Gloow - Privacy Policy

Scope

This privacy policy is an amendment to the general terms of service. It governs the processing of your personal data by Gloow, a company registered with the Belgian National Bank and Company Registry under enterprise number 0667.958.628, with registered offices at Bremenhulstraat 18, 9260 Serskamp, Belgium, Europe (hereinafter "Gloow") and the User (hereinafter "you" or "User"). The purpose of this Privacy Policy is to specify which categories of personal data we collect through your usage of the Gloow Mobile Application and which rights you may exercise in that regard.

A. Types of data we collect

In this section we will list the types of data we collect. By creating an account and using our service, the User will give his/her consent to the collection of the following data:

1) Personally identifiable information

Gloow has no intent to collect any information about your personal identity. Part of your identity is merely used for a secure and verifiable authentication process. We are using Auth0 as a service partner to secure the authentication process. They might process potentially personally identifiable data on our behalf, to guarantee secure access to the server and that other individuals can not access your data.

At a minimum our authentication requirements will be an email address to verify access to your account. In case you use any Social Authentication providers to access the service, such as Apple, Facebook or Google it is possible that some of your personally identifiable data is shared with Auth0. This may include:

• Your full name
• Your email address
• A profile picture

This id information will be used to create a more personalised experience in the application. These personal data are not persisted to our database servers. On our database servers we merely link data to your account using a UUID, which has the following format: 11bf5b37-e0b8-42e0-8dcf-dc8c4aefc000. This uuid does not contain any direct identity information but is an (in)direct link to your account that is protected by Auth0.

All users can request the removal of this personal data at any time by following the steps on the settings page, or by sending an email to info@gloow.io.

2) Information entered into the mind mapping system

The majority of data collected is whatever information you decide to enter into the mobile application. Due to the flexibility of the system many different types of information may be entered, thus making it possible, but far from necessary, that this is also personally identifiable information. Keep in mind that any information entered into the system will be (in)directly linked to your account. As stated on our Terms of Service, the User will remain the owner of his/her data at all times, and the user can request an export of his/her data and/or the removal of your data from our database servers.

All data entered into the system is stored securely and encrypted in the AWS cloud to offer protection against loss, abuse, alteration,or destruction of all (personal) data we store and process.

3) App Usage Data

The Gloow system also collects some usage information about how you interact with the system. This data is gathered anonymously and is not directly linked to your account. This information is collected to understand better how Users use the Mobile Application and the main purpose will be to improve our software and User Experience.

We may share App Usage Data with third party data processors. Specifically we are working with the following services:

• Firebase
• Google Analytics

4) App Performance and Chrashlytics Data

The final data type we collect are data about our Application performance and potential crash logs. This data is gathered anonymously and is not directly linked to your account. This information is collected to have more insights into our application performance and to be able to detect and fix possible issues quickly and effectively.

We may share App Performance and Analytics Data with third party data processors. Specifically we are working with the following services:

• Sentry
• Firebase Crashlytics

B. Your rights

Under the Applicable Data Protection Legislation, you are entitled to exercise certain rights in relation to your personal data collected and processed by us. If you would like to be supplied with further information on your rights or wish to exercise them, please write to us at info@gloow.io.

The exercise of your rights is free and will be executed within one (1) month of the receipt of your request to exercise your rights. In those cases where we deem your request to exercise your rights manifestly unfounded or excessive, we reserve the right to charge you an administrative fee for the execution of your request,

1. Withdrawal of consent

You have the right to withdraw your consent in relation to all processing activities for which you have previously given us your consent.

2. Right of access

You are entitled to request a copy of the data we process and hold on you. If we process and/or hold personal data about you, you will receive a copy of the information in an understandable format together with an explanation of why and how we hold and use it.

3. Right of rectification

You have the right to ask us to correct your personal data. This includes the right to have us correct spelling mistakes or change an address, email addresses, phone numbers, etc. Additionally, depending on the purposes of the processing, you have the right to complete any incomplete information we process or hold about you.

4. Right of erasure

You have the right to request the deletion of the personal data we process or hold on you.

5. Right to data portability

You are entitled to receive the (personal) data we process for you in a structured, commonly used, and machine-readable format.