Privacy

At the Glow Academy, we care deeply about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by the Glow Academy. This policy explains our privacy practices for the GlowAcademy.com (which we’ll refer to as the "Site"), the Glow Academy’s mobile applications (the "Apps") and our other services provided by the Glow Academy, Inc. We'll refer to the Site, the Apps and our other services as the "Services." This policy does not apply to the practices of third parties who may also collect or receive data in connection with your use of the Services.

Our Privacy Policy

We process your personal information to run our business and provide our users with the Services. By accepting our Terms of Use (and in some jurisdictions, by acknowledging this policy), you confirm that you have read and understand this policy, including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use the Services. We are not responsible for the content or the privacy policies or practices of any of our members or third-party websites and apps.

The Glow Academy’s Terms of Use require all account owners to be at least 13 years of age. Children under 13 are permitted to use The Glow Academy's Services only if they have permission and direct supervision by the owner of the account. You are responsible for any and all account activity conducted by a minor on your account. We do not knowingly “sell,” as that term is defined under applicable law, including the California Consumer Privacy Act, the personal information of minors.

By using the Services, you acknowledge that the Glow Academy will use your information.

Information Collected or Received

In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our vendors and suppliers that help provide the Glow Academy services you may interact with (such as, for example, for payments or customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. The Glow Academy uses the personal information it receives and collects in accordance with the purposes described in this policy.

Registration, Account Setup, Service Usage: In order to use the Services, will need to submit a valid email address. If you register, you will need to submit a name associated with your account. You may modify that name through your account settings. You need to provide this information to enable us to provide you with the Services. Additional information, such as billing and payment information (including billing contact name, address, telephone number, credit card information), a telephone number, and/or a physical postal address, may be necessary in order for us to provide a particular service. We use stripe.com to process payments. Please refer to Stripe's privacy policy regarding storing your payment information. 

Profile: You may provide your name and other personal information (such as birthday, gender, location) in connection with your account and activity. You can edit or remove this information through your account settings. Other members may see reviews and other information you decide to share via social networks. 

Automated Information: The Glow Academy automatically receives and records information from your browser or your mobile device when you visit the Site, use the Apps, or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. The Glow Academy may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.

We also automatically collect device-specific information when you install, access, or use our Services. This information can include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies & Similar Technologies Policy and “Information Uses, Sharing, & Disclosure” Section below.

Data from Advertising and Marketing Partners: As described below, the Glow Academy receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to the Glow Academy comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.

Analytics Information: We use data analytics software to ensure Site and App functionality and to improve the Services. This software records information such as how often you use the Apps, what happens within the Apps, aggregated usage, performance data, app errors and debugging information, and where the Apps were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application. For more information, see the Glow Academy's Cookies and Similar Technologies Policy and Disclosures.

Information from Third Parties: Some members or visitors may choose to connect to the Glow Academy or register a Glow Academy account using an external third-party application such as Facebook. Connecting your Glow Academy account to third-party applications or services is optional. If you choose to connect your account to a third-party application, it is subject to your agreements with that third party (like their Terms of Use and privacy notices), and the Glow Academy can receive information from that application. We may also collect public information in order to connect with you, such as when we communicate with you over social media. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on the Glow Academy on certain social media networks which are connected to your Glow Academy account, and you can revoke your permission anytime in your account settings. Certain third-party applications that you use to create or sign in to your account may provide you with the option to discontinue receiving messages from us or allows you to forward those messages to another email address. If we are unable to send you critical messages about your account, we may suspend or terminate your account.

Non-Member Information: the Glow Academy receives or obtains information (for example, an email address or IP address) about a person who is not yet a registered the Glow Academy member (a “non-member”) in connection with certain the Glow Academy features, such as when a non-member chooses to subscribe to the Glow Academy newsletter, a member invites a non-member to visit the Site, a member uploads non-member information using the contact uploader feature, a non-member engages in a transaction, a member sends a gift card code to a non-member, or a non-member uses Guest Checkout to make a purchase. Non-member information is used only for the purposes disclosed when it was submitted to the Glow Academy, for purposes necessary to the functioning of the Glow Academy's Services or where the Glow Academy has a legitimate interest, as disclosed in the “Information Uses, Sharing, & Disclosure” Section below, or to facilitate action authorized by a member or the non-member.

Messages from the Glow Academy

On occasion, the Glow Academy will need to contact you. Primarily, these messages are delivered by email or push notifications for a variety of reasons, including marketing, transactions, advocacy, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email in your account settings or by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. The Glow Academy may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, the Glow Academy may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, or to provide you with information about products and features that you may find of interest. You can update your contact preferences in your account settings.

Some messages from the Glow Academy are service-related and necessary for members and Guest Checkout users. You understand and agree that the Glow Academy can send you non-marketing emails or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, and correspondence with the Glow Academy’s Support team (including by chat interface or the other methods of communication as described above).

When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number such as for a Guest Checkout purchase, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in marketing emails or messages. Members can also control which marketing emails or messages they receive from the Glow Academy through their account settings. Please note that some changes to your account settings may take a few days to take effect.

Information Uses, Sharing, & Disclosure

We respect your privacy. The Glow Academy will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy.

Legal Bases

When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:

Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;
You have consented to the processing, which you can revoke at any time;
Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
You have expressly made the information public;
Necessary in the public interest, such as to prevent crime; and
Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).

We principally rely on consent (which can be withdrawn at anytime) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.

