Updated as of May 2018.

PRIVACY POLICY

Glowreous, Inc. (“Company”) values your privacy and is committed to maintaining your trust. We provide this Privacy Policy to inform its you of our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received from users of this website located at www.glowreous.com (the “Website”) and users of all other products and services, including mobile application, owned, controlled or offered by Glowreous, Inc. and all content offered as a part thereof (the “Services”).

Changes. This Privacy Policy may be updated from time to time for any reason, at our sole discretion. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Website. You are advised to consult this Privacy Policy regularly for any changes.

Incorporation into Terms of Service. By using or accessing the Website or the Services, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. This Privacy Policy is incorporated into, and considered a part of, the Company’s Terms of Service.

Personal Information. “Personal Information” may include, but is not limited to information that identifies you as an individual or relates to an identifiable person, such as name, postal address, telephone number, email address, etc. The Company does not collect any personal data from visitors to its website that is not voluntarily provided. The Company only collects your Personal Information if you register for an account with the Company’s Website, when you use the Company’s Services, and when you send the Company communications in connection with your use of the Services.

Third Party Personal Information. We may obtain your Personal Information from third parties, such as third parties with whom we affiliate in providing the Company’s services. If you provide the Company with Personal Information about third parties, you warrant to the Company that any Personal Information that you provide to the Company about any third party individuals was obtained by you with full consent, and that the individual has not communicated to you that they wish to opt out of receiving communication from the Company or having the Company collect information about him or her. We use this third party personal information to provide and improve our Services and facilitate communication between you and such third parties, pursuant to this Privacy Policy, the End User License Agreement in our mobile application, and in our Terms of Service.

Use and Sharing of Personal Information. We use the information we collect from our Website and your use of our Services to provide and improve existing Services; to develop new Services; and to protect you and the Company. We also may use this information to offer you tailored content when you visit our Website. We will not share your personal information with anyone except for our Company’s authorized service providers, business affiliates, and business partners for business purposes; or unless we specifically inform you and give you an opportunity to opt out of our sharing your personal information.

In general, we may use and/or share your Personal Information:

• To respond to your inquiries and your requests regarding our Services.
• To send you information regarding our Services and changes to our terms, conditions, and policies.
• To complete your registration, process your payments, and communicate with you regarding your purchase of our Services.
• To send you marketing communication and newsletters about our Services.
• To personalize your experience on our Website.
• To inform you and allow you to participate in our promotions and/or campaigns.
• To facilitate social sharing functionality.
• To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services.
• In connection with our business purposes, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or services, expanding our business activities, etc.
• Our mobile application may also send push notifications to your mobile device. You may receive push notifications if you have previously consented to receiving push notifications and you have shared your suggested location with our app. These push notifications will alert you as to the proximity of our Services with respect to your specific location. If you no longer wish to receive them, you can also turn push notifications off at the device level. The applications may also request access to your device’s calendar application, camera, and microphone. If you have previously allowed access to your device’s calendar and no longer wish to allow access, you may edit the application settings at the device level.

We will not use and/or share your Personal Information:

• To run interest-based advertising campaigns that collect personal data including telephone numbers and credit card numbers.
• To use or associate personal data with remarketing lists, cookies, data feeds, or other anonymous identifiers.
• To use or associate targeting information, such as demographics or location, with any personal data collected from the ad or its landing page, without your consent.
• To share any personal data with Google or third party companies through our remarketing tag or any product data feeds which might be associated with our ads, without your consent.
• To send Google or third party companies precise location information, without your consent.

However, we reserve the right to disclose Personal Information that we believe to be necessary or appropriate in the following circumstances:

• As required by law, such as to comply with a subpoena, or similar legal process.
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• To enforce our Terms of Service.
• To allow us to pursue available remedies or limit the damage we may sustain.

Personally Non-Identifiable Information: We may collect personally non-identifiable information, including but not limited to demographic data, age, education level, profession, geographic location or gender, from you at the time of registration, or when you choose to use our Services. This information is not, by itself, sufficient to identify or contact you. The Company may store such information, or it may be included in databases owned and maintained by partners, affiliates, agents, or service providers of the Company. The Company may use such information and pool it with other information to track data related to growing the business, such as the total number of visitors to our Website and the domain names of our visitors’ Internet service providers.

Passively Collected Information: Your visit to our Website may allow us to obtain certain additional, personally non-identifiable information that is collected passively using various technologies. This information includes but is not limited to, for example, IP addresses, browser types, date and time of page views, location information associated with your IP address, domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or our services. This information cannot presently be used to specifically identify you.

Aggregated Personal Data: The Company may analyze your personal data provided through the Website or in connection with rendering the Services, in aggregate form. This aggregate information does not identify you personally. We may share this aggregate data with our partners, affiliates, agents, or service providers for business purposes. We may also disclose aggregated statistics to explain our Services to current and prospective business partners, and to other third parties for other lawful, business-related purposes.

Customer Credit Card Information. The Company uses a third party to keep a protected copy of your credit card number. This billing data belongs to you, and by utilizing the Services, you grant the Company a license to use this data to bill you for services rendered.

