Privacy Policy

GLUINO Privacy Policy

Last updated: July 2024

This application is powered by Gluino, Inc., dba: GLUINO, a Delaware corporation (together, "GLUINO"), and this Privacy Policy describes the privacy practices of GLUINO. References in this Privacy Policy to "we," "us," or "our" mean GLUINO. This Privacy Policy does not apply to any mobile applications, websites, or other online services that do not link to this policy.

To provide Services through GLUINO, and continue to make them better, GLUINO ("we", "GLUINO") collects information from you. If you're a resident of California or visiting us from the Non-European Economic Area ("EEA"), you should read this policy and the applicable sections below. This Privacy Policy explains how GLUINO collects, stores, uses, transfers, and discloses your information.

GLUINO reserves the right to revise this Privacy Policy. We will give you notice by posting the revised Privacy Policy on our Website and updating the "Last Updated and Effective" date at the top of this Privacy Policy; we may also notify you in other ways, such as through the contact information you have provided. Any changes to this Privacy Policy will be effective immediately on posting the updated Privacy Policy unless otherwise stated or as required by applicable law (for example, notice and opt-in or opt-out consent may be required). By continuing to use our Services, you agree to the revised Privacy Policy to the fullest extent permitted by applicable law.

Please also review the <a href="/terms">Terms of Service</a>, which also apply to use of our Services.

1. Information Collection

Information collected in connection with your use of GLUINO may include:

Information you provide, such as:

Contact information, such as your first and last name, email address, street address, and phone number.
Any information, queries, requests you make of GLUINO (together "Queries").

2. Cookies and Other Information Collected by Automated Means.

We, our service providers, and other third parties may automatically collect information about you, your computer or mobile device, and activity occurring on or through the GLUINO. These parties may collect this type of information over time and across third-party applications, websites, and/or services and may use cookies, web beacons, and other technologies to collect this information. The information may include:

Information about your device's hardware, such as model and screen resolution
Information about the software on your device, such as your browser type
Unique identifiers associated with your device, such as device identifier (e.g., Google Advertising ID or Apple ID for Advertising)
Information about the network to which you are connected and inferences we may draw from it, such as your IP address and general location information such as city, state or geographic area
Information about your use of and actions on GLUINO, such as items you viewed, how long you spent on a certain item, navigation paths between items or actions, information about your activity on GLUINO, links you click, access times, and length of access, if applicable

Please see the "Targeted Online Advertising" section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

How We Use Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate GLUINO. We use your personal information to:

Provide, operate, and improve GLUINO, including to develop new products and services
Provide the services you request
Communicate with you about GLUINO, including by sending you announcements, updates, security alerts, and support and administrative messages
Personalize your experience with GLUINO and our communications
Provide support and maintenance for GLUINO, including by responding to your requests, questions, and feedback

To send you marketing and promotional communications. Company may send you marketing communications. Please see the "Your Choices" section below for information about your choices regarding marketing communications.

To display advertisements. We work with advertising partners to display Company’s advertisements online. These advertisements are delivered by our advertising partners and may be targeted based on your use of GLUINO or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled "Targeted online advertising."

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; (b) protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

