Your privacy and the security of your personal data will always be taken very seriously, and steps are taken to ensure your privacy is protected at all times.
1. About this Policy
This Policy applies to your use of this Site and the App, regardless of how you access it via mobile devices and the App.
This Policy sets out the essential details relating to your personal data relationship with Glaciera. The terms governing your use of Glaciera services are defined in our Terms. You must read this Policy to be fully aware of how and why we are using your personal data.
This Policy aims to:
- Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with.
- Explain your rights and choices concerning the personal data we collect and process about you and how we will protect your privacy.
- Your rights and your preferences: Giving you choice and control.
The General Data Protection Regulation (“GDPR”) gives individuals certain rights regarding their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:
- The right to access the personal data that we process about you – This enables you to receive a copy of your personal data we hold about you and check that we are lawfully processing it.
- The right to request the rectification of your personal data enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify the accuracy of the new data you provide to us. You can manage some of this information in your account.
- The right to request the deletion of your personal data – This enables you to delete or remove personal data where there is no good reason for us continuing to process it and also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), withdrawn your consent. There is no other lawful basis where we may have processed your information unlawfully. However, please note that we may not always be able to comply with your request for erasure for specific legal reasons, which will notify you, if applicable, at the time of your request.
- Object to processing your personal data – This enables you to object to your personal data processing where we are relying on a legitimate interest (or those of a third party). There is something about your particular situation, which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms. The right to object to direct and marketing purposes is absolute.
- Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to delete it; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether the use of your data but we need to verify whether we have an overriding legitimate ground to use it.
- Request transfer of your personal data – We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent – Withdraw consent when we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you.
If you wish to exercise any of the rights set out above, please contact Glaciera at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information concerning your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
3. What personal data is collected
We may collect and store information which includes, but is not limited to, the following information about you:
- Personal data you provide when you use our Services, create a Glaciera account, and subscribe to Glaciera account
- Personal data we collect automatically when you use our Services, create a Glaciera account, and subscribe to Glaciera account
- Personal data from other sources
- Social network data you share with us.
3.1 Personal data you provide when you use our Services, create a Glaciera account and subscribe to Glaciera account
- Data that identifies you, such as your name, address, telephone numbers, email addresses, your user name that you provide when setting up your Glaciera account
- Financial information (e.g., credit card and account numbers, transaction details, and form of payment
- Billing information you provide
- You may provide us with additional information by updating or adding information to your Glaciera account, by inquiries, or if you contact us for any other reason regarding our Services
- Other data that we are required or entitled by the applicable law to collect and process and that we need for authentication or identification or for the verification of the data we collect
3.2 Personal data we collect automatically when you use our Services, create a Glaciera account, and subscribe to a Glaciera account
- Data that is generated as part of one of your transactions (e.g., purchases, subscriptions) or that is linked to your Glaciera account as a result of a transaction in which you are involved, such as transaction amount, time and location of transactions, and form of payment and payout method
- Data regarding all other interactions with our Services and your communications with us
- Location data, including your general location (e.g., IP address) and your mobile device's precise location data. Please note that for most mobile devices, you can manage or disable the use of your location services for all applications in the settings menu of your mobile device
- Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click, and other actions you take as part of your use of our services and in advertising and email content
- Data about user preference and behavior to be used for marketing and remarking purposes on Google and others.
- Data about your activities and interactions with our advertising partners, including data about the advertisements you were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement, etc
- Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, individual device token, and cookie-related data (e.g., cookie ID)
- The IP address from which your device accesses the Services
- Location data, including your general location data (e.g., IP address) and your mobile device's precise location data. Please note that most mobile devices allow you to manage or disable location services for all applications in the settings menu.
3.4 Personal data from other sources
We also collect personal data about you from other sources and third parties to the extent permitted by applicable law. In particular, this includes the following data:
- Data from credit agencies or bureaus (e.g., credit reports/checks, identity confirmation)
- Data from data providers (e.g., identity verification, online advertising related data)
We combine or connect the personal data we collect from you with data from these other sources. Where personal data is disclosed to our third parties, we take steps to confirm that these third parties are otherwise legally permitted to disclose your personal data to us.
