Last Updated: May 25, 2018
Glow takes issues of privacy and the protection not only of personal health information, but all kinds of information about your private life very seriously. As discussed below we take great efforts to protect your information from disclosure, to use your information only to improve the service for you and to improve our ability to provide services to other people in a similar situation, and to assist researchers in finding better ways to improve health.
WE DO NOT SELL OR RENT YOUR PERSONAL DATA TO THIRD PARTIES. WE DON’T SHARE YOUR INFORMATION (OTHER THAN FORUM POSTS) TO SOCIAL NETWORKS OR OTHER PUBLIC OR SEMI-PUBLIC PLACES UNLESS INSTRUCTED BY YOU TO DO SO.
We only disclose your information to you or as you authorize us to (although we may include certain elements of that information in our data base on an anonymized basis). However we wish to remind you that the kind of information Glow collects is significantly more sensitive than the information you may be providing to other application providers – and you should be extra careful before instructing us to share that information with anyone else. Your menstrual cycles, fertility information and pregnancy status is much more sensitive than the number of steps you took today or where you were when you took your most recent selfie – we recognize that and recommend that you take extra care before deciding to ask us to share it with anyone.
PARTICULARLY IMPORTANT INFORMATION
Who We are: For the purpose of applicable data protection legislation, the data controller of your personal data is Upward Lab Holdings, Inc. of 555 Kearny Street, 7th Floor San Francisco, California. We are in the process of identifying and appointing a Representative in the EU, but in the meantime, our EU Representative is Ryan Ye, reachable through EURepresentative@glowing.com. Our data protection officer is Ryan Ye, reachable through GlowDataProtectionOfficer@glowing.com
Must Read Sections: We direct your attention in particular to the sections entitled “International Data Transfer” and “Your Rights”.
PURPOSES OF PROCESSING
WHAT WE COLLECT
Information You Give Us:
Glow gives you a number of options regarding what information you will give us:
• When you register to create an account with Glow and/or Glow First (whether through one of the Glow Apps or on the Internet);
• When you participate on a Forum or other communication mechanism; and
• When you update a Glow App or the Website with information relevant to your fertility or pregnancy,
When you register with Glow you will submit a variety of personal data (such as gender, age, birthdate, name, email address, mobile phone number) and as you use the Glow Apps you may submit a variety of information (such as menstrual cycle, weight, temperature, occupation, hobbies, interests, zip code, etc.) which may include sensitive personal data about personal health issues and/or information related to your past, present, or future physical or mental health condition (“Sensitive Personal Data”). You may also choose to provide us with access to certain personal data stored by third parties including social media sites (such as Facebook and Twitter) and health sites, such as Apple HealthKit and Google Fit. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. You may (and may be required to) share information about or give us access to additional third-party websites or services.
Also, when you sign up for Glow First, we may collect personal data such as credit card numbers and/or cell phone numbers, as well as other information about you necessary to ensure that a transaction is properly authorized, such as your address, zip code, and cv number (collectively, “Payment Information”). We also may retain such Payment Information (or our third party “fulfillment house”, such as PayPal, may retain such information) to facilitate future transactions. See “Controlling Your Personal Data” below if you would like us not to use that information to assist you in completing future transactions.
If you choose to participate in Glow First or become a party to the Glow Fertility Services Patient Agreement, not only may you need to provide us with Payment Information, but if you become entitled to receive a payment from Glow First, you will need to provide us with your social security number as well as information about an accredited infertility clinic and proof of medical claims showing that you are using their services. We may use that information in making filings with the IRS or relevant state taxing authorities.
User Generated Content
In addition to information about yourself, it may be possible for you to submit other content ("Content"), such as photos and other media, each of which you present through technology available through the Services, including but not limited to our forum. It is entirely up to you whether you want to submit this additional information, and whether you would like to make it available to others – although information you share on the forum will automatically be shared with others, including users of the Services and others on the internet. However, Glow has no responsibility for how people you allow to view your Content (or the public if you make any information available to the public or post on the forum) use that material, or to whom they may forward it. We urge you to be very careful when deciding to disclose your personal data, or any other information, on the forum. Such personal data and other information will not be private or confidential once it is published on the forum.
