LAST UPDATED | July 5, 2017
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 and phone number in order to obtain information about our Services. 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.
“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.
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-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-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”.
We use third-party analytics services, such as Google Analytics, Mixpanel and Flurry Analytics, to collect and analyze the non-personally identifiable 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.
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 personally identifiable information you submit within the mobile application.
DO NOT TRACK
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-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-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.
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.
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 email@example.com.
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.
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 firstname.lastname@example.org.
THE SECURITY OF YOUR INFORMATION
We take reasonable measures to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. 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.
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
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.
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.
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.
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.
EU-US PRIVACY SHIELD. 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.
Glint has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
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.
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