Last updated: October 1, 2022
Gluetrail Inc. (together with its affiliated companies – “Gluetrail”, “Gluetrail”, “we”, “our” or “us”) puts great efforts in making sure that the personal data processed by us is safe and used properly, and that our data practices are properly communicated to our customers, users and prospects.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use of our Services. If you are a user of the Services on behalf of any of our business customers, we suggest that you contact your account administrator with any questions.
What personal data do we collect ?
We collect and generate the following types of personal data relating to our Customers:
Website usage and device information (connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on their device;
Customer account information (contact, contractual and billing details concerning our customers, which may also contain the details of their internal focal persons who directly engage with Gluetrail concerning their organizational account, e.g., the account administrators, billing contacts and authorized signatories on behalf of the customer; as well as the customer’s needs and preferences, as identified to us or recognized through our engagement with them);
Information concerning our customers and prospects (contact and business details, our communications with such customers and prospects (correspondences, call and video recordings, and transcriptions and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement).
Personal Information collected throughout Google signup and Github signup are limited to the individual's personal email adress used during the process. This information is stored in our secured database as part of the user creation process needed to access the platform. This information can be removed at anytime upon request.
We collect such data either automatically, through the data subject’s interaction with us or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
Why do we collect personal data ?
We use Customers’ personal data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, users, visitors, prospects, ourselves and our Services.
Specifically, we use our Customers’ personal data for the following purposes:
To facilitate, operate, enhance, and provide our Services;
To train our customer and user-facing staff;
To provide our Customers and users with assistance and support;
To gain a better understanding on how individuals use and interact with our Sites and Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
To contact our Customers with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them;
To facilitate, sponsor and offer certain events, contests and promotions;
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
To comply, and maintain our compliance, with applicable laws, regulations and standards.
What are the retention periods of the personal data collected ?
We retain Customer personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services, Sites and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
When and how do we share my personal data with others?
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data for such limited purposes as determined in our agreements with them.
How do we access user or organization data
We have a strict OAuth 2 policy where customers have to explicitely grant access through an OAuth 2 Flow. The user can delete and revoke at any time this access and access will be deleted from our systems.
Do we share data with AI models
We do not unless explicitely configured to do so. Our platform is designed to ensure that no data is shared with AI platforms or any other third-party services unless you, the user, have explicitly configured it to do so. When you choose to integrate with third-party services, we strictly limit the data shared to only what you have specified in your configuration. This means you have full control over what information is shared, ensuring that your data is used only in ways you have directly authorized. We are committed to providing a transparent and user-driven experience, guaranteeing that your data privacy preferences are respected and upheld at every level of our operation.
Gluetrail AI Functions From time to time, Gluetrail may include Gluetrail AI Functions as part of the Service. This section of the Terms applies to Gluetrail AI Functions where you provide information (“Input”) and receive output generated and returned by the Gluetrail Al Functions based on the Input (“Output”, and together with Input, “Al Content”). For purposes of clarity, Output shall exclude the Service, Third-Party Services, Documentation, and Usage Information. (i) When you use such Gluetrail AI Functions, as between the parties and to the extent permitted by applicable law, you own the AI Content. You are solely responsible for your AI Content, including compliance with applicable laws and these Terms. Other users providing similar Input to Gluetrail Al Functions may receive the same or similar Output. Responses received by other users are not your AI Content. (ii) YOU UNDERSTAND AND AGREE THAT ANY INFORMATION OBTAINED THROUGH USING GLUETRAIL AI FUNCTIONS IS AT YOUR SOLE RISK. DO NOT RELY ON FACTUAL ASSERTIONS IN OUTPUT WITHOUT INDEPENDENT FACT-CHECKING. DO NOT RELY ON DESIGNS, WORKFLOWS/PROCESSES, OR CODE IN OUTPUT WITHOUT INDEPENDENT REVIEW OF FUNCTIONALITY AND SUITABILITY FOR YOUR NEEDS. NO SUCH INFORMATION, SUGGESTIONS, OR OUTPUT OBTAINED BY YOU FROM GLUETRAIL OR THROUGH GLUETRAIL AI FUNCTIONS SHALL CREATE ANY WARRANTY NOT EXPRESSLY MADE HEREIN. (iii) You may not use Gluetrail AI Functions or Output: (1) to develop foundation models or other large-scale models that compete with Gluetrail or the Gluetrail AI Functions; (2) to mislead any person that Output from the Service was solely human-generated; (3) in a manner that violates any technical documentation, usage guidelines, or parameters; (4) to make automated decisions that may have a detrimental impact on individual rights without appropriate human supervision; or (5) in a manner that infringes, violates, or misappropriates any of our rights or the rights of any third party.
Google API Services User Data Policy: Gluetrail use use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements
Business Customers: Our business customers have access to any data we process on their behalf in our capacity as a “processor” or a “service provider.”
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Gluetrail, any of our users or customers, or any members of the general public.
For the avoidance of doubt, Gluetrail may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools. We may also use HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
We also use web analytics tools, including Google Analytics. These tools help us understand users’ behavior on our Sites and Platform, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/, Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
How do we communicate with you?
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. If you are registered as a user to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, user or prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, Platform or Sites, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Gluetrail at any time by sending an e-mail to:email@example.com, changing your communications preferences in your profile settings whilst being logged as a user to our Services, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
How do we ensure the protection of personal data ?
We implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, although we make efforts to protect your privacy, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
Regarding the security measures implemented to protect personal data from any risk of violation, unauthorized disclosure or attack on their integrity, Gluetrail has deployed all the necessary means with its teams and service providers to minimize the risk of security breaches, in particular:
Gluetrail Accounts are secured by personal passwords and optional 2FAs
We strive in particular to maintain 24/7 systems monitoring in order to ensure the security of the personal data we process.
When certain services require the use of a third party (subcontractor), Gluetrail selects its service providers on the basis of strict security and confidentiality criteria previously defined with regard to the issues, and systematically requires from its subcontractors a level security that guarantees a sufficient level of protection of the personal data that they process on our behalf.
Can you object to the processing of your personal data ?
Individuals have rights concerning their personal data. Please contact us by e-mail at: firstname.lastname@example.org if you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as – to the extent applicable – the right to request access to, and rectification or erasure of your personal data held with Gluetrail, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).
We may redact from the data which we will make available to you, any personal data related to others.
Processing on Behalf of Business Customers
Our processing of personal data on behalf of our business customers as part of the Services is governed by our agreements with such customers. We process this data on behalf of our customers in our capacity as service providers (or “data processors”) to our customers. Our customers are “data controllers” (under the EU or UK GDPR and similar laws) or “business” (under the CCPA or similar laws) with respect to that data.
Our business customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using Gluetrail on the customers’ behalf or at their request have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the business customers, including specifically in the context of an employment relationship. Our business customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services.
Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Sites, Platform and/or Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at email@example.com.