GLOSSAI LTD. Privacy policy

Last Updated: February 26, 2023

This privacy policy (“Privacy Policy”) governs how we, GlossAI Ltd. (together, “GlossAI” “we”, “our” or “us”) use, collect, and store Personal Data we collect or receive from or about you (“you”) such as in the following use cases:

1. When you make use of, or interact with, our website, https://glossai.co/  (“Website”)
   1. When you browse or visit our Website
   2. When we process your job application 
   3. When you contact us (e.g. support, help, chat, general inquiries)
2. When you make use of, or interact with, our platform, and any other software, that we license (each individually, and collectively, the “Platform”).
   1. When you create an account and when you log in
   2. When you make use of our Platform
3. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data 
4. When we acquire your Personal Data from third-party sources (such as lead-generation companies) 
5. When we use the Personal Data of our customers (e.g. contact details) 
6. When we use the Personal Data of our service providers (e.g. contact details) 
7. When you interact with us on our social media profiles (e.g., Facebook, LinkedIn) 

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant to GDPR-protected individuals. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. Table of contents:

1. What Personal Data we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your privacy rights. How to delete your account
6. Use by children
7. Interaction with third party products
8. Log files 
9. Our California Do Not Track Notice
10. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

• WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific personal data we collect	Why is the personal data collected and for what purposes?	Legal basis (GDPR only, if applicable)	Third parties with whom we share your personal data	Consequences of not providing the personal data
When you make use of, or interact with, our Website
When you browse or visit our Website
Cookies, analytic tools and log files, usage data (time on site, actions taken) and user data (location, device, channel, lead form For more information, please read our cookies policy	To analyze, support and improve our Website.  To personalize the Website  To help optimize our marketing efforts and campaigns for visibility and conversion.	Consent  Legitimate interest (e.g., essential cookies)	Hubspot	Certain Website features may not be available
When we process your job application.
Full name Email address Telephone number  CV – resume  Cover letter Any other information that you decide to provide/supply us with Please see here our Employee and Candidate Privacy Notice for more information.	To assess you as a candidate To communicate with you in connection with your job application	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g., to analyze your application)	Gmail  Google Drive	Cannot assess you as a candidate Cannot communicate with you in connection with your job application
When you contact us (e.g. support, help, chat, general inquiries)
Full name Email address Any other information that you decide to provide/supply us with	To answer your query To respond to your requests To provide support and customer service To customize your experience	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract   Legitimate interest (e.g. provide support and answer your questions)	Slack  Hubspot Gmail	Cannot answer your query Cannot respond to your requests Cannot provide support and customer service Cannot customize your experience
Full name Email address	To send you marketing communications	Consent	Gmail Hubspot	Cannot send marketing communication
When you make use of, or interact with, our Platform
When you create an account and when you log in
Full name Email address User ID and Password Any other information that you decide to provide/supply us with	To create your account and allow you to create the admin and regular users To allow you to log in/sign up to the Platform To fulfill your requests for our services and related activities (e.g., account management, support) To perform/execute the relevant agreement To grant you access to the services (our Platform)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to allow you to sign up to the Platform)	LogRocket Amazon (AWS) Gmail	Cannot create your account and allow you to create the admin and regular users Cannot allow you to log in/sign up to the Platform Cannot fulfill your requests for our services and related activities (e.g., account management, support) Cannot perform/execute the relevant agreement Cannot grant you access to the services (our Platform)
Full name Email address	To send you marketing communications	Consent	Gmail Hubspot	Cannot send marketing communication
When you make use of our Platform
Full name IP Address Any other information that you decide to provide/supply us with	To provide you with access to our Platform To allow you to use the Platform In order to provide you the services	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to allow you to sign up to the Platform)	LogRocket Amazon (AWS) Gmail	We cannot provide you with access to our Platform We cannot allow you to use the Platform We cannot provide you with the services
When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
Full Name Email Address Company name Job title Phone number Any other data you decide to provide/supply us with	To establish a first business connection/discussion To send you marketing communications	Consent  Legitimate interest (e.g. to establish a business connection)	Hubspot	Cannot establish a first business connection/discussion Cannot send you marketing communications
When we acquire your Personal Data from third-party sources (such as lead-generation companies)
Contact details	To establish a first business connection/discussion To send you marketing communications	Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent	Hubspot	Cannot establish a first business connection/discussion Cannot send you marketing communications
When we use the personal data of our customers (e.g. contact details)
Full name Company name Email address  Any other data you decide to provide/supply us with	To provide our products and services To perform the applicable agreement To communicate with our Customers/clients (e.g., to send you contract-related communications) To send you marketing communications	Processing is necessary for the performance of a contract to which our customer is a party. Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g. send you contract-related communications)	Gmail Slack	Cannot provide our products and services Cannot perform the applicable agreement Cannot communicate with our Customers/clients Cannot establish a first business connection/discussion Cannot send you marketing communications
Full name Email address	To send you marketing communications	Depending on the context, legitimate interest (B2B marketing or soft-opt in) or consent	Gmail	Cannot establish a first business connection/discussion Cannot send you marketing communications
When we use the personal data of our service providers (e.g. contact details)
Full name Company name Job title Email address  Phone number Any other data you decide to provide/supply us with	To contact our service providers/vendors To perform the applicable agreement	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g.to contact our service providers)	Gmail Deel	Cannot contact our service providers/vendors Cannot perform the applicable agreement
When you interact with us on our social media profiles (e.g., Facebook, LinkedIn)
Full name Company name Email address  Phone number Any other data that you decide to supply/provide us and/or publicly available on your social media account	To reply and/or respond to your request or question	Consent  Legitimate interest (e.g. send you more information about GlossAI)	N/A	Cannot reply and/or respond to your request or question

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 

• HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA

1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
2. Retention of your Personal Data. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. 

•  HOW WE SHARE YOUR PERSONAL DATA 

In addition to the recipients described above, we may share your Personal Data as follows:

1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies. 
2. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
3. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
4. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or 
5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

• ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA 

1. Storage: We store the Personal Data with the following storing companies: AWS – Ohio.

• External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When GlossAI engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. 
• YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
• Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
• You have the right to object, to or to request restriction, of the processing;
• You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

1. You can exercise your rights by contacting us at privacy@glossai.co. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. 
2. Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@glossai.co. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

• USE BY CHILDREN. We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at  privacy@glossai.co.  
• INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service. 
• LOG FILES. We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

• OUR CALIFORNIA DO NOT TRACK NOTICE. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We may collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services. If you choose to operate your web browser “do not track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We may allow third parties such as such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
• CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@glossai.co.