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:
"Location Data" is information that is derived from your GPS, Wi-Fi, compass, accelerometer, IP address, or public posts that contain location information. Location information will be disclosed (either to us, to other users, or both):
when you use location-based features, i.e. when you share your location with other Glamster users; and
when you access Glamster, as we derive location information from your IP address, device, or internet service to prevent multiple or fraudulent log-ins to your account.
"Log Data" is information that we automatically collect when you use Glamster, whether through the use of cookies, web beacons, log files, scripts or ETags (as explained in more detail in our Cookies Policy), including:
technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access Glamster, your IP address and your device’s version and identification number;
metadata, which means information related to items you have made available through Glamster, such as the date, time, or location that a shared photograph or video was taken or posted.
"Non-Personal Information" is any information that is not reasonably practicable to directly or indirectly identify you.
"Personal Information" is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you. We set out examples of Personal Information (and how we collect such Personal Information) in"How do we use your information"below.
"Shared Information" is information about you or relating to you that is voluntarily shared by you on Glamster. Shared Information may include postings that you make on Glamster (including your public profile, photos, videos, and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using Glamster share about you.
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:
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:
government, public, regulatory, judicial and law enforcement bodies or authorities: there are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, such as a court order, subpoena or other legal processes, to enforce our terms, address issues relating to security or fraud, or protect our users and provided the requesting entity has valid jurisdiction to obtain your personal information;
related group companies: we share your Personal Information within our group of companies (and all related group companies may only use your personal information in accordance with this policy), including GlamsterLtd. (located on the Marshall Islands),for the purpose of:
providing Glamster to you, assisting us in carrying out the purposes set out under the "How do we use Your Information" section above, and carrying out our obligations and enforcing our rights under the Glamster Terms of Service or this Privacy Policy; and
in the event of an internal restructuring of our or our affiliates businesses, or the sale of Glamster or any of its assets to a third party, the entity that consequently operates Glamster may be a different entity to us and we will transfer your information accordingly so that your service can continue;
service providers: service providers supplying services to support, improve, or promote other products or features through our services, including the following service providers:
Providers of Translator APIs and related cloud services to provide in-app multi-language functionality.
Service provider to help speed up content delivery to you in your region using acceleration points and content delivery networks.
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;
Glamster Official Accounts and Mini Program operators, other services via which you choose to use Glamster Login for third-party apps, if you elect to follow or use the relevant Official Account / Mini Program/ Glamster Login for third-parties;
a third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with this Privacy Policy.
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:
you believe that it is no longer necessary for us to have your Personal Information;
we obtained your consent to process the Personal Information and you withdraw that consent (and we have no other grounds for processing the Personal Information);
you believe we are unlawfully processing your Personal Information; or
you are or were under the age of 16 when we collected the Personal Information and we can verify your age.
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:
you believe the Personal Information is not accurate (for the period it takes for us to verify whether it is accurate);
we wish to erase the Personal Information as the processing we are doing is unlawful (but you want us to retain the Personal Information and just store it instead); or
we wish to erase the Personal Information as it is no longer necessary for our purposes (but you require it to be stored for the establishment, exercise or defence of legal claims).
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