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1. Please read carefully!

This glue Privacy Policy (“Privacy Policy”) describes how we (glue, “we” or “us”) collect and use information pertaining to each of our registered users (App Owners, “Business”, “User” or “You”), and Members (“Users-of-Users”, “App Users”) in connection with their access to and use of glue’s mobile apps (“glue Apps”).

The purpose of this Privacy Policy is to provide you with a clear explanation of when, why and how we collect and use your personal information, as well as an explanation of your statutory rights. This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.

Read this policy and make sure you fully understand our practices in relation to your Personal Information, before you access or use any of our Services. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately avoid or discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us at support@glue.support.

By accessing or using any of our services, you acknowledge that you have read this Privacy Policy.

2. What information do we collect?
We collect three types of information that can be found and updated on the platform (e.g. the Workspace):

• User Information- Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number) and billing details (name, physical billing address, payment method and transaction details). Only required Users’ information is collected for the purpose of connection, identification, ownership verification and payment.
• Business Information- all information provided by the App Owner regarding the Business related to the app, in order to fully utilize glue’s service – address, products and services, prices, schedule, team etc.
• Members Information- We may collect information pertaining to users of our User’s (“Club Members”, “Users-of-Users”, “Members”) – individuals that downloaded the apps and registered. This information is provided by the Members and the App Owners, or through Members’ access to and/or use of the Services only if elected so by their own free will. This information can be updated by both sides at all times.

For the avoidance of doubt, any Non-Personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.

3. How do we collect such information?

There are two main methods we use:
We collect information through the use of the Services. When a User register for our Service, or a Member download, register and use the App, we are aware of it and will usually gather, collect and record such uses, sessions and related information.
We collect information which Users provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services, and Business Information updated in the Workspace as part of the usage of the App.

4. Why do we collect such information?

We collect Information for the following purposes:

• To provide and operate the Services;
• To further develop, customize and improve our Services, based on Users’ and Members common or personal preferences, experiences and difficulties;
• To provide our Users with ongoing customer assistance and technical support;
• To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section ‎9 below);
• To create aggregated statistical data and other aggregated and/or inferred Non-Personal Information, which we may use to provide and improve our respective services;
• To enhance our data security and fraud prevention capabilities;
• To comply with any applicable laws and regulations.

We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:

• Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with our Services, to provide you with our customer assistance and technical support), or
• Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
• Our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of glue campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.

Our Services are not permitted to children under 18 years of age. No one under age 18 should provide any Personal Information to us through any of our Services. We do not knowingly collect Personal Information from children under 18. Parents and guardians should supervise their children’s activities at all times.
We also collect and use information in order to contact our users, and in order to comply with the laws applicable to us.

5. Where do we store your information?

glue’s Users’ and Members’ Personal Information may be maintained, processed and stored by glue and service providers in the United States of America, in Europe (including in Lithuania, Germany and Ukraine), in Israel, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
glue is based in Israel, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.
glue’s service providers that store or process your Personal Information on glue’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
Upon request, glue will provide you with information about whether we hold any of your Personal Information. You may access, correct or update your personal information at all times by yourself.
Please note that canceling your glue subscription does not permanently delete your glue account and does not erase all of your information from glue’s databases. You may request deletion of your Personal Information only by sending a written request to support@glue.support and receiving a written confirmation.
We will respond to your request via returned email within a timeframe imposed by local laws or a reasonable timeframe. Only once you receive a written confirmation from glue regarding your request, you can regard your data as deleted.
After completing this process, you can no longer use any of your glue Services, your User Account and all its data will be removed permanently, and glue will not be able to restore your account or retrieve your data in the future. If you contact glue Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.
glue’s data storage providers are contractually committed to protect and secure your data.
Among other things, glue adheres to the EU – US & to the Swiss-US Privacy Shield Principles, for further protecting and enhancing our users’ privacy.
Data Localization Obligations: If you reside in a jurisdiction that imposes “data localization” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.
You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America as explained above.