4. How We Share Personal Information

Service Providers. We may engage other companies and individuals to perform certain business-related functions on our behalf. Examples may include providing technical assistance, payment processing, billing, email management, customer service, marketing assistance, order fulfillment, delivery services, and reservation and online ordering systems. We authorize these parties to use personal information only as necessary to perform their functions.
Business Transfers. In connection with or during the negotiation of a financing, merger, acquisition, dissolution or similar corporate event, or the sale of all or some of GLUINO's or Company's assets, the information that GLUINO or Company, as applicable, have collected, including personal information, may be transferred as a business asset. If the company, business, or assets are acquired by another company, the acquiring company will possess the personal information that GLUINO or Company, as applicable, collected and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.
Third Parties Providing Services on Our Behalf. We use third parties to perform certain services on our behalf, such as hosting the Site or Site features, providing website usage analytics, fulfilling orders, processing payments, sending email or other communications, providing marketing assistance and data analysis or enhancement, running promotions, or performing other administrative services. We may share information about you with these third parties to allow them to execute, deliver, or improve the services that they provide for you and for GLUINO.
1. OPENAI.COM. Gluino is an interface that interacts with OPENAI.COM to facilitate the use of OpenAI in a secure manner.
 - NO PERSONAL INFORMATION IS EVER EXCHANGED WITH OpenAi.
2. By utilizing GLUINO, you will also be subject to OpenAi's terms and conditions (<a href="https://openai.com/policies/terms-of-use/">https://openai.com/policies/terms-of-use/</a>) as well as its privacy policy (<a href="https://openai.com/policies/privacy-policy/">https://openai.com/policies/privacy-policy/</a>)
3. We use Stripe Payments, Inc. ("Stripe") as its third-party electronic payment processing provider for payment services (e.g. card acceptance, merchant settlement, and related services) ("Payment Services") for payments related to the Service. By making use of the Payment Services on the Service, you agree to be bound by Stripe's terms and conditions (available at <a href="https://stripe.com/us/terms/">https://stripe.com/us/terms/</a>) as well as its privacy policy (available at <a href="https://stripe.com/us/privacy/">https://stripe.com/us/privacy/</a>) and hereby consent and authorize us to delegate the authorizations and share the information you provide to us with our third party electronic payment processing provider(s) to the extent required to provide the Payment Services to you.
4. We use Google Analytics. Google Analytics uses cookies and similar technologies to collect and analyze information about the use of the Website and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. For information from Google about opting out, click here, and to download the Google Analytics opt-out browser add-on from Google, click here.
 - T/C: <a href="https://www.google.com/analytics/terms/?hl=en-US">https://www.google.com/analytics/terms/?hl=en-US</a>
 - Privacy: <a href="https://policies.google.com/privacy?hl=en-US">https://policies.google.com/privacy?hl=en-US</a>
Legal Requirements. We may disclose your information if required to do so by law, or in the good faith belief that such action or disclosure is necessary or appropriate to: (i) operate GLUINO, (ii) comply with any legal obligation, report unlawful activity, cooperate with law enforcement or public authorities (including for the purpose of meeting national security or law enforcement requirements), (iii) protect against legal liability, (iv) protect and defend our rights, property, personnel, suppliers, sponsors, agents or licensors, (v) protect the personal safety of vendors, users of GLUINO or the public, or (vi) comply when compelled to disclose personal information to other third parties by government authorities or as required by law or regulation, including, but not limited to, in response to court orders and subpoenas.
Business Transfers. In evaluating or engaging in a sale of assets, merger, acquisition, reorganization, bankruptcy, or other transaction, we reserve the right to disclose, transfer, or assign your personal information and communications. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent.

5. Your Choices

Opt-out of Marketing Communications. You may opt out of marketing communications from Company by following such instructions as may be provided in the communication, or by changing your opt-out options through the App.
Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across GLUINO and third-party services. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, GLUINO may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
Targeted Online Advertising. Some of the third parties that collect information about users' activities on or through GLUINO may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. Users may opt out of receiving targeted advertising through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to visited Websites. Some services do not currently monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser "Do Not Track" settings and/or signals, in connection with GLUINO.

6. Accessing Personal Information and Retention Period

Accessing Your Account. Please note that if you choose not to provide us with certain personal information, we may not always be able to provide you with the relevant GLUINO product or service that you request. For example, without providing an email address, you will not be able to create an account.
1. You may access, view, correct, or update certain personal information collected about you by accessing your account through the GLUINO application and edit your personal information. If you want to deactivate your account, you may do so through your account.
2. If you have any concerns about how we are using your personal information, would like to correct or remove correct the personal information that you have provided to us, please send your request using the contact details in the Contact Us section.
Retention Period. When you request that we delete your personal information, we will take commercially reasonable steps to remove it from our active databases but will keep original information consistent with our business practices to the extent permitted by applicable law (for example, for purposes of dispute resolution, enforcement of agreements, complying with legal requirements, recordkeeping, backup, and document retention).

7. How We Protect Your Information

GLUINO maintains commercially reasonable measures designed to protect your personal information in connection with your use of GLUINO. However, no security system is impenetrable, and we cannot guarantee the security of your personal information.

External Websites. GLUINO may contain links to other Websites and online services operated by third parties, which are not associated with Company and which Company does not control. We are not responsible for the content or the privacy policies or practices of those Websites or online services. We encourage you to read the privacy policy and legal terms of Websites or online services that you visit or use.
Contact Us. If you have questions about this Privacy Policy, please contact Company using the contact information provided on GLUINO.
Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on GLUINO. If we make material changes, we will notify you by posting an announcement on GLUINO or sending you an email.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section applies only if Company's privacy practices are governed by The California Consumer Privacy Act of 2018 ("CCPA"), and only with respect to.

