January 11, 2024
Glow Commitment Privacy Policy
This Privacy Policy (“Policy”) describes the information collected by Glow Commitment Inc. (“Glow Commitment”, “us”, “we”), how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. By using the Glow Commitment website (the “Website”) and the services, features, webinars, newsletters and content offered by Glow Commitment (the “Services”), you are accepting the practices described in this Policy. This Policy forms an integral part of Glow Commitments Terms of Service www.glowcommitment.com which is incorporated by reference. Any capitalized term used but not defined in this Policy will have the meaning defined in the Terms of Service.
Please read this Privacy Policy carefully when using the Services.
THE INFORMATION GLOW COMMITMENT MAY COLLECT
1. Information You Provide.
Glow Commitment may collect and store any personal information you enter through the Services or the Website. This may include personally identifying information, such as your name, username, e-mail address, phone number, and responses to skincare-related questions.
You may also provide information for publication or display (“Posted”) on public areas of the Website (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Glow Commitment does not store any financial information provided by a user, even though we may request information about you and your credit card and/or bank account. Glow Commitment does not store user financial data due to its use of third-party agents, including but not limited to Paypal.com and Stripe.com as its financial transaction facilitator. Please refer to such third parties’ Terms of Use for more information about how these parties use your information:
PayPal: https://www.paypal.com/us/webapps/mpp/ua/useragreement-full
Stripe: https://stripe.com/legal
Statamic: https://statamic.com/terms
Laravel 10: https://laravel.com/
Vimeo: https://vimeo.com/privacy
INTUIT Mailchimp: https://www.intuit.com/privacy/statement/
We do not store any user financial information, even though we may request information about yourself and your credit card and/or bank account. Financial information is handled, processed, and stored by the third-party financial transaction processing companies. To the extent that Glow Commitment uses third-party providers for financial transaction services, we believe that such third parties take the privacy of your personal information seriously and will use your information only in accordance with the terms of their privacy policies.
While Glow Commitment uses industry standard Secure Socket Layer (SSL) encryption technology, no system can be completely secure. Therefore, Glow Commitment does not promise, and you should not expect, that such any content or information you submit to the Website or Services may not be inadvertently collected and that any such content or information will remain secure. The information you provide to us will be kept in our database. We will use reasonable means to protect the integrity and safety of the database. However, we cannot guarantee that third parties will not improperly access the database. Glow Commitment may rely on third-party professional hosting solutions that use reasonable care in maintaining security measures to protect you and our systems against unauthorized access to, or alteration, disclosure, destruction, or loss of personal data hosted on our system.
You also may give us permission to access your information on other services. If you connect to the Services using your Facebook, Apple Face ID, or other third-party service credentials (each, a “Supported Platform”), you authorize us to collect your authentication information, such as your username, encrypted access credentials, and other information that may be available on or through your Supported Platform account, including but not limited to your name, photograph, home address and past activity on the applicable Supported Platform. The information we get from Supported Platforms may depend on your settings or their privacy policies.
2. Information Collected Automatically.
Like many sites on the Internet, the Website automatically collects information from your browser when you visit the Website. This information may include your location, internet addresses, and other web log information (such as your web request, Internet Protocol (“IP”) address, browser type, device type, browser / device language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser or device [see “Cookies” below]).
This information is logged for internal use by Glow Commitment, including helping diagnose technical problems and to administer the Website in a manner that allows us to constantly improve the quality of the Services provided to you. We may also combine all of this non-identifying information with other non-identifying information to infer interests or demographic characteristics.
Glow Commitment is the sole owner of information collected on the Website. We reserve the right to screen, copy, transmit, and review all communications conducted by or through the Website and the Services. We may conduct these activities for technical support purposes and in order to enforce our policies and agreements. At our sole discretion, we may decide to conduct these activities at various times or not at all.
3. Cookies and Use of Tracking Technologies.
Like many sites on the Internet, when you visit the Website, Glow Commitment may assign your computer one or more cookies to facilitate access to the Website or the Services and to personalize your online experience. Through the use of a cookie, Glow Commitment also may automatically collect information about your online activity on the Website, such as the time and date of your visits, the links you click, and the searches you conduct on the Website, as well as your use of the Services. Glow Commitment may use this data to better understand how you interact with the Website and the Services, to monitor aggregate usage by our users and web traffic routing on the Website, and to improve the Website or the Services. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able use some of the interactive features offered on the Website or the Services. In addition, please be aware that other parties may also place their own cookies on or through the Website or the Services, and may collect or solicit personal information from you. Other cookies may reflect de-identified demographic or other data linked to the registration data you have submitted to Glow Commitment in hashed, non-human readable form. No personally identifiable information is contained in these cookies.
