PRIVACY POLICY

Last Updated: August 20, 2021

Please read the following to learn more about our Privacy Policy.

By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Your use of Glozal’s Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in our Terms of Service.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us at info@glozal.com.

Will Glozal ever change this Privacy Policy?

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Last Updated date above. Your continued use of our Services following the posting of any changes to this Privacy Policy means you consent to such changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.

What Information does Glozal Collect?

Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, this includes information you provide when you create your account, comment on a part of our website, provide your passport or identification-document, or provide us with access to your accounts on third-party sites (“Third-Party Sites”). If you choose to invest through our Site, we will collect financial information from you, such as your digital asset wallet information (including wallets you may have created through the use of our Services), financial account information and other payment information, and we may collect information to verify your income or net-worth. Please note that we do not store any card payment information, but we do store other financial information. If you choose to add an investment entity to your account, we will also collect information about the entity. The decision to provide this information is optional; however, if you decide not to register or provide such information, you may not be able to use certain features of the Services

Information Collected Automatically: Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device. For more information, please review our Cookie Policy.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

Information Collected From Other Websites and Do Not Track Policy: Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked. Remember that this is just our Do Not Track policy, and we can’t and don’t make any promises about how third parties react when you set this signal on your browser.

Testimonials: We may collect and display personal testimonials of satisfied users of our Services in addition to other endorsements. With your consent, we may post your testimonial along with your Personal Information, on the Services. If you wish to update or delete your testimonial, please contact us at info@glozal.com.

Will Glozal Share or Use Any of the Personal Information it Receives?

We do not rent or sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information with third parties as described in this below:

  • Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.
  • Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
  • Our Agents: We may employ other companies and people such as escrow agents, transfer agents, counsels, advisors, accountants, banks and other financial service providers, to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Information will be shared with such parties only to the extent reasonably necessary for them to perform services for us or on our behalf and pursuant to confidentiality obligations.
  • Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
  • Third Party Services: We may use third party services, such as Google Analytics, to grow our business, to improve and develop our Services, to monitor and analyze use of our Services, to aid our technical administration, to increase the functionality and user-friendliness of our Services, and to verify that users have the authorization needed for us to process their requests. These services may collect and retain some information about you, such as the IP address assigned to you on the date you use the Services, but not your name or other personally identifying information. We may combine the information generated through the use of these services with your Personal Information but never in a way that will identify you to any other user. Although these services may plant a persistent cookie on your web browser to identify you as a unique user the next time you use the Services, the cookie cannot be used by anyone but Google or Intercom, as applicable. These services’ ability to use and share information about your use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You may find additional information about Google Analytics at https://google.com/policies/privacy/partners/. Finally, you can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/.
  • Protection of Glozal and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with the law or in response to lawful information requests, subpoenas, court orders, or legal process from law enforcement agencies, self-regulatory organizations, state, federal and foreign regulators; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Glozal, our employees, our users, or others.

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive for the following:

  • To deliver and improve our Services;
  • To manage your account and provide you with customer support;
  • To perform research and analysis about your use of the Services;
  • To develop, display, and track content and advertising tailored to your interests on the Services and other sites, including providing our advertisements to you when you visit other sites or mobile application;
  • To diagnose or fix technology problems;
  • To automatically update the Services;
  • To verify your identify and prevent fraud or other unauthorized or illegal activity;
  • To enforce or exercise any rights in our Terms of Service;
  • To provide users with statistics on how they use the Site relative to other anonymous users; and
  • To perform functions or services as otherwise described to you at the time of collection.

Is Personal Information about me secure?

We strive to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

California Residents

California’s “Shine The Light” law permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the Personally Identifiable Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please email info@glozal.com or mail your request to: Glozal, 22 East Maxwell Dr 06107 West Hartford, CT.

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Glozal will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@glozal.com.

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

  • Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
    • Name;
    • Postal address;
    • Telephone number
    • Email address;
    • Date of birth;
    • Username and password; and
    • Other information you directly give us on our Site
  • Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:
    • IP address
    • Device identifiers
    • Web browser information
    • Page view statistics
    • Browsing history
    • Usage information
    • Transaction information (e.g. transaction amount, date and time such transaction occurred)
    • Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
    • Location information (e.g. IP address)
    • Log data (e.g. access times, hardware and software information)

How Do We Use Your Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

  • Create and manage user profiles;
  • Communicate with you to process orders;
  • Provide support and assistance for the Services;
  • Personalize website content and communications based on your preferences;
  • Meet contract or legal obligations;
  • Respond to user inquiries;
  • Fulfill user requests;
  • Comply with our legal or contractual obligations;
  • Resolve disputes;
  • To verify your identify and prevent fraud or other unauthorized or illegal activity ; and
  • To enforce or exercise any rights in our Terms of Service.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
    • Name;
    • Postal address;
    • Telephone number
    • Email address;
    • Date of birth; and
    • Username and password.
  • Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
    • IP address
    • Device identifiers
    • Web browser information
    • Page view statistics
    • Browsing history
    • Usage information
    • Transaction information (e.g. transaction amount, date and time such transaction occurred)
    • Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) — For more information, please review our Cookie Policy.
    • Location information (e.g. IP address)
    • Log data (e.g. access times, hardware and software information)
  • Examples of these legitimate interests include:
    • Operation and improvement of our business, products and services
    • Marketing of our products and services
    • Provision of customer support
    • Protection from fraud or security threats
    • Compliance with legal obligations
    • Completion of corporate transactions
  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
  • Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

  • Wallet providers;
  • Payment processors;
  • Fraud prevention service providers;
  • Analytics service providers;
  • Staff augmentation and contract personnel;
  • Hosting service providers;
  • Co-location service providers; and
  • Telecommunications service providers

We also share Personal Data when we believe it is necessary to:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
  • Protect us, our business or our users, for example to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud
  • Maintain the security of our products and services

We also share information with third parties when you give us consent to do so.

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, Glozal secures the personally identifiable information you provide in a controlled, secure environment and protected from unauthorized access. Your account is protected by password. Glozal regularly audits its system for any possible security vulnerabilities to safeguard Personal Data. Glozal protects the security of your information during transmission by using Transport Layer Security (TSL/SSL), which encrypts all information that you input. However, your password is the key to your account, and your private key or other information provided to you when you created your wallet is critical to ensuring privacy in your wallets. If you do share your password or your Personal Data with others, you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose control over your Personal Data and may be subject to legally binding actions taken on your behalf.

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email info@glozal.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by visiting your Glozal user account settings view.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by editing them on your Glozal user account settings view.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about Glozal’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Glozal and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services and providing your information, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Glozal in the U.S. and will be hosted on U.S. servers. You hereby consent to and authorize Glozal to transfer, store and process your information to and in the U.S., and possibly other countries. By using the Services, you expressly agree to allow Glozal to maintain all necessary data to meet its regulatory obligations, including but limited to the U.S. Securities and Exchange Commission, Financial Industry Regulatory Authority or any other agency authorized by law to monitor and regulate Glozal.

What If You Have Questions Regarding Your Personal Data?

If you have any questions about this section or our data practices generally, please contact us using the following information:

  • Name:
  • Physical address:
  • Email address for contact:
  • Designated representative and contact information:
    • Thibauld Favre, thibauld@glozal.com
  • Data Protection Officer and contact information:
    • Thibauld Favre, thibauld@glozal.com

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to info@glozal.com and we will try to resolve your concerns.