Tracking and Advertising. The Company’s Website may use technologies such as cookies, web beacons and log files.

• Cookies. When you visit our Website or otherwise interact with the Services, we may send one or more “cookies” to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites. Some features on this site will not function if you do not allow cookies. We may link the information we store in cookies to any Personal Information that you submit while visiting our Website.

We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site.

Functional cookies, persistent and session type, store information to enable core site functionality, such as Live Chat and Client ID remembrance.

Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.

Advertising cookies may be set through our Website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to https://www.allaboutcookies.org/manage-cookies/index.html.

If you reject cookies, you may still use our site, but some features on the site will not function properly.

• Web Beacons. Web beacons are electronic files that signal when a webpage, advertisement, video, other content, an email or newsletter has been viewed. They are usually invisible to you. We may use web beacons alone or in conjunction with cookies to compile information about your use of our Services and/or Website. Web beacons may be used to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by web beacons to your Personal Information to gauge the effectiveness of certain communications and our marketing campaigns.
• Log Files. A Log File is a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software. Log file information is automatically reported by your browser or our mobile application each time you access the Website or our Services. Along with cookies and web beacons, log files help provide additional functionality to the Website and Services and help us analyze Website and Services usage more accurately. We and our third party tracking-utility partners may use log files on our Services to gather automatically gather and store information including, but not limited to, internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for business purposes. As described herein, we may use Google Analytics, which uses cookies and other, similar technologies to collect and analyze information about use of the Website and Services, and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We may, either directly or through third party companies and individuals we engage to provide services to us, also:

• Track your use of our Website and the Services for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, etc.
• Track your use of the Website and the Services to enable you to use and access the Services and pay for your activities on the Website and through the Services.
• Track your behavior on our own Website and use of the Services to market and advertise our services to you on our Website platform and third party websites.

Advertising Networks. We may partner with third party ad network(s) and other service providers such as Facebook to show you relevant ads, including ads displayed on the Services and on other companies’ websites or apps, on any of your devices. Our service providers may use cookies and web beacons to collect non-personally identifiable information about your activities on the Services and other web sites and mobile apps to provide you targeted advertising based upon your interests. They may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer.

You may opt out of receiving advertisements by visiting the Network Advertising Initiative (https://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (https://www.aboutads.info/choices/). You may download the AppChoices app at www.aboutads.info/appchoices to opt out in our mobile app. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Services, generally. The advertising will simply not be targeted or specific to your interests.

Children. The Website and our related Services are not intended for anyone under 18, and we do not knowingly collect information from anyone under the age of 18. Anyone aged 18 or under should not submit any Personal Information without the permission of their parents or guardians. By using the Website and our related Services, you are representing that you are at least 18 years old.

Links to Other Websites. This Privacy Policy applies only to this Website and the Company’s Services. It does not apply to any third-party sites. The Company has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party websites. In addition, the Company will not and cannot censor or edit the content of any third-party site. By using the Services, you expressly relieve the Company from any and all liability arising from your use of any third-party website that is referenced or linked on our Website.

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties or their websites. By way of an example, on our Website, we may link to TripAdvisor.com or Yelp.com to inform our users regarding spa reviews. However, we are not liable for any damages that may result from your visit to or use of these website. The inclusion of a link anywhere on our Website or in our mobile app does not imply endorsement of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, LinkedIn, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Website or Services.

Security. We maintain reasonable and appropriate, although not infallible, security precautions. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts. You should note that in using the Website and our related Services, your information will travel through third party infrastructures which are not under our control. Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to info@glowreous.com.

Data Retention. We will retain your Personal Information for as long as needed to provide the applicable Services, unless a longer retention period is required or permitted by law.

Do Not Track. Your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. The Company’s Website does not respond to “Do Not Track” signals or other mechanisms from a visitor’s browser. If, in the future, we create a program or protocol to respond to such web browser “Do Not Track” signals, we will inform you of the details of that protocol in this Privacy Policy. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Google AdWords. This Website uses the Google AdWords in order to advertise on third party websites (including Google) to previous visitors to our site or to similar audiences online. This may result in you seeing an advertisement on the Google search results page, or a site in the Google Display Network. Google may include in-ads notice labels to disclose interest-based advertising to their users. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Website. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy. Google reserves the right to display to users which remarketing lists users are on, along with the corresponding domain name. You can set preferences for how Google advertises to you using the Google Ad Preference Manager (https://www.google.com/settings/ads/onweb/), and you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

Analytics Software. We and our third party tracking-utility partners use log files on our Website and/or Services to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes. Specifically, we analyze trends, administer the site, track users’ movements around the Website, and gather demographic information about our user base in the aggregate.

We may use Google Analytics, which uses cookies and other, similar technologies to collect and analyze information about use of the Website and/or Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources.

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the GoogleAnalytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We may also use Flurry Analytics, which allows us to analyze our mobile app users’ behavior and engagement through data observations, and provides features for user segmentation, consumer funnels, and app portfolio analysis. You can learn more about how Flurry Analytics works by visiting https://developer.yahoo.com/flurry/docs/faq/other/.

