Gloo Interactive Services and Assessment Privacy Statement

This Gloo Interactive Services and Assessment Privacy Statement (this “Statement”) is effective as of March 31, 2020.

This Statement describes how we, Gloo, LLC, collect, use, disclose and otherwise process your personal information when you use an online interactive service that we operate and which displays a link to this Statement (our “Services”). participate in an assessment. We offer a variety of services-additional privacy statements may apply to your use of those services.

We use the term “personal information” to mean information that identifies or is reasonably capable of being associated with you. If you are located in the European Economic Area (EEA), UK or Switzerland (collectively, “EEA+”), please also see our Supplemental EEA+ Privacy Statement. If you are a resident of California, please also see our Supplemental California Law Disclosures.

1. Consent

This section on consent does not apply if you are located in the EEA+. By using our Services, or making your personal information available to us as described in this Statement, you consent to our processing of your personal information in accordance with this Statement.

2. What Types Of Information Do We Collect?

Depending on how you interact with our Services, we may collect the following personal information about you, which we have grouped together as follows:

  • Identity Information, which includes your name, account username, and account password.
  • Contact Information, which includes your address, email address, telephone number, and communications preferences.
  • Demographic Information, which includes your age, marital status, income, or location.
  • Religious Information, which includes your religious preferences, such as what religious organization or organizations you attend.
  • Growth Signals, Views and Characteristics, which include your growth steps, assessment responses, interests, views, opinions, perspectives, traits, characteristics.
  • Technical Data, which includes your internet protocol (IP) address (a number that is automatically assigned to a device when it connects to the Internet), information about the device you use to access our Services, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and geolocation.
  • Usage Data, which includes information about how you use our Services, including the domains you visit, what features you used and for how long, the website that referred you to us, and date/time stamps.
  • Assessment Initiators. We collect the name and contact information of assessment initiators and their employees with whom we may interact.

    If you are under 13 years of age, please do not use our Services. We do not knowingly collect or maintain personal information from persons under 13 years of age. If we learn that we have collected personal information from persons under 13 through our Services, we will take appropriate steps to delete this information.

  • 3. How Do We Collect Personal Information?

    We may collect personal information about you from the following sources:

  • From your organization: Organizations engage us to provide our Services to individuals associated with them—for example, Assessment Initiators to provide a platform in which groups of individuals can share their views, or to work with individuals to improve in self-identified areas of growth. If your organization engaged us to provide our Services to you, we may receive your Identity Information, Contact Information, Demographic Information and/or Religious Information from them so that we may begin to offer our Services to you.
  • From you: If you use our Services, including by creating an account, sharing content, or requesting resources and publications from us, we receive any personal information that you voluntarily submit to us, which may include your Identity Information, Contact Information, Demographic Information, Religious Information and Growth Signals, Growth Signals, Views and Characteristics. As you interact with our Services, we will also automatically collect Technical Data about your equipment and Usage Data about your interactions with our Services. We collect some of this data by using cookies, server logs and other similar technologies. Please see the section “How Do We Use Cookies and Similar Technologies?” below for more information about how we use these tools.
  • From other users: Our Services include social media, communications and other features. We may receive personal information that other users post, publish or submit to our Services. Our Terms and Conditions here prohibit users of our Services from disclosing the personal information of others without their consent or another lawful basis.
  • From third-party databases that originally collected your personal information on the basis of your prior, informed consent. We use this information internally to be able to customize the services we provide to you, such as by offering you a resource for improving yourself in a self-identified area of growth that we believe you would benefit from.
  • From third-party social networking sites at your option: If you choose to connect your Gloo account with your account on a third-party social networking site, we will receive access to certain personal information that you shared with that social networking site. This personal information may include your Identity Information (such as name and username), and Growth Signals, Views and Characteristics (such as photos, media, likes and public posts). Please see the privacy statements of that social networking site to understand how it collects, uses, discloses and otherwise processes your personal information.
  • From publicly available sources, such as information that you or your organization make publicly available online.
  • 4. How Do we Use Your Personal Information?