3.5 Social network data you share with us
- We allow you to use social networks (such as Facebook) or other providers of single sign-on services (such as Google) with whom you already have an account to create a Glaciera account or link your Glaciera account to such single sign-on services. You can determine the personal data that we can access when authorizing the single sign-on service connection.
- We may also use plug-ins or other technologies from various social networks. If you click on a link displayed through a social network plug-in, you voluntarily connect to that social network.
4. Explaining the legal bases for using personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you. For example, when you purchase our services, that is a contract between you and us for us to execute it.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests—for example, fraud screening as part of the check-out process or keeping our website secure.
- Where we need to comply with a legal or regulatory obligation, for example, keeping records of our sales for tax compliance.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example, about sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent at any time.
Below you will find a summary of the purposes for which we process your personal data, sorted out by our legal basis for this processing and sharing:
4.1 We process your personal data to fulfill our contracts with you and provide you with our Services. This includes the following purposes:
- Processing data relating to you or your company to enter into a contract with you and execute it.
- Provision of our Services, including but not limited to enabling and performing transactions and ensuring our Services' functionality. In connection with our Services' provision, we will send you notifications relating to the execution of transactions and our Services' use per the communication preferences in your Glaciera account.
- Provision of our payment services
- Providing general customer service support, including the solution to problems with your Glaciera. For this purpose, we may contact you via email.
4.2 We process your personal data to comply with legal obligations to which we are subject. This includes the following purposes:
- Participation in investigations and proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for detecting, investigating, and prosecuting illegal acts
- Prevention, detection, and mitigation of illegal activities (e.g., fraud and money laundering)
- Complying with information requests from third parties based on any statutory information rights they have against us (e.g., in the event of an intellectual property infringement or other unlawful activity)
- Ensuring the information security of our services
- Retention and storage of your personal data to comply with specific legal requirements
4.3 We process your personal data where it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests. To reconcile our legitimate interests with your rights, we have introduced control mechanisms. We process your data for the following purposes:
- Participation in proceedings conducted by courts, law enforcement agencies, government agencies or public authorities, intergovernmental or supranational bodies, in particular for detecting, investigating, and prosecuting illegal acts, unless there is a statutory obligation to this effect and we may legitimately assume that the disclosure of the data is necessary to avert imminent disadvantages or to report a suspicion of an illegal act. In such cases, we will only disclose what we believe is necessary, such as your name, address, telephone number, email address, user name, IP address.
- Prevention, detection, mitigation, and investigation of fraud, security breaches, and other prohibited or unlawful activities, unless there is a statutory obligation to this effect.
- Monitoring and improving our Services' information security unless there is a statutory obligation to this effect.
- Performance of identity checks and comparison of information for accuracy and verification purposes.
- Administer and protect our business and the site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting).
- Analysis and improvement of the Services to identify and solve problems and provide you with an improved user experience.
- To the extent permitted by applicable law without your consent, communications with you via email to inform you about our Services (according to your communication preferences in your Glaciera account). If you do not wish to receive marketing communications from us, you can also unsubscribe by clicking on the link in the email you received. For technical reasons, this may take a few days.
- Evaluation of the quality and success of our email marketing campaigns (e.g., through analysis of opening and click rates)
- Assertion of or defense against legal claims
4.4 With your consent, we process your personal data for the following purposes:
- Marketing communications by email. We may engage third parties to send marketing communications on our behalf
- Processing of your precise location data
- Provision of a single sign-on service allowing you to log-in to third party services using your Glaciera log-in credentials
- Processing of your personal data based on your consent, which you have given so that third parties or we can enable you to use certain services or make them available to you
5. Retention of your personal data
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
We take appropriate measures to ensure that any personal data is kept secure and is kept for only so long as is necessary for the purpose for which it is used.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
If your personal details change or if you have any queries about how we use your personal data, please notify us by contacting us at firstname.lastname@example.org.
6.1 Your choice regarding cookies
If you choose not to receive cookies, you may still use most of the features on your site, including purchasing Services.
7. Data security
We protect your personal data through technical security measures to minimize risks associated with data loss, misuse, unauthorized disclosure, and unauthorized disclosure and alteration. To this end, we use firewalls and data encryption, for example.
8. Other important information regarding data protection