4. Information Collected by Third Parties.
When you use the Website or the Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include, but are not limited to: advertisers, ad networks, and ad servers; analytics companies; your device manufacturer; your device data and internet service providers.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
These third parties may use tracking technologies to collect information about you when you use this Website or the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
If you connect your Glow Commitment account to a Supported Platform, the Supported Platform may share information about your account with Glow Commitment. You also may give Glow Commitment permission to cause certain transactions on the Supported Platform. You understand that such activities will be attributed to your account on Supported Platforms and may be published on the Supported Platforms.
You understand and agree that Supported Platforms’ or other third parties’ use of information they collect from you is governed by their privacy policies, and Glow Commitment’s use of such information is governed by this Policy.
In addition, Glow Commitment may receive certain information collected by third parties, such as when third parties conduct background checks on Glow Commitment Providers. Those third parties share the results of the background check with Glow Commitment.
5. Agents.
Glow Commitment may employ or engage other companies and individuals from time to time to perform business functions on behalf of the Website and the Services. These persons are provided with personal identifying information required to perform their functions, but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to removing repetitive information from user lists, analyzing data, providing marketing assistance, performing background checks, processing credit card payments, and providing user services.
Any supplied billing or payment information (if collected by and through the Website, as opposed to being directly inputted and collected by and through third parties) shall be encrypted for transmittal to a third-party intermediary for processing. Such billing information is used only to bill for those purchases you choose to make through the Website or the Services. The process is designed to protect your billing information against unauthorized misappropriation by third parties. As the technological landscape is constantly changing, no security system is absolutely secure. Glow Commitment cannot and does not guarantee the security of any of its databases and information contained therein, nor can Glow Commitment guarantee any supplied information will be absolutely secure from interception during transmission to the Website and/or the Services over the Internet.
HOW GLOW COMMITMENT USES THE INFORMATION IT COLLECTS
Glow Commitment may use information that it collects as described above to:
Learn your individual skincare questions, needs, and desires, and what specific changes you want to see in the skincare industry.
Sell the abovementioned data to third parties.
Deliver the services that you have requested, including by sharing your information with Supported Platforms in connection with such requested services.
Provide you with customer support.
Address user complaints.
Improve the Website and the Services.
Give you notice about your account/subscription, including expiration and renewal notices.
Communicate with you by email or message in connection with the Services.
Enforce or exercise any rights in Glow Commitment’s Terms of Service.
Perform functions as otherwise described to you at the time of collection.
The usage information we collect helps us to improve the Website and to deliver a better and more personalized experience by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you use the Website.
We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Glow Commitment may also release your personal information to a third party in order to protect, establish, or exercise our legal rights or defend against legal claims; comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or as necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity.
Through your settings within the Website and the Services, you can choose which communications you receive from us and manage your profile information and connected Supported Platforms. To change, customize, or limit access to or sharing of information collected from Supported Platforms, please visit your account settings on the applicable Supported Platform.
YOUR CHOICES ABOUT OUR COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information. If you do not consent to the collection, use or sharing of your information in the manner described in this Policy, please do not provide us with such information. By providing such information, you are opting into the collection, use and sharing of this information in accordance with this Policy.
1. Tracking Technologies.
You may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you may be able to reduce the number of cookies you receive from us or third parties, or delete cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser to see if you can reject or disable such cookies. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Website may then be inaccessible or not function properly.
2. Advertising Services.
When you use the Website, we, our service providers and advertising partners may set and access cookies and similar tracking technologies on your computer or mobile device in order to collect information about your online web-browsing activities over time and across different online websites and services (including, but not limited to, online or cloud computing services, and online applications) or mobile applications in order to serve you ads or other content personalized to your interests. This form of advertising is referred to as Interest Based Advertising (“IBA”). In order to personalize these ads or content, we or our advertising partners or service providers may connect and/or share data about you either to data you provided to us, e.g., your email address, or to information collected from you, such as your IP address or other unique identifier. The use of cookies, pixel tags, or similar technologies by these third parties is subject to their own privacy policies, not ours. To learn more about such interest-based advertising, please visit: https://optout.aboutads.info.