The California Consumer Privacy Act of 2018 ("CCPA") requires Company to provide to California residents an explanation of how Company collects, uses, and shares their personal information, and of the rights and choices Company offers to California residents regarding its handling of personal information.

Personal Information That We Collect, Use, and Share. Company does not sell personal information. As explained in this Privacy Policy, GLUINO uses cookies and other tracking tools to analyze traffic and facilitate advertising. If you would like to opt out of GLUINO’s (and third-party advertising partners') use of cookies and other tracking technologies, please review the instructions provided in the <a href="#opt-out-guide">Online Tracking Opt-out Guide</a>.

Here is a summary of how we currently collect, use and share personal information, and how we have collected used and shared the information in the preceding 12 months.

Personal information we collect	CCPA categories (Definitions are available <a href="#definitions">here</a>)	Sources of personal information	Purposes for which we may collect and use personal information	Data Sharing
Contact information Transaction information Payment details Your correspondence or feedback Other information that you provide to us voluntarily	Identifiers Commercial information Financial Information	You	Service delivery Marketing Compliance & Operations	Shared with service providers
Cookies and other information collected by automated means Inferences drawn from device data and online activity data	Unique Identifiers Commercial Information Internet or Network Information Inferences	You Automatic collection	Service delivery Marketing Compliance & Operations	Collected directly by advertising partners Shared with and collected directly by service providers

Please note that we may also disclose personal information to comply with law, and for compliance, fraud prevention, and safety purposes; in the event of business transfers; and to our professional advisors, as further described above in the "How We Share Personal Information" section.

California Residents' Privacy Rights

The CCPA grants California residents the following rights:

Information. You can request information about how Company has collected, used and shared your personal information during the past 12 months.
Access. You can request a copy of the personal information that Company maintain about you.
Deletion. You can ask Company to delete the personal information that Company has collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting Company from providing certain sensitive information in response to an access request and limiting the circumstances in which Company must comply with a deletion request. If Company denies your request, it will communicate its decision to you.

You are entitled to exercise the rights described above free from discrimination.

How to make a request. To request access to or deletion of personal information, contact the GLUINO via the contact information provided on GLUINO.
Identity verification. The CCPA requires GLUINO to verify the identity of the individual submitting the request before providing a substantive response to the request.
Authorized agents. California residents can empower an "authorized agent" to submit requests on their behalf. Company will require the authorized agent to have a written authorization confirming that authority.

Definitions

The CCPA defines "personal information" as "information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household."

It establishes the following categories of personal information:

Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers
Customer records information: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information
Characteristics of protected classifications under California or federal law: Race, religion, sexual orientation, gender identity, gender expression, age
Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Biometric information: Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data
Internet or other electronic network activity information: Browsing history, search history, and information regarding a consumer's interaction with an Internet Website, application, or advertisement
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information: Information that is not "publicly available personally identifiable information" as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)
Inferences. The law also includes inferences that could be used to create a profile reflecting a consumer's:
- Preferences
- Characteristics
- Psychological trends
- Predispositions
- Behavior
- Attitudes
- Intelligence
- Abilities
- Aptitudes

It gives the California attorney general the power to add categories of personal information to address changes in technology, data collection practices, obstacles to implementation, and privacy concerns.

What isn't personal information

The CCPA's definition of personal information does not include publicly available information. That would be data contained in publicly available federal, state, or local government records.

Certain types of information are exempt from CCPA regulation, including certain financial information and medical information regulated by the Health Information Portability and Accountability Act (HIPAA).

Online Tracking Opt-Out Guide

This guide is not exhaustive and your usage of any and all information herein is solely at your own risk.

Like many companies online, we may use services provided by Google and other companies that use tracking technology. These services rely on tracking technologies - such as cookies and web beacons - to collect directly from your device information about your browsing activities, your interactions with Websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.

Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:

Google: <a href="https://adssettings.google.com">https://adssettings.google.com</a>

Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Digital advertising Alliance: <a href="http://optout.aboutads.info">http://optout.aboutads.info</a>
Network Advertising Initiative: <a href="http://optout.networkadvertising.org/?c=1">http://optout.networkadvertising.org/?c=1</a>

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use. Any use of this guide is solely at the discretion of the user.