Privacy Policy

May 20, 2020

GENERAL INFORMATION

Welcome to Glamster!

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

The use of our services (being the Glamster mobile app, the website www.Glamster.me, or any third-party platforms through which Glamster is provided) (together, "Glamster") involves the processing of your Information.

This Privacy Policy explains the when, how, and why when it comes to the processing of your Information in connection with Glamster, and sets out your choices and rights in relation to that information.

By using Glamster you agree to the processing of your Information in accordance with this Privacy Policy. If you do not agree to the processing of your Information in the way this Privacy Policy describes, please do not provide your Information when requested and stop using Glamster.

CONTACT

In this Privacy Policy, "we", "our", or "us" refers to:

Glamster Ltd

TRUST COMPANY COMPLEX
AJELTAKE ROAD
AJELTAKE ISLAND
MAJURO
MARSHALL ISLAND
MH 96960

If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Information, please contact our Data Protection Officer via email at[email protected].Please note that if you are a resident in the European Union you have the right to lodge a complaint with your country’s data protection authority.

SCOPE AND APPLICATION OF THIS Privacy Policy

Please note that this Privacy Policy does not apply to information that you choose to disclose or submit to:

a) services other than Glamster (such as other products or services supplied or operated by us or our affiliates), that do not expressly state that this Privacy Policy applies;

b) any third party services (including any third party websites) that you may access through Glamster; or

c) companies or organizations that advertise products or services on Glamster.

If you are using Glamster on behalf of a company, partnership, association, government or other organization (your "Organization"), you agree to notify your Organization’s relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time ("Connected Persons") of the collection of their Personal Information, and you agree to obtain your Connected Persons’ consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. When this Privacy Policy refers to "you" or "your" this includes you and any Connected Persons. If you or any Connected Persons would like to request your personal information be removed from our database, please contact us at [email protected]

What information do you need to provide Glamster?

This section describes the different types of personal information we collect from you and how we collect it. We process different categories of information and data - these are set out below:

References to "Information" in this Privacy Policy mean both Personal Information and Non-Personal Information.

HOW DO WE USE YOUR INFORMATION?

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (EEA), it also identifies the legal basis under which we process your data:

Information

Purpose of Processing

Registration Data and Log-in Data.Your user name (user alias / Nickname), mobile phone number, and IP address.


Legal Basis (EEA): Necessary to perform our contract with you to provide your Glamster profile and provide Glamster services.

  • to set up and log in to a user account on Glamster;

  • to notify you about changes to Glamster;

  • to facilitate communication;

  • to provide you with user support;

  • to enforce our terms, conditions, and policies;

  • to send and receive audio messages, text messages and video files using Glamster;

  • to send and receive Cryptocurrencies like Bitcoin, Ethereum or GLAM using Glamster;

  • to communicate with you;

  • to provide personalized help and instructions;

  • to better understand how you access and use Glamster;

  • to develop new and improve existing services;

  • to provide language and location customization;

  • to protect any rights, property or safety of ours, our affiliate companies, or other users of Glamster; and

  • to administer Glamster and for internal operations, including troubleshooting, data analysis,


User Profile Search Data. Record of search inquiries.


Legal Basis (EEA): Necessary to perform our contract with you to provide efficient access to your Glamster activity.

to provide quick access to previous searches.

Shared Information - Profile Data

Any information that you include in your publicly-visible Glamster profile, which may include your user name and photo.


Legal Basis (EEA): Necessary to perform our contract with you to provide your Glamster profile and provide Glamster services.

  • to provide personalized help and instructions;

  • to provide language and location customization;

  • to develop new and improve existing services;

  • to better understand how you access and use Glamster;

  • to maintain your Glamster account in accordance with your instructions and requests.


Shared Information – Profile Media. This comprises all of the information you make available to other users via Glamster, comprising:

  • Glamster group posts and responding to other users’ Glamster messages; and

  • information made available by another user about you via their use of Glamster – for example, any Shared Information that others using Glamster make available about you via Glamster group chats, and communications they make to you and others using Glamster.


Legal Basis (EEA): Necessary to perform our contract with you to provide your Glamster profile and provide Glamster services.

  • to administer the Glamster platform;

  • to provide personalized help and instructions;

  • to provide language and location customization;

  • to develop new and improve existing services;

  • to maintain your Glamster account;

  • to better understand how you access and use Glamster.


Chat Data. Content of communications between you and another user or group of users. This is stored on your device and the devices of the users that you have sent communications to. We do not permanently store this information on our servers and it only passes through our servers so that it can be distributed to the users you have chosen to send communications to.


Legal Basis (EEA): Necessary to perform our contract with you to provide the chat services of Glamster.

to facilitate delivery of communication to another user.

Contacts List. Your on-device contact list.


