GLASSWIRE PRODUCTS AND SERVICES PRIVACY POLICY

Last Updated: April 25, 2024

This Products and Services Privacy Policy (“Policy”) describes the information that GlassWire, a brand owned by Domotz Inc, and its subsidiaries and affiliates (collectively, “Domotz”, “GlassWire”, “we”, “our”, or “us”) collect, use, share, and store about you through the GlassWire subscription services (the “Services”). In doing so, we are committed to protecting and respecting your privacy and personal data, in accordance with applicable data protection and privacy rules. In the interest of clarity, we confirm that we do NOT sell or rent or your personal data to any third party. For the avoidance of doubt, GlassWire is NOT in the advertising business. Data is collected and utilized by GlassWire solely for the provision of the Services and for the purpose of enhancing your digital security.

GlassWire is designed to provide full visibility and control over digital traffic generated or received by an end-user endpoint on a computer network for the purpose of enhancing digital security. Specifically, GlassWire allows - amongst others - for logging of traffic counters and IP address of traffic destination or origin. For the avoidance of doubt, GlassWire does NOT inspect the data packets going through an endpoint, it just records the quantity of traffic and the IP destination of such traffic to/from the endpoint, in order to make a Subscriber and/or an end user aware of any abnormal or unwanted data patterns occurring on GlassWire monitored machines. GlassWire also allows a Subscriber and/or end-user to block any data traffic. Furthermore GlassWire, if so requested, allows a Subscriber to obtain a summary overview of digital assets present in the Subscriber’s IP Network.

If you use GlassWire for personal use, you are likely to be both a Subscriber and an end user of the GlassWire services, in so far as you are likely monitoring your own network traffic. If you use GlassWire in a commercial environment, such as an IT System Administrator or a Managed Service Provider, you are using GlassWire to monitor traffic of a number of different hardware endpoints, likely associated with many different individual end-users (also referred to as “Data Subjects”).

In this Policy, personal information means information relating to an identified or identifiable natural person of a Data Subject. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. The use of personal information collected through our Service shall be limited to the purpose of providing the Service for which the Subscribers have engaged.

Subscribers to our Services who monitor multiple endpoints are solely responsible for establishing policies for and ensuring compliance with, all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information of Data Subjects in connection with the use of our Services. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your personal information.

The Subscriber remains at all times the sole owner of any personal information collected via the GlassWire Application. We at GlassWire collect such information solely under the direction and on behalf of our Subscribers, and have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. If you are an individual who interacts with a Subscriber using our Services (such as a customer of one of our Subscribers) and would either like to amend your contact information or no longer wish to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.

This privacy policy was last updated on April 25, 2024. We may change it from time to time, so please check back regularly to keep informed of any updates.

By using the Services, you are accepting and consenting to the practices described in this policy, now and as amended by us.

What information does GlassWire collect?

We collect the following categories of information:

  • Information you give us.

    Account and Registration Information:
    We ask for and may collect personal information about you such as your name, address, phone number, email address, and credit card information, as well as certain related information like your company name and website name, if applicable, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with your Account.

    We refer to any information described above as “Account Information” for the purposes of this Policy. Account Information is used by GlassWire exclusively for billing purposes and for providing you with GlassWire product updates and/or the GlassWire newsletter if you have chosen to subscribe to it. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

    Other Submissions:
    We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, requesting customer support, or otherwise communicating with us.

    Attendee Information:
    We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of GlassWire Company participates.

  • Information That We Collect From You on our website:
    We provide additional details about how we collect and use information from our public web sites in our Website Privacy Policy.

  • Information That We Collect during the provision of our services:

    Geo-location data: we may collect information such as referrer URL, approximate location, and the time zone where our products and services are installed to provide and manage our services and to assist you in case of troubleshooting.

    Technical information from your devices: we collect technical and diagnostic information about the devices on which the GlassWire App runs. For instance, we automatically collect its up and down status, operating system version, unique GlassWire license number in hash format and an inventory of the software running in it. We do so in order to provide our services to you in the GlassWire application on your computer.