If you do not want your information collected and used by us or the companies we work with for IBA purposes, you can opt out of this form of advertising through the cross-industry Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance (DAA). To opt out of IBA, please click on the following link and follow the instructions: DAA AppChoices – http:// www.aboutads.info/appchoices/ and http://optout.aboutads.info. To opt out from the use of information about your online activities for IBA by NAI member companies, visit: http:// www.networkadvertising.org/choices/.
THIRD-PARTY WEBSITES
There may be a number of places on the Website and the Services where you may click on a link to access other websites that do not operate under this Policy. For example, if you click on a hyperlink on the Website, you may be taken to a website that Glow Commitment does not control. These third-party websites may independently solicit and collect information, including personal information, from you. Glow Commitment recommends that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy” link typically located at the bottom of the webpage you are visiting.
CHILDREN’S PRIVACY
Glow Commitment forbids the use of the Website and the Services to individuals age 17 and below, without the consent of a parent or guardian over the age of 18. Glow Commitment does not knowingly collect personal information from children under the age of 13. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
NOTICE TO CALIFORNIA USERS
Subject to the limitations under California Civil Code § 1798.83, if you are a California resident, you may ask us to provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year. You may also request the identity of certain third parties that received your personal information from us for their direct marketing purposes during the immediately preceding calendar year. You may make a request as described hereinabove once a year.
Glow Commitment does not currently disclose personal information to third parties for their direct marketing purposes.
VISITING THE WEBSITE AND SERVICES FROM OUTSIDE THE UNITED STATES
This Policy is intended to cover collection of information on the Services from residents of the United States. If you are visiting the Website or using the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where Glow Commitment’s servers are located and Glow Commitment’s central database is operated. By using the Website or the Service, you understand that your information may be transferred to Glow Commitment’s facilities and those third parties with whom Glow Commitment shares it as described in this Policy. You are responsible for ensuring that information you share conforms to all local data protection laws. You acknowledge that the laws, regulations, and standards of the country in which your information is stored or processed may be different from those of your own country.
LEGAL DISCLOSURE
Glow Commitment may transfer and disclose your information to third parties: (i) to comply with a legal obligation; (ii) when we believe in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce Glow Commitment’s Terms of Service; (v) to respond to an emergency; or (vi) otherwise to protect the rights, property, safety, or security of third parties, visitors to the Website or the public.
CHANGES TO THE PRIVACY POLICY
Glow Commitment will occasionally update this Policy. When Glow Commitment posts changes to this Policy, it will revise the date at the top of this Policy. Glow Commitment recommends that you check the Website from time to time to inform yourself of any changes in this Policy or any of Glow Commitment’s other policies.
If you have any questions concerning this Policy, please contact us at:
Glow Commitment, Inc
Attn: Privacy Policy Questions
4045 Hampton St 6H
Elmhurst, NY 11373-2015
Email: kathleen@glowcommitment.com
Privacy notice for California residents
Effective Date: [DATE]
Last Reviewed on: [DATE]
This Privacy Notice for California Residents supplements the information contained in our Privacy Policy above and applies solely to all users of the Website, who reside in the State of California (” consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include publicly available information from government records, or deidentified or aggregated consumer information. In particular, we have collected the following categories of personal information from our consumers, where indicated “YES” below, within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Information on a consumer’s interaction with a website. | YES |
| G. Geolocation data. | Physical location or movements | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
We obtain the categories of personal information listed above as defined in Sections 1-4 of the “The Information Glow Commitment May Collect” section of the Privacy Policy.
USE OF PERSONAL INFORMATION
We may use the personal information we collect from you as defined in the “How Glow Commitment Uses the Information it Collects” section of the Privacy Policy. In addition, we disclose each of the foregoing categories of personal information to our service providers, business and advertising partners, advertising networks, data analytics providers, and social networks.
We may “sell” the following categories of personal information: identifiers, personal information categories listed in Cal. Civ. Code. § 1798.80(e); commercial information; internet or other electronic network activity; geolocation data; and inferences. You can opt-out of the sale of your personal information to a third party by contacting kathleen@glowcommitment.com. For the purposes of this Privacy Policy “sell” means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral written, or electronic communication of your personal information to an outside party for monetary or other valuable consideration.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (as further defined below in Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or using that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at kathleen@glowcommitment.com. Only you, or someone legally authorized 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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The “verifiable consumer request” must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.
CONTACT INFORMATION
If you have any questions or comments about this notice, the ways in which we collect and use the information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at kathleen@glowcommitment.com.