We rely on consent for targeted online and offline marketing including through tools like Facebook Custom Audience and Google Customer Match. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Facebook, Google, and other partners disclosed in our Cookies and Similar Technology Policy. These partners have their own privacy policies and consent mechanisms for their customers, in addition to the Glow Academy’s controls. You may see the privacy policies and privacy choices for these partners, and the information you share with them, in our Cookies and Similar Technology Disclosures.

Our Legitimate Interests

Where we process your information on the basis of legitimate interests, we do so as follows:

Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help sellers find the best ways to market and sell their products on the Glow Academy.

Providing Marketing Communications: We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for the Glow Academy's advertising programs (including the Glow Academy’s on-site advertising and marketing).

Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to the Glow Academy’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, in accordance with our existing case resolution process, we may use information you provide to resolve disputes with the Glow Academy or other members.

Site Customization: We may learn about the types of products that you’re interested in from your browsing and purchasing behavior on (and off) the Site or Apps and use such information to suggest potential lesson as a result. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help content providers find the best ways to market and sell their lessons on the Glow Academy.

Legal and Safety: the Glow Academy may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against impending or asserted legal claims, including to collect a debt, or a material violation of our policies (including our Intellectual Property Policy); to comply with a subpoena, court order, legal process, regulation, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our rights or property, or violations of the Glow Academy's Terms of Use. For example, if permitted due to the forgoing circumstances, your information may be shared with tax authorities or other governmental agencies. In the cases set out above, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims or to facilitate the collection of taxes and prevention of tax fraud. It may also be necessary in the public interest (such as to prevent crime) or to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).

If the Glow Academy receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, the Glow Academy may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details. Find out more about how the Glow Academy responds to requests for records or information about members of the Glow Academy’s community in our Requests for Information Policy.

Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used for certain information (such as credit card numbers) using TLS (transport layer security). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. The Glow Academy offers advanced security features and settings for members, such as two-factor authentication for signing in, and sign in history and notifications; you can view more information in your account settings.

If you have any questions about the security of your personal information, you can contact us.

Retention

The Glow Academy will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Glow Academy member account), or as needed to provide the Services to you. If you no longer want the Glow Academy to use your information to provide the Services to you, you may close your account. The Glow Academy will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, the Glow Academy sellers may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or shop name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.

Your Rights & Choices

Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, the Glow Academy gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Glow Academy account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.

Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used. 

Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.

Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.

Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of the Glow Academy. See this Help Center article for more information.

Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.

Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.

The CCPA provides California residents with the following additional rights:

Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.

Right to Opt-Out: To the extent that the Glow Academy “sells” personal information(as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information).

If you would like to manage, change, limit, or delete your personal information, you can do so via your Glow Academy account settings. Alternatively, you can exercise any of the rights above by contacting us by submitting a message through our contact form. Once you contact us to exercise any of your rights, we will confirm receipt of your request.

Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. If you need further assistance, you can contact the Glow Academy through our contact form. We will respond to your request within a reasonable timeframe.

Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.

Email & Messages

You may also control the receipt of certain types of communications from the Glow Academy in your account settings. The Glow Academy may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings, and you can learn more in the “Messages from the Glow Academy” Section of this policy. If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account. Click here to learn how to close your account.

Cookies

We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies. A more detailed explanation of the technologies we use, and how to opt out when applicable, can be found in the Glow Academy’s Cookies & Similar Technologies Policy.

Additional Disclosures for California Residents

Notice of Collection

In addition to the Rights & Choices described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the “Information Collected or Received Section above, the categories of personal information that we have collected – as described by the CCPA – are:

Identifiers, including name, email address, shop name, IP address, and an ID or number assigned to your account.
Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
Demographics, such as your age or gender, or, where you have provided such information to the Glow Academy voluntarily, demographic information about your race, ethnicity, sexual orientation, or gender identity, provided in relation to specific marketing and advocacy projects and campaigns.This category includes data that may qualify as protected classifications under other California or federal laws.
Commercial information, including purchases and engagement with the Services.
Internet activity, including your interactions with our Services and what led you to our Services.
Sensory visual data, such as pictures posted on our Service.
Geolocation data provided through location enabled services such as WiFi and GPS.
Inferences, including information about your interests, preferences and favorites.
The Purposes for Our Collection

We collect and use these categories of personal information for our business and commercial purposes described in the “Information Uses, Sharing and Disclosure” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.

Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)

the Glow Academy does not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities. You can read more in our Cookies & Similar Technologies Policy.

To opt-out of receiving interest based advertising, you can exercise your choice by using your account privacy settings, or the general privacy settings link located at the footer of our homepage and most pages of the Site. The right to opt-out of interest based advertising is available to all the Glow Academy users.

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Shine the Light

California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Other than to Sellers on the Glow Academy (see “Buying and Selling” under the “Information Uses, Sharing and Disclosure” Section above), who must obtain your separate consent for their own marketing off of the Glow Academy, or unless you request us to or consent to it, the Glow Academy does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below. For information on interest based advertising with the Glow Academy and how your information is used for marketing, see the Glow Academy’s Cookies & Similar Technologies Policy.

Accessibility

If you have a disability and would like to access this policy in an alternative format, please contact us using one of the channels listed in the “Contact” section below.

Your Responsibilities

If you sell using our Services or use the Glow Academy’s API, you may receive and determine what to do with certain personal information. Your privacy responsibilities, including when you act as an independent data controller (someone who decides what personal data to collect and the purpose you use the data for) are laid out in the the Glow Academy Seller Policy and the the Glow Academy API Terms of Use.

Privacy Policy Changes

We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Apps’ platform. We encourage you to check back regularly and review any updates.