If you send or disclose any Sensitive Personal Data to us when you submit user generated content on our forum, you consent to our processing and use of such Sensitive Personal Data in accordance with this Policy. If you do not consent to our processing and use of such Sensitive Personal Data, you must not submit such user generated content to our Website.”
In each case, we will collect and record the information you have provided.
Information We Automatically Collect:
If you visit this Website, be advised that Company will maintain web logs to record data about all visitors and customers who use this website and interact with the Services and we will store this information. All web logs are stored securely and are accessible to a very limited number of employees who are required to adhere to strict guidelines regarding user data security and privacy.
Furthermore, when you use one of the Glow Apps, we may record information regarding the use of that Glow App, including your cell phone number, and if such facilities are enabled on your cell phone, your location and similar information.
Finally, in order to provide the best possible service and to allow us to make certain internal reports and make recommendations, we collect aggregate information about the use of the Service, including information about users accessing this website or using the Glow Apps, such as Internet protocol addresses, browser type, browser language, referring / exit pages and URLs, other browser history, 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, and the date and time (“Activity Information”).
When you visit the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your transactions, content you viewed, click stream information, and cookies that may uniquely identify your browser or your account. We use various technologies to collect and store information which may include sending one or more cookies or anonymous identifiers to your device. Please refer to the section on cookies below.
Information We Collect From Other Sources:
Information from Health Sites. Our Services include interfaces that allow you to connect with health sites, such as Google Fit or Apple Fit. We may add this to information we get from our Services. Please refer to the section “Information Shared with Other Systems, Such As Healthkit or Google Fit” below for more information.
HOW WE USE/SHARE YOUR INFORMATION
We may use personal data to verify your identity, verify your address, or manage risk. We may also use personal data to perform and improve our Services, contact you, conduct research, and provide anonymous reporting for medical research. For example, we may use information to provide customer service and support, process transactions, resolve disputes, collect payments, prevent illegal activities, customize the Services and recommendations, reduce risk to all parties involved in our transactions, and verify the accuracy of information.
We make your profile available to other users according to the privacy settings you set for yourself as part of your profile. Your user name will be identified to us and to any recipient of messages you send through the Services, including on forums. We also use your name, email address and other information on our system to notify you of new product releases, service notifications, and to solicit your feedback and input. In the event that we decide to allow you to submit other information about yourself, the availability of that information to other users will also be controlled by privacy settings you may set for yourself.
We share your personal data with employees and affiliates, as well as certain vendors, partners and third parties as required to offer the Services. This includes, but is not limited to, processing transactions, maintaining your account, responding to court orders and legal investigations, for litigation purposes, complying with audits or other investigations, and reporting to credit bureaus. We do not profit from your personal information and do not share your information with advertisers.
We may combine your personal data with information we collect from other companies and use it to improve and personalize the Services, content, and communications with you. We may also do so in order to improve our prediction methodologies and algorithms.
We may combine your personal data with information we collect from other users in an aggregate and anonymous format and share this anonymous data with third parties. When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We do this in order to improve the quality of the information we provide to you and to other users.
Protected Health Information
We maintain “protected health information” (as defined in the Health Insurance Portability and Accountability Act, “HIPAA”) in compliance with applicable health care privacy and security rules and our contractual obligations with our business partners and customers, including health care providers and their contractors (who are also subject to HIPAA). In the case where you affirmatively accept our Glow Fertility Program Patient Services Agreement, we act as a conduit between (a) health care providers offering fertility-related services, (b) other persons involved in the arranging, provision or financing of health care services and (c) end users such as you, and share your protected health information in connection with those services only in accordance with applicable law.
We may use personal data to deliver products, or service update notices, and promotional offers based on your communication preferences. With your consent (either in response to an email request or in certain cases, pursuant to the preferences you’ve expressed in your profile), we may send you marketing e-mails about upcoming promotions, and other news, including information about products and services that may be of interest to you. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you. We may combine your information (after it has been anonymized) with information we collect from other companies and use it to improve and personalize the Services, content and advertising. We may also do so in order to improve our prediction methodologies and algorithms.
