Your Privacy Matters

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We at Glassbeam (Glassbeam Inc. and our partners) are committed to protecting your privacy.

This Privacy Policy applies to our Website or subdomains of www.glassbeam.com (for Example, https://login.glassbeam.com) referred to as “Sites”, through our HTML-formatted email messages, and social media pages. This Privacy Policy tells you about policies, our data collection methods and its uses, processing of your data we retain in our environment, and the usage practices. It also describes your rights regarding use and access of your personal information. If you do not agree with this Privacy Policy and our practices described, you should not use our Sites.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

If you have any questions about this Privacy Policy or our practices of your Personal Information you provide us, please write to us by email at [email protected] or by snail mail to Glassbeam Inc., 2350 Mission College Blvd., Suite 777, Santa Clara, CA 95054 USA

Collection of Personal Information “Personal Information” is information that identifies you as an individual including:

• First and last name
• Company address
• Telephone number both landline and mobile
• Email address
• Company name and job title

We and our third-party service providers collect Personal Information using these methods, including:

• Through our own or third-party applications/services: We collect Personal Information through web-based applications and services, for Example, when you communicate with us via email, fill out forms on our Sites, schedule face-to-face meetings with our representatives and subsequently share information as follow up, or register for an event where you would like to meet our representatives.
• Offline sources: We collect Personal Information from you offline, for Example, when you meet our representatives or delegates in events where we present or exhibit, and share information at our booth, express interest in our products over the phone with our sales representatives, or contact customer facing teams located either in the United States (our Headquarters) or from our development center located at Bangalore, India.
• From Other Sources: We receive your Personal Information from other sources, for Example, publicly available information such as LinkedIn or data procured from organizers of events where we attend or make a representation through consultants or through designated employees and, joint marketing/sales personal through contracted partners, when they share the information with us. The information may include, for Example, contact name, company, and generic industry-specific data, as well as title, department, address, phone number, and e-mail addresses.

Lawful Basis for Collection of Information

We need to collect Personal Information in order to provide the requested services to you. If you do not provide the information requested, we may not be able to provide the services.

Use of Personal Information Website specific use of your Personal Information:

• Improving the content on our Sites, for Example, by receiving feedback information that is relevant to our customer, partners, and Sites’ users like you.
• Conducting data analysis, for Example, through Google Analytics to improve the efficiency of our Sites and its content being served.
• Enhancing, improving, or modifying our current products and services.
• Identifying usage trends, for Example, understanding which parts of our Sites are of most interest to you using Pardot or other third-party applications.
• Determining the effectiveness of our marketing or sales campaigns that help us understand your needs and interests.
• Operating and expanding our activities on our Sites, for Example, understanding which parts of our Sites are of most interest to you using third-party applications that provide heat-map tracking, tracking Pixels, and so on.
• Preventing fraud or other illegal activities, such as hacking or malware attacks on Glassbeam Inc. and its partners.

Fulfilling your request for information 

These are the purposes when one of our representatives from marketing, sales or our Press Release media partners will make contact with you using the information you have shared with us.

• Sending you updates to this Privacy Policy, terms of using our services, or notify you about enhancements to product information.
• Responding to your inquiries and fulfilling your requests, when you contact us through one of our online contact forms, for Example, when you register a request to meet one of representatives at an event.
• Processing your request for marketing collaterals, job applications, on-demand webinars, and customer service requests.>

Communicating with you through our newsletter and social sharing channels Our Marketing or Sales team will make contact with you for these purposes:

• Contacting you for marketing and sales purposes, including notifications related to product enhancements and announcements that are related specifically to your needs and interests.
• Facilitating social sharing functionality that you choose to use.

How we Share Information we Collect We do not sell, trade, or otherwise transfer to outside parties your Personal Information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving you, so as long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

• Third-party Applications and Services: We partner with third-party vendors to provide specific services on our Sites to enhance your experience and improve the usability for future visits. For Example, when you share information through a form on our Sites, your Personal Information may be shared with a third-party application or service provider. The purpose of sharing your information with third-party service providers is to conduct analysis using statistics on the content and viability of their services for you. Our third-party application vendors do not have explicit permission from Glassbeam Inc. to nor are they allowed to use personally identifiable information except for the purpose of providing specific services on our Sites.

How We Protect Your Information

We are committed to protecting the confidentiality of your information. We take reasonable measures to secure your information, including industry standard administrative, physical and technical controls. These controls include policies, third party reviews, access controls and testing.

International Transfers of Your Information

Your personal information may be transferred outside the country of origin. When transferring data we will comply with all applicable laws and regulations.

California Privacy Notice This Privacy Notice for California Residents supplements the information contained in this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

As pertaining to California residents, we have collected the following categories of personal information within the last twelve (12) months:

Collected

• Identifiers. A real name, postal address, Internet Protocol address, email address, account name. To be clear, we do NOT collect identifiers such as a Social Security number, driver’s license number, passport number, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number. Glassbeam does NOT collect personal information such as a Social Security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Not Collected

• Commercial information. Records of Glassbeam’s products or services purchased, obtained, or considered.
• Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• Geolocation data. Physical location, as related to IP address.
• Professional or employment-related information. Current or past job history.
• Protected classification characteristics under California or federal law.
• Biometric information.
• Sensory data.
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
• Inferences drawn from other personal information.

Sales of Personal Information Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months (including that we do not “sell” the personal information of minors under 16 years of age).

Your Rights and Choices The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose the same to you.