6. Member’s (Users-of-Users) information

glue may collect, store and process certain Non-personal and Personal Information of Members (“Members Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts or otherwise collect and manage contacts via their glue App. Such contacts are then stored with glue, on the User’s behalf.
For such purposes, glue serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation) of such Members Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Members Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Members Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of your Members’ Personal Information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
glue cannot provide legal advice to Users or their Members. However, we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User App, in accordance with the applicable laws and regulations, and that all Members carefully read those policies and make sure that they consent to them.
For more information on how Members Information may be handled by glue (which may be relevant for the specific notice you provide to and/or consent you obtain from your Members), please see Sections ‎7, ‎11 and ‎12 below.
If you are a Member or customer of any of our Users, please read the following: glue has no direct relationship with the individual Members whose Personal Information it processes. If you are a Member or customer of any of our Users and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by glue on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Members’ Personal Information, you can do so by sending a written request to support@glue.support and receiving a written confirmation. Only once you receive a written confirmation from glue regarding your request, you can regard your data as deleted.
We will respond to your request via returned email within a timeframe imposed by local laws or a reasonable timeframe.
Unless otherwise instructed by our User, we will retain their Members’ Personal Information for the period set forth in Section ‎11 below.

7. Sharing personal information with third parties

glue will not share your Personal Information with third parties (or otherwise allow them access to it) except for and only in the following manners and instances:

7.1. Law Enforcement, Legal Requests, and Duties: Where permitted by local data protection laws, glue may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.

7.2. glue Subsidiaries and Affiliated Companies: We may share Personal Information internally, for the purposes described in this Privacy Policy. In addition, should glue or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we have good faith that such change in control might materially affect your Personal Information stored with us, we will notify you via e-mail and/or a prominent notice on our Website of this event and certain choices you may have regarding your Personal Information.
Sharing of Personal Information from glue subsidiaries and affiliated companies in the European Union and Switzerland to glue’ United States subsidiary adheres to the EU-US and Swiss-US Privacy Shield frameworks.
To clarify, glue may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, glue may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.

 

8. Use of cookies and other tracking technologies

glue’s marketing team uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags, and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Users and Members with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of Members preferences and authenticated sessions, to better secure our Services, to identify technical issues, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by glue, and we, therefore, cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may adversely affect your user experience.

9. Communications from glue

9.1. Promotional Messages: We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from glue through such means.
If you do not wish to receive such promotional messages or calls, you may notify glue at any time or follow the “unsubscribe”.
We take steps to limit the promotional content we send you to a reasonable and proportionate level and to send you information which we believe may be of interest or relevance to you, based on your information.

9.2. Service and Billing Messages: glue may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User App; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you will not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a glue User (which can only be done by deleting your account – see section 5 in this document).

10. Your rights in relation to your personal information

It is imperative that you have control over your Personal Information. That’s why glue has taken the steps to enable you to access, receive a copy of, update, amend, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes.
Please note that canceling your glue subscription does not permanently delete your glue account and does not erase all of your information from glue’s databases. You can delete your information only by sending a written request to support@glue.support and receiving a written confirmation. Only once you receive a written confirmation from glue regarding your request, you can regard your data as deleted.
After completing this process, you can no longer use any of your glue Services, your User Account and all its data will be removed permanently, and glue will not be able to restore your account or retrieve your data in the future. If you contact glue Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.

11. Data Retention

We may retain your Personal Information (as well as your Members’ Information) for as long as your User Account is not permanently deleted, as indicated in this Privacy Policy.
We may continue to retain such Personal Information even after you cancel your subscription and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Members, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to information in our care. Upon a personal written request will ensure it is securely deleted.

12. Security

glue has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Users’ privacy.
Regardless of the measures and efforts that are being taken by glue, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Members’ Information or any other User Content you upload, publish or otherwise share with glue or anyone else.
We, therefore, encourage you to set strong passwords for your User Account and avoid providing anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at support@glue.support

13. Public App Content

If you upload any Content to your App and provide it in any other way as part of the use of any Service, you do so at your own risk. We advise against uploading or posting any information you do not wish to be public.
You understand and acknowledge that even after its removal by you or us, copies of User Content may remain viewable if any third parties (including any of your Members) have copied or stored such User Content.

14. Updates and interpretation

We may update this Privacy Policy as required by applicable law, and to reflect changes to our information collection, usage, and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Unless stated otherwise, our most current Privacy Policy applies to all information that we have about Users and Members, with respect to glue Apps and other Services.

Any heading, caption or section title contained herein, and any explanation is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.