Third Party Content
We may decide to share information about your transactions and experiences using the Glow Service (but not about your creditworthiness) to our affiliates for their everyday business purposes.
We will share your information with any party when required by law or by a government request to do so or to combat fraud or criminal activity.
CONTROLLING YOUR PERSONAL DATA
Be advised that if you send messages or post material on or forums or elsewhere containing personal data, that data may be collected and used by others. The Services provide a number of tools that you can use to control the availability of your profile and other personal data, but forum posts will be available to the general public. You can edit your profile and other data at any time through each of the Glow Apps and/or the Website.
You can terminate your account at any time, which will remove your profile and other personal data from view. Glow, however, may (but is not obligated to) keep information about you that is on its system following your termination, and your forum posts will continue to be available online. You may request complete deletion of your personal data (other than forum posts) by writing firstname.lastname@example.org. Subject to the provisions of your Glow Fertility Program Patient Services Agreement, if any, we will delete your data within 60 days of our receipt of that request. Contact Glow at email@example.com to terminate your account or for any other questions about your personal data and/or forum posts. Unless you request the deletion of your personal information and subject to applicable law, Glow maintain copies of your content indefinitely, even after you terminate your account.
INFORMATION SHARED WITH OTHER SYSTEMS, SUCH AS HEALTHKIT OR GOOGLE FIT
In addition, in the event that you use one of those services, you should be careful about allowing other applications, services or people to access your information through that service. While much information collected by those services is innocuous, people who see Glow data may be able to determine a variety of personal data, such as that you are trying to become pregnant or when you are likely to be having your period.
Glow does not use or disclose to third parties personal data or other information gained through the use of the HealthKit framework or Google Fit for advertising, other use-based data mining purposes or similar services, other than for purposes of improving health or for purposes of health or medical research.
We do not disclose any of your personal data, to any third party without your express permission (other than as provided herein or in anonymized and aggregated format), and in the case of information gained through HealthKit or Google Fit such sharing will only be for purposes of enabling the third party to provide health and/or fitness services or for medical research.
We do not sell any of your personal data, including personal data gained through HealthKit or Google Fit, to advertising platforms, data brokers or information resellers.
We do not use any of the personal data obtained through HealthKit or Google Fit for any purpose other than providing health and/or fitness services in connection with the Glow Apps.
You may decide to provide us with another person's email address so that person may be invited to join Glow or so that we may facilitate your communication with other people through the Services. You may also provide us with another person's contact information for purposes of delivering information through the Glow Apps. We use this information to contact and, if necessary, remind that person that he or she has been invited to join Glow or receive content through one of the Glow Apps. All invitees are provided with the option not to receive further invitations from Glow. We may disclose such information if required to do so in order to comply with legal process, as described above.
AUTOMATED DECISION MAKING AND PROFILING
We do not generally use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
The Service sends "cookies" to your computer or smartphone when you access the Website or use one of the Glow Apps and the Services use such cookies as described here. A cookie is a small text file recorded on your hard drive or smartphone that identifies you as a unique user and contains certain information about your particular login session and/or your use of the Services, such as the domain name of the user, your internet service provider, your operating system, and the date and time of access. We may obtain the services of outside parties to assist us in collecting and processing information collected through cookies.
You can set your browser or mobile device to notify you when you receive a cookie. This will enable you to decide if you want to accept it or not. If you do not accept cookies you may not be able to use all functionality of your browser software, the Website or the Glow Apps. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org
The Services use the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through the Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of the Website and help the content of the pages you request load quickly. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those Services.|
|Functionality Cookies||These cookies allow the Services to remember choices you make when you use the Services, such as remembering certain preferences, remembering your login details and remembering the changes you make to other parts of the Website or the Glow Apps which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the Website or use the Services.|
|Analytics and Performance Cookies||
These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. It includes the number of visitors to the Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.