Deletion Request Rights You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us per the contact information described below.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

EU-U.S DPF, UK Extension to the EU-U.S DPF, and Swiss-U.S DPF Privacy Notice

Glassbeam, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Glassbeam, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Glassbeam, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Reporting on the investigatory and enforcement powers of the Federal Trade Commission (FTC)

Glassbeam is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and will comply with all requests.

Right to invoke binding arbitration

Individuals  have the option to invoke binding arbitration under specific conditions as set forth in Annex I of the DPF Principles.

Requirement to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

Glassbeam may disclose personal information in response to lawful requests by public authorities. Glassbeam will take steps to balance its responsibility to national security or law enforcement requirements with its obligation to protect individual’s privacy. Glassbeam will notify individuals of any such disclosures.

Liability of onward transfers to third parties’

Glassbeam assumes liability in cases of onward transfers to third parties by ensuring individuals are aware of the potential sharing of their information and the associated responsibilities of Glassbeam.

Dispute Resolution

If you have a concern regarding our Privacy program, please contact us at [email protected] so that we may address your issues.

If Glassbeam cannot resolve the issue, your concern should be brought to a relevant Data Protection Authority for independent dispute resolution. Glassbeam has selected the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) as independent dispute resolution bodies to address complaints and provide appropriate recourse free of charge.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Glassbeam, Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

As a citizen of the European Union or United Kingdom you are afforded rights in the processing of your personal information, as summarized below.

Request Access to Data (Right to information)

You are entitled to request a copy of your Personal Data held by us, as well as a description of how the information is used

Correcting Personal Data (Right to Rectification)

You are entitled to request that any incorrect Personal Data that we hold is corrected.

Deleting Person Data (Right to Erasure)

You are entitled in certain circumstances to request that some or all of your Personal Data is deleted. If you request that all of your Personal Data is deleted, we will close your account and you will no longer be able to access the service.

Objecting to or limiting our use of your Personal Data (Right to Object to Processing)

You are entitled to request that we limit the use of your Personal Data to specific circumstances.

Object to Automated Decision Making

You are entitled to object to not be subject to any decisions that are based solely on automated processing.

Transfer of Your Data (Right to Data Portability)

You are entitled to request a copy of the Personal Data that you provided in machine readable form.

Japan Privacy Notice This Privacy Notice for Principals in Japan supplements the information contained in this Privacy Policy and applies solely to Principals in Japan where Glassbeam has collected personal information in relation to the provision of goods and services for those persons.

Principals’ Rights

Under the Amended Act on the Protection of Personal Information, Principals are afforded specific rights on any Retained Personal Data such as requests for notification of purpose, disclosure, correction, supplementation, deletion, cessation of use, removal or cessation of disclosing to a third party and information pertaining to the processing of information in foreign countries.

To submit a request related to your personal data, you should contact us immediately via telephone at 408-740-4600 or send us an email to [email protected].

Provisions to Third Parties and Foreign Countries

As provided for in the laws and regulations, except in the following circumstances, the Company will not provide personal information or personally referable information to third parties, either in Japan or overseas, without the prior consent of the relevant person.

1. When the provision of personal information is based on laws and regulations (including cases based on laws and regulations relating to the protection of private information)
2. When there is a need to protect the life, body or property of a person and it would be difficult to obtain the consent of the relevant person
3. When there is a particular need to improve public health or promote the healthy development of children and it would be difficult to obtain the relevant person’s consent
4. When it is necessary to cooperate with a government organization, local government body or individual entrusted by such entities in performing duties prescribed by laws and regulations and there is a risk that obtaining the consent of the relevant person would interfere with the performance of said duties
5. When a subscriber’s personal information is provided in the course of a business succession due to a merger or other reason

Management of Personal Information

We are committed to protecting the confidentiality of your information.  In order to protect personal data from loss, inconsistencies, and unauthorized access or disclosure, Glassbeam takes reasonable measures to secure your information, including the implementation of industry standard organizational and technical controls. An overview includes:

a. Establishment of Basic Policy

To ensure appropriate handling of information assets including personal data Glassbeam has established an “Information Security Policy”.

b. Development of the Rules Regarding the Handling of Personal Data

Glassbeam has established an Acceptable Use policy that establishes the Company’s requirements for handling computing resources and personal data obtained in the course of business.

c. Systematic Security Control Measures

Glassbeam has established a Chief Information Security role  to oversee information protection programs. Glassbeam is also reviewed by internal information security audit and external organizations regarding the ongoing maintenance of its security program.

d. Human Security Control Measures

Glassbeam requires its personnel to execute confidentiality agreements at the time of joining as well as be involved in ongoing education on information security.

e. Physical Security Control Measures

Glassbeam controls the entry and exit of personal data management areas and take measures to prevent physical compromises, unauthorized access or the theft equipment and documents.

f. Technical Security Control Measures

Glassbeam takes measures to manage access to servers and other information devices, and to prevent information leakage due to unauthorized software.

g. Understanding of the External Environment

Glassbeam complies with all applicable laws and regulations regarding the handling of information. When handling personal information in a foreign country, the Company shall understand the system for the protection of personal information in such foreign country and take measures for security control of personal information.

How to  Submit Inquiries or Exercise Your Privacy Rights 

If you have questions or concerns, or would like to exercise your rights related to your personal data, you should contact us immediately via telephone at 408-740-4600 or send us an email to [email protected].

Contact [email protected]

Glassbeam Inc.  2350 Mission College Blvd.,
Suite 777, Santa Clara,
CA 95054
USA

 

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