Legal Basis (EEA): Necessary to perform our contract with you to provide Glamster and connect you with your friends.

to connect you with other Glamster users using the "Recommended Friends / Invite Contact" function.

Log Data. See the definition above.


Legal Basis (EEA):It is in our legitimate interest to ensure the security of our services, manage registrations, and improve our services.

  • to better understand how you access and use Glamster;

  • to administer Glamster;

  • for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management.

Customer Support Information. Any information that you provide to our customer support team.


Legal Basis (EEA):Necessary to perform our contract with you to provide and support Glamster.

  • to investigate your support issue.

Surveys. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a service provider to conduct these surveys and this will be notified to you prior to you completing the survey.


Legal Basis (EEA): We collect this information with your consent.

  • to better understand how you access and use Glamster;

  • to provide personalized help and instructions;

  • to develop new and improve existing services;

  • to improve Glamster and respond to customer requests and preferences.

Contest Information.Any information that you provide to us in submitting an entry to a contest offered on Glamster.


Legal Basis (EEA):Necessary to perform our contract with you to validate contest entry and award prizes.

  • to facilitate your participation in the contest;

  • to award prizes, if applicable.

Pseudonymized and Aggregated Data.


We pseudonymize and aggregate certain Personal Information to improve our services.


Legal Basis (EEA): It is in our legitimate interest to ensure the security of our services, manage registrations, and improve our services.

  • Analysis of what features or actions are taken within the app in order to improve the app experience

  • Fraud detection and account safety analysis

  • User demographic analysis on items such as region, phone model, operating system platform, system language, and Glamster version in order to better understand how our users are using Glamster

  • Web and account traffic statistics of what content and services are used when users access third-party services on the Glamster Open Platform as a method for informing third-party service providers basic analysis of how their service is being used by Glamster users

WHO DO WE SHARE YOUR DATA WITH?

We will not transfer your Personal Information to any other third parties except as specified below, or in circumstances where you consent to such transfer.

Only where necessary will we share your information with selected recipients who have a legal basis and valid jurisdiction to request such data. These categories of recipients include:


Any third party (selected by us) with whom we share user data is required to provide the same or equal protection of user data as stated in this policy and is prohibited from retaining, using, or disclosing your information except as necessary to provide services to us;

SHARED INFORMATION

Glamster enables certain information to be shared publicly with your Glamster contacts and other users of Glamster. At any time you can hide your profile from public view and search by unchecking "allow find by phone number" in your account settings. This means that other users of Glamster will not be able to find you. We refer to this type of information above as Shared Information. Shared Information will remain publicly-available for so long as you or a user that has shared such information retains it. Even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.

Where you have requested that we erase your Personal Information that we have made public and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the Personal Information or providing links to the Personal Information to erase it too.

Please consider carefully what you post and communicate through Glamster. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in Glamster.

COMMUNICATIONS FROM US

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend Glamster for maintenance, or security, privacy, or administrative-related communications). We send these to your email address or via SMS. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to Glamster.

SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as "sensitive" and is subject to stricter regulation than other types of Personal Information.

Please note that content and information that you input to Glamster, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

Before communicating any Personal Information of a sensitive nature within Glamster, please consider whether it is appropriate to do so.

By posting any Personal Information of a sensitive nature within Glamster, you are consenting to such information being available within the controls you have selected (for example, available to the audience of users you select as being capable of viewing your post or profile information).

AGE RESTRICTIONS

Glamster is not intended for persons under the age of 18. Persons under the age of 18 must not use Glamster for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect Personal Information from any children under the age of 16 without such consent. Please contact our Data Protection Officer if you believe we have any Personal Information from any children under the age of 16 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.





WHERE DO WE PROCESS YOUR DATA?

GlamJet Ecosystems operates around the world. The Personal Information that we collect from you will be transferred to, stored at, or processed in the AWS Network(as data processor). “AWS Network” means AWS’s data center facilities, servers, networking equipment, and host software systems (e.g., virtual firewalls) that are within AWS’s control and are used to provide the Services.

Our engineering, technical support, and other teams that support the supply of Glamster to you are based in our offices around the world and may have incidental access to certain of your data in order to provide the service (for example, in order to fix technical issues that you report). We rely on the European Commission’s model contracts for the transfer of personal data to such third countries (i.e., the standard contractual clauses), pursuant to Decision 2001/497/EC (in the case of transfers to a controller) and Decision 2010/915/EC (in the case of transfers to a processor.

SECURITY OF YOUR PERSONAL INFORMATION

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

HOW LONG DO WE KEEP HOLD OF YOUR DATA?

We will retain your Personal Information as set out in the following table, except where we are otherwise required to retain such data in accordance with the law. Should you or we terminate your account for any reason, we will take steps to ensure that your Personal Information is no longer available through Glamster, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.