We use Google Analytics for this purpose, which uses its own cookies. You can find more information about Google Analytics cookies here.
|Targeted and advertising cookies||We do not use Targeted Advertising cookies.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.|
If you would like more information about cookies associated with on-line advertising or to opt-out of third-party collection of this information, please visit the Network Advertising Initiative website http://www.networkadvertising.org. You can also disable cookies that remember your browsing habits and target advertising at you by visiting http://www.youronlinechoises.com/uk/your-ad-choice. If you choose to remove targeted or advertising cookies, you will still see advertisements but they may not be relevant to you. Also, even if you do choose to remove cookies by the companies listed at the above links, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
We may also use internet tags (also known as action tags, web beacons, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) and cookies at our Website and in the Glow Apps and may deploy these tags/cookies through a third-party advertising partner or a web analytical service partner and we or they may store the respective information (including your IP address) in a foreign country. These tags/cookies may be placed both on online advertisements that bring users to our Website and on different pages of our Website or the Glow Apps. We use this technology to measure the visitors' responses to our Website and the Glow Apps and the effectiveness of communications with users (from ourselves and third parties) including how many times a page is opened and which information is consulted, as well as to evaluate your use of our Website or the Glow Apps. A third-party partner or the web analytical service partner may be able to collect data about visitors to our and other sites because of these internet tags/cookies, may compose reports regarding our Website’s and the Glow Apps’ activity for us and may provide further services which are related to the use of the Glow Apps, our Website and the internet. They may provide such information to other parties if there is a legal requirement that they do so, or if they hire the other parties to process information on their behalf. If you would like more information about web tags and cookies associated with on-line advertising or to opt-out of third-party collection of this information, please visit the Network Advertising Initiative website http://www.networkadvertising.org. (We are not affiliated with the Networking Advertising Initiative in any way.)
THIRD PARTY SITES
The Services may contain links to other web sites, and content in the Glow Apps may be hosted by other web sites. These other sites maintain their own policies regarding cookies and the collection and use of personal data. It is up to you to review those policies yourself.
INTERNATIONAL DATA TRANSFER
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Glow Apps or Services you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We use reasonable organizational, technical and administrative measures to protect personal data within our organization. If you have any questions regarding which measures and techniques we use, feel free to contact us. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised, please immediately notify us of the problem by contacting us using the details set forth in the section titled “Additional Questions” below.
In addition, we urge you to take precautionary measures in maintaining the integrity of your data. Please be responsible in making sure no one can see or has access to your personal accounts and log-in username and password information. If you use a public computer, such as one at a library or a university, or a shared device, always remember to log out of the Glow Apps or Services.
If you use the Glow Apps or Services through your employer’s computer network a mobile device owned by your employer or through an internet café, library or other potentially non-secure internet connection, such use is at your own risk. It is your responsibility to check beforehand with each such company’s privacy and security policy with respect to Internet and mobile device use.
We cannot guarantee the identity of any other person with whom you may interact in the course of using the Glow Apps or Services, or the authenticity of any information that others may provide.
Company is not responsible for your handling, sharing, re-sharing and/or distribution of your personal health information. Moreover, if you forward personal health information electronically to another person on or off any Glow Apps or the Services, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.
We will only retain your personal data as long reasonably required for you to use the Glow Apps and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes). You may request that we delete data you have provided by sending an email to firstname.lastname@example.org. Subject to the provisions of your Glow Fertility Program Patient Services Agreement, if any, we will delete your data within 60 days of our receipt of that request.
We do not knowingly allow individual Users who are identified as located in the European Economic Area and under the age of 16 or who are identified as located outside the European Economic Area and under the age of 13 to create accounts that allow access to our secure site or that use Glow Apps, without them obtaining the prior consent of a parent or guardian.
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of Sensitive Personal Data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data from a server or business located in the European Economic Area to a server or business outside the European Economic Area. Please note that your use of some of the Glow Apps or Services may be ineffective upon opt-out.
- Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
- Amend. You can also contact us to update or correct any inaccuracies in your personal data.
- Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details set forth in the section titled “Additional Questions” below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Please contact email@example.com if you would like to receive a copy of this document showing changes from previous versions.
HOW YOU CAN CONTACT US
If you have questions or concerns regarding this policy, you should contact us at firstname.lastname@example.org