    We use your personal information for the following purposes as permitted by applicable law:

  • Providing our Services, including:
  • Responding to you, including any requests, questions, comments or concerns you may submit to us.
  • Communicating with you, including to send you information regarding our Services, changes to our terms and conditions, privacy statements, marketing information, and other information according to your communications preferences.
  • Asking you to complete assessments. If your organization engaged us to administer an assessment, we may use your personal information to ask you to complete an assessment at your organization’s request. If you complete an assessment, we process the personal information you choose to provide to us to develop aggregated insights that do not contain any personal information about you or anyone else whom your organization asked to complete the assessment. We share these aggregated insights with your organization to facilitate your organization’s purposes for deploying the assessment.
  • Maintaining and improving our products and services, including to understand how users use our products, services and content, to maintain, administer, evaluate, secure and optimize our Services, and to develop new products and services.
  • Perform and enforce our contracts with you, including to exercise our rights and perform our obligations under our Terms and Conditions and any other contracts you may have entered into with us.
  • Legal Purposes. We may process your personal information we believe to be necessary or appropriate for legal reasons to: (a) satisfy in good faith any applicable law, legal process, or proper governmental request; (b) investigate any violations of our Terms and Conditions, contracts and policies and assert remedies; (c) detect, prevent, or otherwise address fraud, security or technical issues, and (d) protect against harm to the rights, property or safety of ours, our users or the public.
  • 5. How Do We Share Your Personal Information

    We may share your personal information in the following situations, as permitted by applicable law:

  • At your request. Our Services include certain social media and other features that allow you to share information with other users, persons and organizations when you use them. We provide you with notices while you use our Services that explain when one of the features you are using will result in the disclosure of your personal information to other users and parties. If the feature on our Services is a plug-in offered by a third-party social networking site (such as a third-party operated “like” button), that third party may also provide you with privacy notices that describe how your personal information is processed when you interact with that plug-in. We also provide settings that allow you to configure to whom your posts and content are available. When you use these types of features, you instruct us to disclose your personal information according to our notices and your settings.
  • Service Providers. We share your information with service providers as necessary for them to provide services to us, subject to appropriate confidentiality and data protection agreements. Service providers assist us with website hosting, data storage, data analytics, providing assessments, providing technical support, sending communications, fulfilling user requests, and other activities related to the management of our business and services.
  • To comply with laws and protect legal interests.We may share personal information for legal reasons as we believe to be necessary or appropriate to: (a) satisfy any applicable law, legal process, or proper governmental request; (b) enforce any agreement we may have entered into with you or your organization, including investigating any violations or asserting remedies; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect against harm (whether tangible or intangible) to the rights, property or safety of Gloo, our users or the public as required or permitted by law; and (e) establish or exercise our rights, defend against a legal claim, and investigate, prevent or take action regarding possible illegal activities or a violation of our policies.
  • In connection with a sale or similar transaction. We may provide personal information to a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction.
  • Other Disclosures with Your Consent. We may ask for your consent to share your information with other recipients not described elsewhere in this Statement.
  • 6. How Do We Use Cookies and Similar Technologies?

    Please find here a resource that includes definitions of some of the more technical terms used in this Section. We use cookies, browser log data, pixel tags, browser web storage and application data caches in connection with our Services to collect the Technical Data and Usage Data described in Section 2 above, which we use for the purposes set forth in Section 3 above.

    You can also delete, restrict and block cookies from being set on your device via the settings of your browser. To do so, please refer to the Help function within your browser, or you may wish to visit www.allaboutcookies.org, which contains information on how to disable cookies on a wide variety of browsers. To opt out of certain types of this targeted online advertising (sometimes called "interest-based advertising") or to learn more about it, please visit the Digital Advertising Alliance, the Network Advertising Initiative and the DAA's AboutAds program. Certain features of our Services may not work as intended if you block certain cookies that our Services use.

    7. What Rights Do You Have regarding your Personal Information?

    You may have rights under applicable privacy laws, including to access, correct, update, delete, block or limit our use of your personal information. To exercise any such rights, please contact us at privacy@gloo.us and clearly describe your request. If you are located in the EEA+, please see our Supplemental EEA+ Privacy Statement. If you are a resident of California, please also see our Supplemental California Law Disclosures.

    8. Links to Other Websites

    Our Services may contain links to other websites and services that may have privacy policies or notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through these other services. Links to other services are provided solely for convenience. Your usage and browsing on any such services is subject to their respective policies. Please review the privacy notices posted on other websites that you may access through our website.

    9. Changes to this Privacy Statement

    We may change our privacy practices and this Statement from time to time. To the extent that our Statement changes in a material way, the Statement that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent (express or implied) to the new Statement.

    We may update this Statement from time to time to reflect changes to our information processing practices. When we update our Statement in a material way, we will update the effective date at the beginning of the document. We will also provide you with notice of changes and obtain your consent to any such changes where and as required by applicable law. We encourage you to review this Statement periodically for the latest information on our information processing practices.

    10. Contact Information

    If you have any questions, comments, or complaints concerning our privacy practices, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

    Data Protection Officer 
    Gloo 
    831 Pearl Street 
    Boulder, CO 80305 
    privacy@gloo.us