Privacy Policy

Glass Labs Inc. (“Glass”) cares deeply about the privacy of its users and would like to share the steps it takes to protect your personal information in compliance with applicable data privacy laws and best practices.  The below policy describes: (1) what information may be collected; (2) how such information may be used; and (3) your rights as a visitor or user of this app regarding such information. Information may be collected on our app and website (the “App”). Glass uses this information to deliver the services offered on the App, to inform you of changes to the App or your account, to enhance the App, to prevent illegal or potentially prohibited conduct, and to enforce our Terms of Use (the “Terms”), which incorporate this Privacy Policy by reference.

Before you access or use any of our services we encourage you to read the entire Privacy Policy. A short summary is below:

We take your privacy very seriously and we work hard to earn and keep your trust. As such, we adhere to the following basic principles to protect your privacy:

1. Please Read the Whole Policy

This Privacy Policy governs Glass’s information management policies including how Glass gathers, stores or shares your information, if at all. Notwithstanding anything to the contrary, this Privacy Policy does not apply to information that is gathered or collected offline. By using the App and by submitting information to Glass, you agree to the practices described in this Privacy Policy and to any other applicable terms, including the Terms. This Privacy Policy is intended to provide you with a clear explanation of how, when and why we collect and use your personal information, as well as an explanation of your legal rights. Nothing in this policy is intended to override the terms of any contract you have with us or any rights you have under applicable data privacy laws.

Please read the entire policy and make sure you fully understand our practices before using our services. If you do not agree with our practices you must immediately leave the App. If you have any questions after fully reading the policy, please contact us at: legal@glass.photo.

From time to time, we may develop new or offer additional services or we might change or extend the list of partners that we use to store and process personal data.  If the introduction of services results in any material changes in the way we collect or process your information we will provide you with more information and update this policy.

2. What Information Is Collected?

We collect two types of information from visitors and users. The first, unidentified and non-identifiable information (“Anonymous Information”) does not enable Glass to identify the visitor or user from whom it was collected. The Anonymous Information collected by Glass may consist of the date, time, length and non-precise location of your visit. Glass will not aggregate, use or share Anonymous Information with third parties for marketing or advertising purposes.

The second type of information we collect is individually identifiable information, meaning information that can identify an individual or may, with reasonable efforts, lead to the identification of an individual (“PII”).  PII collected by Glass consists of contact details provided by users when creating a user account (“User Account”) (e-mail address, full name, profile picture and description), correspondence through the App, and any other PII provided directly by users and visitors to Glass.  A third-party payment processor collects and processes financial information on our behalf; we do not collect or retain your payment information. If any Anonymous Information is linked to PII, it is treated as PII as long as the connection exists.

You may review, amend or delete any and all information associated with your User Account by signing into your account on the App. You may also request the deactivation of your User Account and any uploaded content by sending an e-mail to legal@glass.photo.

3. How Is Information Collected?

Glass collects information about you only if we have a reason for such collection, such as to provide you with a user account, to communicate with you, or to improve our App. Information is collected in three ways:

(a) Information collected automatically through accessing the App. When you visit the App (or any website), your actions while your browse the App or access any links, directly through the App or may be tracked. We do not use cookies.

(b) Information you provide Glass. When you contact us directly, provide information for a User Account, or register for our email newsletter, we collect the PII you provide us.  We may also store all communications you have directly with us (support tickets, emails).

(c) Information obtained from outside sources. You can learn more about these practices in Section 7 below.

4. Why Is Information Collected and When is it Shared?

We use the information we collect (both Anonymous Information and PII) to operate and improve the App.

We do not share your PII with outside parties except to the extent necessary to operate our App, such as to process credit card information. We use RevenueCat and Apple to authenticate who you are and your payment information. Please click through for their privacy policies.

In the future, we may sell to, buy, merge with, or partner with other businesses. In such transactions, Anonymous Information and PII may be among the transferred assets.

Glass will not sell, license, rent, or otherwise disclose your PII except as stated herein, unless under the following circumstances: (1) you have affirmatively given your consent; (2) we previously notified you of the disclosure in this Privacy Policy or when you provided your information on the App; (3) we are compelled by law, legal process, or court order to disclose; (4) disclosure is required to identify, contact, or bring legal action against someone who may cause harm to, or interference with, Glass’s rights or property, our users, or anyone else; or (5) to respond to an inquiry, request or complaint that you have made. Glass may cooperate with Internet service providers to identify users whenever required to comply with law, to enforce compliance with this Privacy Policy or our Terms, or to protect the App, our customers and others.

5. Where is Information Stored?

Glass is working with state of the art partners to establish and protect their data storage facilities. The companies we are working with to make this possible are: Amazon AWS.

Glass uses industry standard technologies to safeguard your data (both Anonymous Data and PII) from unauthorized use and disclosure and to prohibit possible security breaches of the App. Unfortunately, no website, application, computer system or online communication is completely secure. Glass cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the App is at your own risk.

Glass will take commercially reasonable steps to use heightened security technologies to protect the transmission and storage of transactional information to the App. Such heightened security measures may include the secure transmission and encryption of all supplied sensitive financial or other transaction-related information. Glass does not handle any such information directly but uses Apple’s secure system. Check out Apple’s privacy policy here.

Unless otherwise specified, whenever you make a payment, your financial and other transaction-related information will only be used to process your transaction and will not be stored on our servers or used for marketing purposes.