Finally, we may also use Facebook Analytics, which allows us to analyze data, trends and charts related to your use of our mobile app, including but not limited to data related to your launching, viewing content, searching or purchasing. You can learn more about how Facebook Analytics by visiting: https://developers.facebook.com/docs/analytics/faq

By using our Website and/or mobile app, you herein agree to our use of the aforementioned analytics software for our business purposes.

Your California Privacy Rights. Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. You may request and obtain from us once a year, free of charge, certain information about the personal data (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 data 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 submit your request in writing to info@glowreous.com.

Facebook Connect/Open ID Providers. You may log into your account on our Website and/or access our Services using sign-in services such as Facebook Connect or an Open ID provider. In addition, when using our mobile application, we may allow you to tell friends about our services by accessing the contacts in your Facebook or other social media account. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our registration form. Services like Facebook Connect give you the option to post information about your activities on this Website to your profile page to share with others within your network if you so choose.

Blog/Public Forum on our Website. Our Website offers publicly accessible message boards, blogs, and community forums to which you or other users may contribute. Our blog/public forum allows you and other users to guest blog and post content such as videos, photos, and advertisements with respect to the Services. Posted information on our blog/public platform may be collected and used by others.

You agree not to post on our Website any content that: (i) may create a risk of harm, loss, physical or mental injury, emotional distress, death, disability, disfigurement, or physical or mental illness to you, to any other person; (ii) may create a risk of any other loss or damage to any person or property; (iii) seeks to harm or exploit children by exposing them to inappropriate content, asking for personally identifiable details or otherwise; (iv) may constitute or contribute to a crime or tort; (v) contains any information or content that we deem to be unlawful, harmful, abusive, racially or ethnically offensive, defamatory, infringing, invasive of personal privacy or publicity rights, harassing, humiliating to other people (publicly or otherwise), libelous, threatening, profane, or otherwise objectionable; (vi) contains any information or content that is illegal (including, without limitation, the disclosure of insider information under securities law or of another party’s trade secrets); (vii) contains any information or content that you do not have a right to make available under any law or under contractual or fiduciary relationships; or (viii) contains any information or content that you know is not correct and current. You agree that any user content that you post does not and will not violate third-party rights of any kind, including without limitation any intellectual property rights or rights of privacy.

The Company reserves the right, but is not obligated, to reject and/or remove any user content on the blog/public forum that the Company believes, in its sole discretion, violates these provisions. We also reserve the right to block or remove any content we deem inappropriate, obscene, lewd, lascivious, filthy, violent, harassing, defamatory, libelous, tortious, illegal, threatening, or otherwise objectionable, regardless of whether it was intended to be private or public. Since we do not review all content on our Website, we cannot guarantee that we will be able to take protective measures in the event that any user posts content that violates the terms of this provision. However, when we become aware of content that we consider violates this provision (i.e., is offensive or could compromise the privacy of your personal or confidential information or that of another person), we will make a good-faith, reasonable effort to block or remove such content.

The Company takes no responsibility and assumes no liability for any user content that you or any other user or third party posts or sends over the Website or mobile app, or any action you take in reliance on any user content posted by another user. You shall be solely responsible for your user content and the consequences of posting or publishing it, and you agree that we are only acting as a passive conduit for your online distribution and publication of your user content.

Furthermore, you understand and agree that you may be exposed to other people’s user content that may be inaccurate, objectionable, inappropriate for children, or otherwise unsuited to your purpose, and you agree that the Company shall not be liable for any damages you allege to incur as a result of exposure to such user content.

You may self-edit and/or remove the content you posted on our Website and/or mobile app by logging into your account. Or, to request removal of any content that you believe violates this provision or that you previously posted on our blog/community forum, please contact us at info@glowreous.com. In some cases, we may not be able to remove your content, especially if it was already re-posted by another user. If this is the case, we will let you know if we are unable to do so and why in response to your request.

Referrals. If you choose to use our referral service to tell a friend about our Services by email, we will ask for your friend’s email address, and send your friend a one-time email inviting them to visit our Website and/or our mobile application, and inform them of our Services. We will only stores your friend’s email address for the sole purpose of sending this one-time message and tracking the success of the referral program. Your friend may contact us at info@glowreous.com to request that we remove this information from our database at any time.

If you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Testimonials, Ratings and Reviews. If you submit testimonials, ratings, or reviews of the Services directly on our Website, any Personal Information you include will be displayed on the Website. We may also partner with third-party service providers to collect and display ratings and review content on our Website. If you provide our third-party service providers with your Personal Information in the process of submitting your rating and review, the content and Personal Information collected by a third party will be posted on our Website, absent your express instruction not to do so. If you want your testimonial, rating, or review removed from our Website at any time, please contact us at info@glowreous.com.

Opt-Out Policy. If, at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at info@glowreous.com.

Contact Us. If you have any questions or concerns relating to our use of your Personal Information, please email info@glowreous.com. Additionally, you may reach us by postal mail at:

Glowreous, Inc.
c/o SOLUZIONE USA INC.
4 Spinnaker Place
Redwood City, California 94065