.

Partner Marketing Cookies
Cookie Name	Description	Cookie Expiration
Google	Tracks users for advertising targeting purposes	After 6 months
AddThis	Enable visitors to share content with a range of networking and sharing platforms.	After 12 months
LinkedIn	Tracks members and non-members of social media for behavioral advertising, analytics, and market research.	After 24 months
Bing	Tracks users for advertising targeting purposes	After 24 months
DoubleClick	Analyzes audience to improve website design and content.	After 24 months

Partner Analytics Cookies
Cookie Name	Description	Cookie Expiration
Google Analytics	Tracks website traffic	After 26 months

Essential Cookies On Our Website
Cookie Name	Description	Cookie Expiration
Intercom	Tracks a user’s conversation between page requests	After 9 months

Preference Cookies
Cookie Name	Description	Cookie Expiration
Munchkin	Records last visit and activity	After 24 months

Unlike persistent Cookies, session Cookies expire when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies and similar technologies on your hard drive. Note that this Privacy Policy covers only Glint’s use of Cookies and does not include use of Cookies by such third parties.

“Web Beacons” (also known as clear gifs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

“APIs” or application programming interfaces are software components that enable our Services to communicate with third-party services. We may use APIs to enable our Services to communicate with and gather information from third-party services, such as single sign on (SSO) services, used by our users.

We may receive reports based on the use of Cookies, Web Beacons, APIs, and other similar technologies by third-party services providers that we engage, on an individual and aggregated basis.

Log Data. Our servers automatically record certain information about how users use our Services (we refer to this information as “Log Data”). Log Data may include information such as a user’s Internet Protocol (IP) address, browser type, operating system, the web page that a user was visiting before accessing our Services, the pages or features of our Services to which a user browsed and the time spent on those pages or features, search terms, the links on our Services that a user clicked on, comments and other communications conducted over our Services, information from other third party products and services that we enable users to connect to their Accounts and other statistics. We use this information to administer the Services, and we analyze (and may engage third parties to analyze) this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our users’ needs and preferences. We may combine the Log Data with other information we collect about you. We do this to improve our Services or to improve marketing, analytics, or functionality. We may use a person’s IP address to fight spam, malware and identity theft. We also use the IP Address to generate aggregate, non-directly-identifying information about how our Services are used. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you or to improve marketing, analytics, or Site functionality.

Location Information. We do not ask for, access or track any location based information from your mobile device at any time while downloading or using our App or Services.

Survey Information. If you are Survey Respondent, we will collect your survey responses and provide them to the Glint Client (defined below) (including its Administrators) all under the direction of the Glint Client, who is the data controller in the context of any information you provide in connection with a survey. The “Glint Client” is the Glint corporate customer or client which is responsible for administering the survey. Unless we tell you otherwise via the Services before you respond to a particular survey, we will provide your survey response without directly identifying you to the applicable Glint Client; however, please be advised that, it is possible that the Glint Client may be able to determine your identity based on the information you include in your survey responses (by way of example, but not limitation, if you include PII or non-directly-identifying PII from which you may be identified in your comments or other written survey responses).

We will however, in some cases, associate a Survey Respondent’s PII with your survey responses and provide your PII combined with your responses to the applicable Glint Client but we will inform you of this before you respond to the survey. In such cases, if you don’t want your PII associated with your survey responses and provided to the Glint Client, then you should not respond to the survey in question.

The Glint Client may use and disclose your survey responses as they so choose, subject to the terms of their respective agreements with us. We may also disclose survey responses as further described in the Section entitled “Information Shared with Third Parties”.

ANALYTICS

We use third-party analytics services, such as Google Analytics and AddThis to collect and analyze the non-directly identifying personal information described above. These analytics services use the visitor tracking technology we have described above, such as a Cookie, tracking pixel or other mechanism to collect, use, share and store our users’ data.

You can find more details about how Google Analytics collects, uses and stores our users’ data by reviewing the Google privacy policy, located at http://www.google.com/intl/en/policies/privacy/. In addition, Google Analytics provides you with the ability to opt-out of its tracking services. Details of such opt-out are available at https://tools.google.com/dlpage/gaoptout/. Opting-out of the Google Analytics services will affect only the collection and use of your data by Google Analytics, not by any other party.

AddThis’ privacy policy is located at https://www.oracle.com/legal/privacy/addthis-privacy-policy.html. If you wish to opt out of AddThis’ collection of application usage data while you use our Services, you can visit https://datacloudoptout.oracle.com/

Our marketing partners, or other analytics service providers, also use Cookies or other similar technologies, to analyze trends, and help us administer the Services, track users’ movements around the Services, and gather demographic information about our user base as a whole, including to manage our advertising on other sites. Accordingly, our third party partners may use cookies or similar technologies in order to help us market our services to you. If you wish to opt out of this targeted marketing of our services, please use the options available in the Cookie Banner at the bottom of the page. Please note you may continue to receive generic ads. We may also receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

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 where the application was downloaded from. We do not link the information we store within the analytics software to any PII you submit within the mobile application.

DO NOT TRACK

Do Not Track (DNT) is a concept that has been promoted by regulatory authorities for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. Industry groups, Internet browsers, technology companies, and regulators have been working together to develop a DNT technology standard. While some progress has been made on this issue, it has been slow, and to date no standard has been adopted. Without an industry standard for DNT, users cannot know how any given company abides by a DNT signal they receive from browser headers. Because there is no single standard, Glint currently doesn’t respond to DNT signals. For more information regarding Do Not Track mechanisms, see http://allaboutdnt.com/.

WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?

We will not share any PII that we have collected from you, whether you are Survey Respondent or an Administrator, except as described below:

Information Shared with Our Services Providers. We may engage third party service providers to work with us to administer and provide the Services such as a cloud service provider to host Glint’s service and providing technical support. These third-party services providers have access to your PII only for the purpose of performing services on our behalf.

Non-PII Shared with Third Parties. We may share aggregated information and non-directly identifying information with third parties, including other users, to enhance the effectiveness of our Services and for industry research and analysis, demographic profiling, benchmarking, and other similar purposes. For example, we may share aggregated, non-directly identifying user or organizational information with other Glint Clients to enable them to compare their organization’s metrics (e.g., survey response rates) with organizations of similar size and/or industry.

Information Shared with the Glint Client. As described above, in some cases, for Survey Respondents we will associate their PII with their survey responses and provide this PII combined with the responses to the applicable Glint Client but we will inform Survey Respondents of this before they respond to the survey.

Information Shared with Third Parties Upon the Request of the Glint Client. For Survey Respondents, we will share their survey responses and PII associated with such responses with third parties upon the request of the applicable Glint Client, provided we obtain consent from the Survey Respondents in advance of sharing such information. Transfers to subsequent third parties are covered by the service agreements with our Clients.

Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including PII, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your PII may be disclosed or transferred to the third-party acquirer in connection with the transaction. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

Information Disclosed for Our Protection and the Protection of Others. In certain situations, Glint may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

ACCESSING OR MODIFYING YOUR INFORMATION

Upon request, Glint will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@glintinc.com.

Site Users. If your personal information changes, or if you no longer desire our Services, you may correct, update, amend, delete/remove, ask to have it removed from a testimonial on our Site or deactivate it by emailing us at privacy@glintinc.com headed “subject access request” or write to us at Glint Inc, Attn: Privacy Policy Administrator, 1000 West Maude Avenue, Sunnyvale, CA 94085 USA. Before we process any request, we may request personal information to verify your identity where allowed by law. Where permitted by local law, we may reject requests that are unreasonable or impractical. We will respond to your request within a reasonable timeframe.

We will retain your information for as long as your Account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Survey Respondents and Administrators. Glint collects information under the direction of Glint Clients and has no direct relationship with the individuals whose personal data it processes. If you are either a Survey Respondent or an Administrator and would no longer like to be contacted by the applicable Glint Client, please contact the Glint Client directly. In addition, if you want to correct, amend, or delete inaccurate PII you have provided in connection with a survey or in connection with your Administrator Account, you should direct your query to the Glint Client. If we are requested by the Glint Client to remove data, we will respond within a reasonable timeframe.

RETENTION OF YOUR INFORMATION

We will retain your PII that we process on behalf of the applicable Glint Client for as long as needed to provide Services to our Glint Client. We will retain this PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

OPT-OUT PREFERENCES

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your Account settings page, or you can email us at privacy@glintinc.com or write to us at Glint Inc, Attn: Privacy Policy Administrator, 1000 West Maude Avenue, Sunnyvale, CA 94085 USA.

TESTIMONIALS

We display personal testimonials of satisfied users and customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@glintinc.com.

THE SECURITY OF YOUR INFORMATION

The security of your personal information is important to us. We follow generally accepted standards and take reasonable measures to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure, both during transmission and once it is received. For example, we offer the use of a secure server for the Site and Services. All PII supplied by you to us via the Services is transmitted via Secure Socket Layer (SSL) and the Site via a similarly secure technology. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

You should be aware that Glint Clients may be able to track and review your Internet use and/or emails when you use certain of the Glint Client’s resources (i.e., from your office, or using a laptop or device furnished or provisioned by your organization). We cannot control these activities and are not responsible for any such activities by the Glint Client.

LINKS TO OTHER SITES

Our Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services, and we are not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information, we recommend that you carefully review the privacy policies of other websites and services that you access.

SOCIAL MEDIA WIDGETS

Our Services include Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our Services. These features may collect your Internet protocol address, which page you are visiting on our Site, and may set a Cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing such features.

INTERNATIONAL TRANSFER

Your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there.

The use of information collected through our Services shall be limited to the purpose of providing the service for which the Glint Client has engaged Glint Inc.

The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce, and the European Commission and Swiss Administration, respectively, to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States in support of transatlantic commerce.

Glint participates in and has certified that it complies with the E.U. – U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework. Glint is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Glint has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.

Glint is responsible for the processing of personal data it receives from the EU and Switzerland, under the Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. Glint complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. Glint remains liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such personal data on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Glint is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Glint may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Glint commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us at privacy@glintinc.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, Glint has committed to cooperate with the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Framework, the Privacy Shield Framework shall govern.

OUR POLICY TOWARD CHILDREN

Our Services are not directed to children under 13, and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of a child under 13, we will take steps to delete such information from our files as soon as possible.

QUESTIONS?

Please contact us at privacy@glintinc.com if you have any questions about our Privacy Policy.

GLINT INC
1000 West Maude Avenue
Sunnyvale, CA 94085 USA
Email: privacy@glintinc.com
+1 650.817.7240