Information Type

Retention Period

Registration data

Until such time as you instruct Glamster to delete your account or you have not logged in for 180 days. Your account will be permanently deleted within 60 days of both verifications of account ownership and the account deletion request.

Login data

Information is retained for a period of 3 months from the date of such login.

User profile search data

Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier.

Profile data and profile media (viewable by all users)

Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).

Profile data (viewable upon friend verification)

Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).

Additional account security

Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).

Chat – non-persistent and semi-persistent communication between users

Data is retained for a period of 120 hours from the time of the relevant interaction and then permanently deleted.

Chat - media such as images, video, audio, and files

Data is retained for a period of 72 hours from the time of the relevant interaction and then permanently deleted.

Contacts list

Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier.

Location-based services and Location-based media

Data is retained for a period of 72 hours from the time of the relevant interaction and then permanently deleted.

Group Chats -- data and media

Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).

Provision of third party products and services

Until such time as you instruct Glamster to delete your account. Your account will be permanently deleted within 60 days of both verifications of account ownership and the account deletion request. Please note that the information disclosed to the third party is controlled by them. We will use reasonable efforts to seek that they delete such information when we do.

Information provided to customer service

Until such time as you instruct Glamster to delete your account. Your account will be permanently deleted within 60 days of the account deletion request.

Metadata / Log Data

Data is retained for 3 months from the date of log in and then permanently deleted.

Device Data

Until such time as you instruct Glamster to delete your account. Your account will be permanently deleted within 60 days of the account deletion request.

Cookies

Data is retained for 3 months from the date of log in and then permanently deleted.

If we are required to retain your information beyond the retention periods set out above, for example, to comply with applicable laws, we will store it separately from other types of personal information.

HOW CAN I EXERCISE MY RIGHTS OVER MY DATA?

Some countries' laws grant specific rights to users of Glamster, which are set out in this section. The following section applies only to persons that are resident in the European Economic Area.

You have certain rights in relation to the Personal Information we hold about you. Some of these only apply in certain circumstances as set out in more detail below.

We set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances, such as where the request involves substantial volumes of information or is otherwise complex).

To exercise any of your rights, please complete therequest formand follow the steps for submission.

Access & Correction

Upon request, Glamster will provide you with information about whether we hold any of your personal information. You also have the right to access personal information we hold about you, how we use it, and who we share it with. You also have the right to correct that information.

You can access and correct your personal information by logging into your Glamster account at any time.

If you believe we hold any other personal information, or you want to correct information that you are unable to correct using your account, please complete the request formhere. We may not be able to provide you with certain Personal Information if providing it would interfere with another’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person).

With respect to correction requests, where we agree that the Personal Information is inaccurate or incomplete, we will try to tell any third party to whom we have disclosed the relevant Personal Information so that they can rectify the Personal Information too.

Erasure

You can delete your account, or remove certain personal information, by logging into your Glamster account and following the account deletion instructionshere. If there is any other personal information you believe we process that you would like us to erase, please complete the request formhere.

You may request that we erase the Personal Information we hold about you in the following circumstances:

Also, note that you may exercise your right to restrict our processing your Personal Information (as described below) whilst we consider a request to erase your data.

Please note, however, that we may retain the Personal Information if there are valid grounds under law for us to do so (e.g., for the defense of legal claims, freedom of expression, or some other legal obligation) but we will let you know if that is the case.

Where you have requested that we erase your Personal Information that we have made public and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the Personal Information or providing links to the Personal Information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the Personal Information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Personal Information, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defense of legal claims or for another’s protection).

Where we agree to stop processing the Personal Information, we will try to tell any third party to whom we have disclosed the relevant Personal Information so that they can stop processing it too.

You may request we stop processing and just store the Personal Information we hold about you where:

Portability

You have the right to receive a copy of certain Personal Information we collect from you. This comprises any personal information we process on the basis of your consent (e.g., voluntarily-provided profile data, content posted to group chats) or pursuant to our contract with you (e.g. profile data).

You have the right to receive this information in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer that personal information to another party. You can exercise your right to export your data by following the instructionshere.

If you wish for us to transfer the Personal Information to a third party, please ensure you detail that party. Note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Information or its processing once received by the third party. We also may not provide you with certain Personal Information if providing it would interfere with another’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Objection

You may object to our use of your Personal Information if we use your information on the basis of our legitimate interests (such as when we use your personal information for your account security, such as to prevent malicious log-ins). If you object to such processing, please review and submit the formhere, providing detailed reasons.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us by following the instructions set outhere.

HOW WILL WE NOTIFY YOU OF CHANGES?

We may from time to time revise or add specific instructions, policies, and terms to this Privacy Policy. These instructions, policies, and terms form part of this Privacy Policy.

Whenever we make any changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link and notify you via Glamster or other means before the change becomes effective.

Last modified: 2020-05-20