    Traffic Data information: If you select to use certain advanced security functionality, we may collect counters of traffic data generated by each software application running on your endpoint and the destination / origin IP address such traffic goes to/comes from. For the avoidance of doubt, GlassWire does NOT inspect the data packets going through an endpoint, it just records the quantity of traffic and the IP destination of such traffic to/from the endpoint, in order to make a Subscriber and/or an end user aware of any abnormal or unwanted data patterns occurring on GlassWire monitored machines. We do so by aggregating data anonymously through the user base and displaying average values back to you in your application.

    Digital Asset Information: If you select to use GlassWire Network Scanning feature, we may collect MAC address and other descriptive information of the digital assets present in a Subscriber’s computer network in order to display them to you in the GlassWire App. We may also enrichen that data with third party services in order to present you with more accurate information on the brand, model and type of assets present in your computer network. The enrichening of this data is done on a fully anonymized basis.

  • Information we may receive from other sources.
    We may receive information about you if you use the Services. We work with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks and analytics providers) and may receive information about you from them.

How does GlassWire use the information it collects?

We may use the information we collect to provide, develop and improve our products and services, such as:

  • show you how your traffic activity compares with an average user to help you detect any anomalies in your data pattern or any cybersecurity breach of your endpoint;
  • send you alerts when something happens;
  • provide you with products, services, or information you request, for example when you contact us for remote support and troubleshooting;
  • make assessments and recommendations about products, services and safety;
  • provide you with information our products and services or the required notices;
  • customize your experience when using our products and services;
  • improve the products and services that we provide, such as by better tailoring our content to your needs and preferences;
  • internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • delivering marketing communications about GlassWire-related services, products or promotions and to measure or understand the effectiveness of marketing. We may use service providers to send these messages on our behalf, but we do not share your email address with any other third parties without your permission; and
  • detect, prevent, and respond to fraud, intellectual property infringement, violations of law, or other misuse of the products and services.

We may also combine or aggregate in anonymized or non-personally identifiable format any of the information collected through the use of the Services or elsewhere for any of these purposes and for research, statistical and business purposes.

Legal Basis for Processing (EEA only):

If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.

In what circumstances does GlassWire share my data?

The following are the situations where we may share your data:

  • We may share your personal information with any member of our group, which means our ultimate holding company and its subsidiaries.
  • GlassWire partners and third party developers: We may share deidentified data for research, statistical, and business purposes. Additionally, to improve their software, hardware and services designed for use with our products and services, GlassWire may provide any such partner or third party developer with information that is relevant to that partner’s or developer’s software, hardware and/or services, as long as the diagnostic information is in a form that does not personally identify you.
  • Trusted partners working for GlassWire: GlassWire may occasionally use certain third party service providers to help us provide, improve, protect, and promote our services and to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, providing marketing assistance, processing credit card payments, and providing customer service. These third parties may access your information only to perform tasks on our behalf and in compliance with this Privacy Policy.
  • Business Transitions: If we are involved in a merger, acquisition or sale of all or a portion of our assets, your information may be transferred as part of that deal.
  • Law & Order: We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of GlassWire or our users; (d) to enforce or apply our Terms of Use and other agreements; or (e) to protect the rights, property, or safety of GlassWire or others. Your data may be collected, processed and stored by GlassWire or its service providers where you or our servers reside. As a result, your data may be subject to legal requirements, including lawful requirements to disclose data to government authorities, in those jurisdictions.

How do the Services interact with third parties?

The Services allow you to interact with third party services. Any GlassWire products and services data that you choose to share with a third party is governed by that third party’s privacy policy while in that party’s possession. If you select a third party to share your information, we cannot control the collection, storage or sharing of information collected by that party. Always check the privacy policies for any company that collects your data and make sure you are requested to grant/deny permission to access your information.

When you choose to connect third-party products and services through GlassWire products and services, you are shown details about proposed exchange(s) of data between GlassWire products and services and the third party that is providing the products or service. In some cases, GlassWire Services or the third party will instead (or also) ask for permission to control the products that you have connected. GlassWire products and services may receive and process information from third parties, and some of this information may be associated or stored with your GlassWire account.

