INFORMATION WE COLLECT
GLASSBOX collects information from end users (“End Users”) at several different points throughout the Offering. This may include traffic data including an End User’s IP address, domain server, type of computer, and type of web browser. Our GLASSBOX Solutions (as defined below) are also designed to automatically collect information about your website visits, referring and exit pages and URLs, amount of time spent on particular pages, and the sections/features of our Offering you visit/utilize. This is anonymous information that does not personally identify an End User but may be helpful for marketing purposes and/or for improving an End User’s experience in connection with our Offering.
In general, when you visit our Site or otherwise utilize our Offering you remain anonymous. That said, certain aspects of our Offering, whether deployed by others or by us, will require registration and/or the collection of information that is more personal in nature. In those cases, personal information, such as an End User’s name, address, contact information and other personally-identifiable information (“Personal Information” or “Personal Data”) may be collected from you and stored in our databases, typically when you register to the Site, request support enter into a sales promotion or otherwise interact with us (for example through the “contact us” option). It should be made clear that you have no legal obligation to provide us with any Personal Data and the submission of such information is entirely subject to your sole discretion and consent. However if you will not provide us with the required information we may not be able to provide you with the information/services requested by you.
We may also collect statistical and other data related to your use of our Offering as well as information on Offering usage patterns. This information is collected and used as non-individually identifiable information.
From time to time, GLASSBOX grants certain of its enterprise clients a license or other rights to GLASSBOX’s proprietary software products and solutions (the “GLASSBOX Solutions”). Through their use of these GLASSBOX Solutions and/or through other means, enterprise clients of GLASSBOX may get access to, collect and use: (i) End User non-personally identifiable information; and (ii) End User Personal Data.
The GLASSBOX Solutions enable our enterprise clients to deliver more relevant advertising and content to consumers across digital channels, including desktop and mobile channels, by gathering data about those End Users’ visits to, and use of, our enterprise clients’ digital properties. These clients have their own policies that govern how they collect, use, and share data, even when such collection and use may be carried out, directly or indirectly, by GLASSBOX from time to time. Please consult the privacy policies of the websites you visit and apps you use to become familiar with their privacy practices.
HOW WE/ENTERPRISE CLIENTS USE INFORMATION
We use information which does not identify individual End Users for purposes of analyzing trends, administering our Offering, improving our services, and to gather demographic information about our End User base as a whole. There are also times when we will combine such information with additional non-personal or de-identified information we obtain from other companies as well as End User Personal Data, in order for our enterprise clients to market directly to a certain person subject to requirements of applicable law. We typically analyze this information and organize it into user groups and audiences, based on factors such as age, gender, geography, interests and online actions. We and our enterprise clients then use these user groups and audiences, along with information about the possible relationships among different browsers and devices, to design and deliver customized advertising campaigns or other relevant content. This is often referred to as Interest-Based Advertising. To enable the foregoing, the GLASSBOX Solutions use technology including browser cookies, device identifiers, and other similar technologies to recognize a particular browser or device over time, to predict possible relationships among different browsers and devices and to then relay this information to our servers.
We also compile and store data and information and generate reports related to our End Users’ access to and use of our Offering.
To the extent required under applicable data processing laws and regulations, any Personal Data that we collect will be stored in our database and will be used in accordance with such applicable laws and regulations.
We do not share, distribute, sell or rent any of your Personal Data with/to third parties, including our enterprise clients, except in the following circumstances:
- If the information is required by law in order to prevent, investigate, or take action regarding illegal In addition, we will share information in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights or defend against legal claims;
- If we and/or our enterprise clients have your permission to do so.
Any data processing performed by any third party with whom we have provided End User information (either Personal Data or non-Personal Data) will, if and when required by law, be governed by a data processing agreement in the form required by law, preserving your statutory data protection rights.
GLASSBOX retains the End User data described above which is collected through our GLASSBOX Solutions for purposes of Interest-Based Advertising for up to twenty-four (24) months from the date of its collection.
GLASSBOX may share information internally within our family of companies or with third parties for purposes described in this policy. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this policy. We utilize standard contract clauses approved by the European Commission, adopt other means under European Union law and obtain your consent to legitimize data transfers from the EEA to the United States and other countries.
SOCIAL MEDIA WIDGETS
Information collected from End Users of the GLASSBOX Offering, including such End User Personal Data, may be transferred as part of or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares or stock and/or assets or other corporate change, including, during the course of any due diligence process. By making available your data through the Offering in any manner, you agree that your information may be transferred to third parties under such or similar circumstances.
At any time, you have the ability to opt out of receiving marketing communications from GLASSBOX, but you may not opt out of administrative emails. You can opt out by either changing your e-mail preferences or using the link provided at the bottom of each email message or through any other means that is made available to you.
We do not send emails to anyone without permission (which permission may have been given to us and/or one of our enterprise clients), and we do not sell or rent email addresses to any unauthorized third party. This does not mean that we can prevent spam from happening on the Internet. If you believe that you have received an unsolicited email from us, please contact us at the e-mail below and we will investigate.
Our Site may have links to the sites of other companies, including those of our enterprise clients. We are not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies by visiting their respective websites, apps, etc.
POLICY TOWARDS CHILDREN
GLASSBOX does not knowingly collect personal information from minors who are under the age of 16 through the Websites and/or the Services. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his/her consent, then he or she should contact GLASSBOX at described below. If we become aware that a child under the age of 16 has provided us with personally identifiable information, we will delete such information from our files. Further, the Children’s Online Privacy Protection Act (“COPPA”) requires parental consent for collection of data from children younger than the age of 13 years old. For tips on protecting children’s privacy online, generally, please view the U.S. Federal Trade Commission (“FTC”) website at http://www.ftc.gov/privacy/privacyinitiatives/childrens.html.
We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, due to the nature of Internet communications and evolving technologies, unauthorized entry or use, hardware or software failure, and other factors, the security of End User information may be compromised at any time. No method of transmission over the Internet, or method of electronic storage, is 100% secure.
Therefore, we cannot guarantee the absolute security of Personal Data and disclaim any assurance that such information will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
CALIFORNIA PRIVACY RIGHTS
If an End User is a California resident, California Civil Code Section 1798.83(c)(2) permits such individual to request information regarding the disclosure of his/her information by GLASSBOX to third parties for such third parties’ direct marketing purposes. To make such a request, please send us an email to firstname.lastname@example.org.
LAW ENFORCEMENT & HARM
GLASSBOX may preserve or disclose an End User’s information if we believe that such preservation or disclosure is reasonably necessary to comply with the law, a regulation, or a legal request by law enforcement or the government. We may also preserve or disclose your information to protect the safety of any person or the public, to prevent or address fraud, to handle security within the Services, to handle a technical issue, to protect our rights or property, to protect the rights or property of a third party, or to prevent or stop any illegal or unethical activity.
UPDATE/DELETE USER INFORMATION; OPTING-OUT
You can write to us at any time to obtain a copy of your information and to have any inaccuracies corrected or if you no longer desire to use any of GLASSBOX’s Services (in which case we will endeavor to remove your personal data provided to us). Where appropriate, you may have your Personal Data erased, rectified, amended or completed. In order to contact us regarding your information please e-mail email@example.com. GLASSBOX shall also make available to its End Users other opt-out mechanisms relating to its collection and use of your data as it is required to do in accordance with applicable laws and regulations.
Last updated: May 2018