Data will be maintained, processed and stored by Glass in the United States of America or other jurisdictions, as necessary, for proper delivery of the services or as required by law. PII is kept only as long as necessary to provide you with access to the App and for legitimate and essential business purposes, such as maintaining your account, and making data-driven business decisions about new features and offerings.

6. Requesting Deletion of Information and Your Rights

Upon written request Glass will provide you with information about whether we hold any of your PII. You may access, correct, or request deletion of your PII by emailing: legal@glass.photo. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.

Please note that permanently deleting your Glass User Account erases all of your information from our system. After completing this process your User Account and all its data will be removed permanently, and Glass will not be able to restore your User Account or retrieve your data in the future.

If you are located in countries that fall under the scope of the European General Data Protection Regulation (“GDPR”), data protection laws give you rights with respect to your personal data, subject to exemptions provided by law. These rights include:

Glass strives to provide these rights to all visitors and users. Please email us at legal@glass.photo with any requests, questions, or concerns.

In accordance with Article 77 of the General Data Protection Regulation, you have the right to lodge complaints about the data processing activities carried out to the UK Information Commissioner’s Office, or the data protection regulator in the country where you actually live and work, or where an alleged infringement of the GDPR has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

7. Legal Basis Under EU General Data Protection Regulation for Processing Information of EU Residents.

Where you have consented to data processing, by using this App, your consent provides the legal basis to process your PII. You may withdraw your consent at any time by emailing legal@glass.photo.

We may process your PII where it is necessary to use such PII in order to perform our obligations under any contract with you (for example, to comply with the Terms and Conditions, which you accept by browsing our website and/or in order to provide the App to you).

We may process your PII on the basis of our legitimate interests, such as providing and developing interesting features for our Users, operating and improving the App, developing new services, providing customer service, and market research. We also use your PII to keep our App safe and secure, to protect against, fraud, spam and abuse. Where we rely on legitimate interests to process your PII, you have the right to object to such processing (you can ask us to stop).  You can contact us at legal@glass.photo to object to such processing. We may also process your PII on the basis of our legal obligations.

Cookies and Third-Party Providers

Glass does not use cookies.

This Privacy Policy does not govern the privacy practices of third parties who gather information directly from you when you visit their site or app. The App may embed or contain links for third party websites. Similarly, third-party websites may embed or contain links and advertisements for the App. Glass cannot control and is not responsible for the privacy practices or content on any non- Glass websites. Glass is therefore not liable for your use of and exposure to such third-party websites and any content or advertisements they contain. You should familiarize yourself with the privacy policies and terms of use of these third parties to better understand their information management policies.

If you choose to opt in to receive communications from a third party, any information you provide to said third party, will be subject to the privacy policy of the third party. If you later decide to opt out, you should contact the third party directly.

Where permitted by local data laws, Glass may disclose or otherwise allow others to access your PII pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable law.  If we have a good faith belief that the law requires disclosure, we may disclose your PII, with or without notice to you.

8. Children and Privacy

This App is NOT directed towards children under the age of 13 in the United States and under the age of 16 in the European Union. Glass recognizes the importance of maintaining the privacy of children, especially those under the age of 16. Glass is committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. § 6501, et seq.

Except in limited circumstances allowed by COPPA, Glass does not and will not knowingly request, collect, store, maintain, or share any personally identifiable information of children under the age of 16, without first obtaining the consent of a legal guardian. In those limited instances, Glass will only collect reasonably necessary information, and Glass will not share with third parties any personally identifiable information of a child under the age of 16 without the explicit consent of a legal guardian, or as permitted by COPPA or other applicable law.

You may revoke your consent and request the removal of your child’s information at any time. If you are the legal guardian of a child under the age of 16 and discover that your child has submitted their personally identifiable information without securing your consent, Glass will use commercially reasonable efforts to remove this information. If at any point you wish to review, amend, or request the removal of your child’s information, please send an e-mail to legal@glass.photo and provide the name and account information for your child’s user account.

9. Notification of Changes

Glass may at any time and in its sole discretion, add, modify, or remove any feature, function or portion of the App, the Terms, and/or the Privacy Policy, in whole or in part, with or without notice to you, prior or otherwise. Any changes to the Privacy Policy will be effective as of the posting date. Glass will provide prominent notice on the App of any major changes to the Privacy Policy. Your continued use of the App after Glass posts any modifications to the Privacy Policy shall be deemed your explicit acceptance of those modifications and shall constitute your agreement to comply with the Privacy Policy, as modified.

10. Notice to California Users

California Civil Code Section 1798.83 permits users who are California residents and who have provided with "personal information" (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, or how the Glass reviews and processes any request from you to amend your personal information, please contact us as legal@glass.photo.

11. Contacting Us

If there are any questions regarding this Privacy Policy you may contact us using the information below.

12. Notice to EU Users

The GDPR of the European Union permits users who are residents and who have provided with personal information to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a EU resident you have the right to complain to national or local data protection offices (you can find a list here https://edpb.europa.eu/about-edpb/about-edpb/members_en) and with any questions regarding this, or how the Glass reviews and processes any request from you to amend your personal information, please contact us as legal@glass.photo.

Glass Labs Inc.
Attn: Legal Department
legal@glass.photo

Last Modification: This Privacy Policy was last modified on August 11, 2021.