Any data that GlassWire products and services receive from third-party products and services will be processed and stored by us and will be treated in accordance with this privacy policy. This information may be processed in the same ways as any other data that is a part of your GlassWire account.

How and where does GlassWire process information?

GlassWire users residing in North America will have their information sent to GlassWire Cloud servers located in the United States when transmitting information in the United States.

GlassWire users residing in Europe and the rest of the world will have their information sent to GlassWire Cloud servers based in the European Union when transmitting information from outside of the United States.

To provide you with the Services when you are on the go, we may need to store, process and transmit information in locations around the world from where you are accessing our services– including those outside your country. Those countries may not provide the same level of protection for your data as your home country, and may be available to the governments or agencies under a lawful order of those countries. Where this is the case, we will use reasonable efforts to try to ensure that your data is protected in accordance with this privacy policy.

Remember that when you visit our Website, we collect data as described in our separate Website Privacy Policy.

How long does GlassWire save my data and how can I delete it?

GlassWire generally stores your data on GlassWire’s cloud servers for as long as you remain a GlassWire customer in order to provide you with the Services and for legal compliance purposes. You can view and edit your information on the GlassWire web or mobile application. You can delete your personal data at any time by terminating your account or by writing to us at privacy@glasswire.com. We may retain de-identified data indefinitely.

For personal information that we process on behalf of our Subscribers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.

How does GlassWire keep my information secure?

We take security seriously and care about the integrity of your data. We use administrative, physical, and technical safeguards to protect the confidentiality of personally identifiable information, including encryption, firewalls and SSL (Secure Sockets Layer). However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.

As per the organizational duties introduced by the General Data Protection Regulation (“ GDPR”), we commit to report personal data breaches to the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, also those individuals will be informed without undue delay.

We have appointed a Data Protection Officer of our organization. If you have any questions about the security of your personal information, you can contact him at privacy@glasswire.com.

What are my rights?

At GlassWire we take our users’ rights into the highest regard. For this purpose, we align ourselves to the most advanced privacy regulations available. When in it comes to your Personal Data, we recognize, and commit to respect and enforce, the following rights:

  1. The right to be informed: upon request we will provide you with information about whether we hold or process any of your personal information. To request this information please contact us at privacy@glasswire.com.
  2. The right of access: as a user of our Services, you may access your personal data, at any time, by logging into the GlassWire Website and accessing your profile section.
  3. The right to rectification: as a Subscriber of our Services, you may access and update or change your Account Information by editing them yourself from your profile area of the GlassWire Website.
    A Data Subject who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to their request within thirty (30) days.
  4. The right to erasure: If you no longer wish to make use of our Services, you may erase your personal data from the Account area of the GlassWire Website. You may also exercise this right by making a request, in accordance with Data Protection Laws, by emailing privacy@glasswire.com.
  5. The right to restrict or object processing: You retain the right to request us to refrain from or restrict our processing of your data for the purposes of marketing. To exercise such right, you may click the “unsubscribe” link in any non-transactional email or marketing email from us, update your preferences in your account, or contact us via email at privacy@glasswire.com.
  6. The right to data portability: You retain at all times the right to exercise your right of having your Personal Data exported and transferred – in a safe way – to another provider of Services similar to ours. You may exercise this right by making a request, in accordance with Data Protection Laws, by emailing privacy@glasswire.com.

Any request related to your rights above, will be handled within thirty (30) days from the moment we receive such request.

Children’s Information

The Services are not directed to, nor do we knowingly collect information from, children under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.

Updates to this Policy

We may revise this privacy policy from time to time, and will post the most current version on our website. Please check back frequently to see any updates or changes to this privacy policy. If a revision materially changes your rights, we will notify you and provide you with the opportunity to consent to such changes before applying them to that information.

Contact

If you have any questions, please contact us at privacy@glasswire.com or writing to:
GLASSWIRE
c/o Domotz Inc
120 East 13065 South, Suite 102
Draper, Utah 84020 USA

Last Updated: 25 April 2024

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