Updated: January 1st, 2024
1.1 We are committed to safeguarding the privacy of our website visitors and GlassFrog users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of website visitors and GlassFrog users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 The GlassFrog service incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive some types of emails. You can access these controls from your GlassFrog profile.
1.5 In this policy, "we", "us" and "our" refer to the providers of the GlassFrog software platform.
2. How we use your personal data
2.1 In this Section 2 we have set out:(a) the general categories of personal data that we may process;(b) the purposes for which we may process personal data; and(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our production data and analytics tracking systems. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper and secure administration of our website and service OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information contained in any inquiry you submit to us regarding services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent OR your directly communicated interest in the relevant services.
2.5 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships OR the performance of a contract between you and us.
2.6 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your payment identification data and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us.
2.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 Financial transactions relating to our website and services are handled by our payment services provider, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/us/privacy
3.3 Upon your instruction only, we may disclose your personal data to a Holacracy Provider (list found at: https://www.holacracy.org/providers
) determined most appropriate for your need, language, and region.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Sub-processors and international transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We have operations in the United States and Israel. The European Commission has made an "adequacy decision" with respect to the data protection laws of Israel. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses, which may be obtained by contacting us at firstname.lastname@example.org.
4.3 The hosting and backup facilities for our website are situated in Ireland, and do not require transfer of personal data outside of the EEA.
4.4 We employ a number of third party data processors (listed in Section 4.5) situated in the United States, United Kingdom, Israel, and throughout the European Union. Transfers to these processors will be protected by appropriate safeguards such as standard data protection clauses, binding corporate rules, or other regulation-compliant means. We will take reasonable and appropriate steps necessary to ensure that all third parties engaged as sub-processors are processing the personal information we entrust to them in a manner that is consistent with the requirements of the GDPR and other applicable privacy regulations.
4.5 Third party processors:
5. Retaining and deleting personal data
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We will notify you of significant changes to this policy by email or through the GlassFrog software.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:(a) the right to access;(b) the right to rectification;(c) the right to erasure;(d) the right to restrict processing;(e) the right to object to processing;(f) the right to data portability;(g) the right to complain to a supervisory authority; and(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:(a) consent; or(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others, or in circumstances where the retrieval of such data would pose an undue burden on the data processor.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. The contact information of our EU Representative may be found in Section 13.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.7.13 You may exercise any of your rights in relation to your personal data by written notice to at email@example.com.
7.14 In addition to the rights previously listed in this section, if you are a “consumer” as defined by the California Consumer Privacy Act of 2018 (“CCPA”), you have these specific rights as detailed in that regulation with respect to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household:
(a) The right to request the categories, specific pieces, categories of sources, or the business or commercial purposes for collection of such information (see Section 2) and the categories of third parties with whom the business shares such information (see Section 4.5).
(b) The right to request the deletion of any personal information that we have collected or retained except where otherwise required or excepted by law. You, or a person or business entity registered with the California Secretary of State that you authorise to act on your behalf (an “authorized agent”) may exercise any of these rights by contacting us at firstname.lastname@example.org
The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorised representative of that person. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will depend on the type, sensitivity, and value of the information, including the risk of harm to you posed by any authorised access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.We will not discriminate against you for exercising any of your CCPA rights.
7.15 GlassFrog will not sell your personal information.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
(a) recognize your browser and user session
(b) keep track of what pages you have visited
(c) store your user preferences
(d) perform analytics to help us make our service better, and to(e) assist with administration and security for our website and software
10. Cookies used by our service providers
10.2 We use Hotjar and Heap Analytics to analyse the use of our website. They gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website (see Section 2.2).
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Our details
12.1 This website is owned and operated by GlassFrog LLC.12.2 We are registered in the state of Delaware as entity number 7141180, and our registered office is at 108 Lakeland Ave, Dover, DE 19901.12.3
You can contact us:
(a) by mail, at:GlassFrog LLC, 2810 N Church StPMB #33583Wilmington, DE 19802-4447, US;
(b) using our website contact form: https://www.glassfrog.com/contact;
(c) by email, at email@example.com
13. EU Representative
13.1 Our EU Representative's contact details are:
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative