Privacy Policy

About Glincker

Glincker is committed to safeguarding the privacy of our website visitors and service users. This policy outlines how we handle your personal information with transparency and care.

Applicability

This Privacy Policy applies to all personal information collected or processed by Glincker, regardless of the method of collection or processing. This includes, but is not limited to, information collected through our website, mobile applications, desktop applications, APIs, and any other online services or platforms operated by Glincker.

Our policy also applies to any interaction you have with our services, whether through direct engagement, third-party integrations, or automated systems. It covers data collected when you access our services, create an account, interact with our support team, subscribe to our newsletters, participate in surveys, or engage in any other activities within the scope of our services.

This Privacy Policy is intended to cover the collection, use, and disclosure of information by Glincker in accordance with applicable laws, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the EU Data Act, and other relevant data protection laws. If you are accessing our services from a region with specific privacy requirements, our practices will align with the applicable regulations of that region to ensure your rights are respected and protected.

It is important to note that this Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our services. We encourage you to review the privacy policies of any third-party services you interact with to understand their data practices and your rights concerning your personal information.

By using our website, applications, or services, you consent to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with the terms of this policy, please refrain from using our services.

Legal Basis for Processing (GDPR)

Under the GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide our services to you and fulfill our contractual obligations
• Legitimate Interests: Processing for our legitimate business interests, such as improving our services, fraud prevention, and security
• Consent: Where you have given clear consent for us to process your personal data for specific purposes
• Legal Obligations: Processing necessary to comply with applicable laws and regulations

Information We Collect

Information You Provide Directly

We collect information that you provide directly to us when you use our services. This includes:

• Personal Identification Information: Such as your name, email address, postal address, phone number, and other contact details that allow us to communicate with you.
• Account Information: Information required to create an account or profile, such as a username, password, and security questions or other authentication details.
• Payment Information: If you make a purchase or conduct transactions through our services, we collect payment details, including credit card numbers, billing addresses, and other financial information.
• Communication Content: Any information you provide when you communicate with us directly, such as through customer support requests, surveys, feedback, or participation in promotions.
• User-Generated Content: Information you choose to share publicly or privately through our services, such as comments, reviews, photographs, or other submissions.
• Preferences and Interests: Information about your preferences, settings, and interests that you provide through your interactions with our services or surveys.
• Other Information: Any additional information you provide voluntarily, which may include personal details relevant to specific activities, features, or services offered.

We use this information to provide, maintain, and improve our services, to communicate with you, and to personalize your experience.

Information from Third Parties

We may receive information about you from third parties to enhance or supplement the information we collect directly from you. This information may include:

• Business Partners: We may receive information from our business partners, such as demographic information, your interests, and preferences, or your interactions with their services, which helps us understand your needs and provide more tailored services.
• Data Brokers or Aggregators: We may acquire information from data brokers or aggregators who provide us with additional details about you, such as publicly available information, your interests, or potential purchasing behavior.
• Social Media Platforms: If you engage with us on social media platforms, we may collect information from your public profile, such as your name, username, profile picture, and any other information you choose to share with us or make publicly available.
• Marketing or Advertising Partners: We may receive information from marketing or advertising partners that helps us deliver relevant advertisements or marketing campaigns and to better understand the effectiveness of our marketing efforts.
• Service Providers: We may receive information from third-party service providers who support our business operations, such as payment processors, fraud prevention services, analytics providers, and customer support platforms.
• Publicly Available Sources: We may obtain information about you from publicly accessible sources, including public databases, news outlets, and social media platforms.

We use this information to improve our services, enhance user experiences, prevent fraud, and engage in more effective marketing and communication activities.

Information from Customers

We may collect information provided by our customers about their users or employees in the context of delivering our services. This information may include:

• User Data: Information about users, such as names, email addresses, contact details, job titles, and other professional or personal information that our customers provide to us.
• Employee Data: Details about employees, such as identification numbers, employment status, roles and responsibilities, performance data, and other employment-related information.
• Service Usage Data: Information on how the users or employees interact with our services, including usage patterns, preferences, and feedback provided by our customers.
• Communication Records: Logs of communications between our customers and their users or employees, such as emails, messages, or other correspondence facilitated through our services.
• Compliance and Verification Data: Information required for compliance with legal, regulatory, and security requirements, including identity verification details or other documentation.
• Other Relevant Information: Any additional information our customers choose to provide about their users or employees that is necessary for the provision of our services or as agreed upon with our customers.

We use this information to fulfill our contractual obligations to our customers, enhance service delivery, improve user experience, and ensure compliance with applicable laws and regulations.

Information Collected Automatically

We automatically collect certain information about your use of our services. This information is collected through various technologies and may include:

• IP Address: Your Internet Protocol (IP) address, which may provide general location information.
• Browser Type and Version: Information about the browser you are using to access our services, including the type, version, and settings.
• Operating System: Details about the operating system of your device, including the version and other related technical information.
• Device Information: Information about the device you use to access our services, such as device type, model, unique device identifiers, and other device-related data.
• Access Times and Dates: Information about when you access our services, including timestamps of your visits and usage patterns.
• Referring URLs: The webpages or links that directed you to our services, including referring URLs and exit pages.
• Usage Data: Information about your interaction with our services, including pages viewed, clicks, scrolling data, and other activity related to your use of the services.
• Log Files: Server logs and other data generated by your interactions with our services, which may include IP addresses, internet service provider (ISP), referring/exit pages, and date/time stamps.
• Cookies and Similar Technologies: Data collected through cookies, web beacons, pixel tags, and similar technologies, which help us understand how you use our services and improve your experience.

We use this information to analyze trends, administer the services, track user movements around the services, gather demographic information about our user base, and enhance the functionality and security of our services.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to monitor the activity on our services and store certain information. These technologies help us enhance your experience, analyze our traffic, and understand how you interact with our services. The types of cookies and tracking technologies we use include:

• Essential Cookies: These cookies are necessary for the operation of our services. They enable you to navigate our site and use its features, such as accessing secure areas.
• Performance and Analytics Cookies: These cookies collect information about how you use our services, such as which pages you visit most often and if you receive error messages from certain pages. This data helps us improve the performance and design of our services.
• Functionality Cookies: These cookies allow us to remember your preferences and provide enhanced, more personalized features. For example, they can remember your login details or language preferences.
• Targeting and Advertising Cookies: These cookies are used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns.
• Web Beacons and Pixel Tags: Small electronic files that allow us, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Managing Cookies and Tracking Technologies

You have the option to control your cookie preferences through your browser settings. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling cookies may affect the functionality and features of our services.

To learn more about cookies and how to manage them, you can visit the help section of your browser or the following resources:

• Google Chrome
• Mozilla Firefox
• Microsoft Edge
• Apple Safari

By using our services, you consent to the use of cookies and tracking technologies as described in this policy. You can change your preferences at any time by adjusting your browser settings.

How We Use Your Information

We use the information we collect for various purposes to enhance and optimize our services. These purposes include, but are not limited to:

A. Account Management: To create, maintain, and manage your account, including authenticating your identity and processing transactions.

B. Communication: To communicate with you directly, such as sending you service-related announcements, updates, security alerts, or administrative messages.

C. Customer Support: To provide customer support and respond to your inquiries, feedback, and requests, ensuring effective and timely assistance.

D. Data Analysis and Research: To analyze trends, usage, and activities on our services to better understand user behavior and preferences and to improve our offerings.

E. Improving Our Services: To develop, maintain, and improve our services and features, including monitoring and analyzing usage patterns and performing research and development.

F. Marketing and Advertising: To send you promotional messages and marketing communications that we believe may interest you, including information about products, services, and events, and to measure the effectiveness of such campaigns.

G. Personalization: To personalize and enhance your experience on our services, such as by providing content, recommendations, and features tailored to your preferences and interests.

H. Security and Fraud Prevention: To detect, investigate, and prevent fraudulent, unauthorized, or illegal activities, and to protect the rights, safety, and security of our users and the integrity of our services.

I. Legal Compliance: To comply with applicable legal requirements, such as responding to subpoenas, court orders, or other legal processes, and to enforce our terms and conditions.

J. Transaction Processing: To process transactions and fulfill orders, including sending confirmations and invoices, and to manage payment processing and collections.

K. Third-Party Integration: To facilitate integration and interaction with third-party services, platforms, or applications as necessary to provide a seamless user experience.

L. User Engagement and Retention: To engage with users, encourage interaction with our services, and retain users through loyalty programs, surveys, contests, and feedback solicitation.

We are committed to ensuring the privacy and security of your information while using it to provide, maintain, and improve our services.

Data Sharing and Disclosure

We do not sell your personal information. We only share your personal information with third parties as described in this policy:

• Service Providers: We may share your personal information with vendors, consultants, and other service providers who need access to such information to carry out work on our behalf. These third parties are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.

• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be transferred as a business asset.

• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

• Protection of Rights: We may share your information if we believe in good faith that such disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request.

• Affiliates and Subsidiaries: We may share your information with our affiliates and subsidiaries for purposes consistent with this Privacy Policy, such as providing and improving our services.

• Consent: We may share your information with third parties if you have provided your consent to do so. You have the right to withdraw your consent at any time.

• Aggregate and De-Identified Information: We may share aggregated or de-identified information, which cannot reasonably be used to identify you. This information may be shared for various purposes, including research, analysis, and marketing.

We ensure that any third party with whom we share your personal information is contractually obligated to maintain the confidentiality and security of your data and to use it solely for the purposes for which it was provided.

Data Security

We take reasonable and appropriate measures to protect the information that we collect from or about you from unauthorized access, use, or disclosure. Our security practices include, but are not limited to:

• Encryption: We use encryption protocols (TLS 1.3) to protect sensitive information during transmission over the internet and AES-256 encryption to safeguard your data at rest.

• Access Controls: We implement access controls to restrict access to personal information to authorized personnel only. This includes role-based access and multi-factor authentication for sensitive data and systems.

• Regular Security Assessments: We conduct regular security assessments, including vulnerability scanning and penetration testing, to identify and mitigate potential security risks.

• Data Anonymization and Pseudonymization: Where appropriate, we anonymize or pseudonymize personal information to reduce the risk of identifying individuals in the event of unauthorized access.

• Monitoring and Logging: We maintain activity logs and monitor our systems for suspicious activity to detect and respond to potential security incidents in a timely manner.

• Employee Training: We provide regular training to our employees on data security best practices and require adherence to our internal security policies and procedures.

• Physical Security: We employ physical security measures to protect our facilities and the hardware where data is stored, such as controlled access to data centers and secured storage environments.

Despite our efforts to protect your information, it is important to note that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

We encourage you to take precautions to protect your personal information when using the internet, such as using strong passwords, enabling two-factor authentication, and being cautious with the information you share online.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including to provide our services, comply with our legal obligations, resolve disputes, and enforce our agreements. Our data retention practices include:

Purpose-Based Retention: We retain your information for the duration necessary to fulfill the purposes outlined in this Privacy Policy, such as maintaining your account, providing customer support, and processing transactions.

Specific Retention Periods:

• Account data: Retained while your account is active, plus 30 days after deletion request
• Transaction records: Retained for 7 years for tax and legal compliance
• Support communications: Retained for 3 years after last interaction
• Usage analytics: Aggregated data retained indefinitely; personal identifiers removed after 26 months
• Backup data: May persist for up to 90 days after deletion from active systems

Legal and Regulatory Compliance: We retain your information as required to comply with applicable laws, regulations, and legal obligations. This may include retaining certain information for tax, auditing, or financial reporting purposes.

Dispute Resolution: We retain your information as necessary to resolve disputes, enforce our agreements, and protect our legal rights. This may involve retaining information beyond the termination of your account or your use of our services.

Security and Fraud Prevention: We retain your information as needed to prevent fraud, detect security incidents, and ensure the integrity and security of our services.

Deletion and Anonymization: When your personal information is no longer needed for the purposes for which it was collected or required by law, we will delete, anonymize, or aggregate it to ensure that you cannot be identified from the information.

User Requests: You have the right to request the deletion of your personal information at any time, subject to certain legal or contractual obligations. If you would like to request deletion or have questions about our data retention practices, please contact us.

User Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. These rights may include:

Right to Access: You have the right to request access to the personal information we hold about you, including details on how we use your data and whom we share it with.

Right to Correction: You have the right to request that we correct any inaccuracies or incomplete information we hold about you.

Right to Deletion: You have the right to request the deletion of your personal information, subject to certain exceptions, such as if the information is needed to comply with a legal obligation.

Right to Object: You have the right to object to certain types of processing of your personal information, including processing for direct marketing purposes or when processing is based on our legitimate interests.

Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information under certain circumstances, such as if you contest the accuracy of the information or object to our processing.

Right to Data Portability: You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format (JSON, CSV), and to transmit that data to another controller.

Right to Withdraw Consent: If we have collected and processed your personal information with your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

Right to Complain: You have the right to lodge a complaint with a data protection authority if you believe that your rights have been violated or that your personal information has not been handled in accordance with applicable data protection laws.

How to Exercise Your Rights: You can exercise any of these rights through your account settings, by emailing [email protected], or by contacting us using the information provided at the end of this policy. We will respond to your request within 30 days (or within the timeframe required by applicable law).

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International Data Transfers

Your information, including personal data, may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. We take appropriate steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy and applicable data protection laws, regardless of where the data is transferred to or stored.

• Standard Contractual Clauses: We implement EU-approved Standard Contractual Clauses (SCCs) to ensure that your personal data is protected when transferred internationally.

• UK International Data Transfer Agreement: For transfers from the UK, we use the UK Addendum to the SCCs.

• Adequacy Decisions: In some cases, we may transfer your data to countries that have been deemed to provide an adequate level of protection by relevant data protection authorities.

• Your Consent: By using our services, you consent to the transfer of your information to countries outside of your country of residence, which may have different data protection rules than your country.

If you would like more information about how we protect your personal information during international transfers, please contact us.

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Third-Party Services

Our services may contain links to third-party websites, applications, or services that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third party's site. We strongly encourage you to review the Privacy Policy of every site you visit, as we have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

• No Endorsement: The inclusion of a link to a third-party site does not imply endorsement of the site or its content by us.

• No Control Over Third-Party Content: We do not control third-party sites and are not responsible for their content or privacy practices.

• Risks of Third-Party Sites: Please be aware that third-party sites may collect personal information about you. We are not responsible for the privacy practices or the content of those sites.

For your safety and privacy, we recommend that you exercise caution and consult the privacy policies of these third-party websites or services before sharing any personal information.

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Children's Privacy

Our services are not intended for use by children under the age of 13 (or 16 in the EEA), and we do not knowingly collect personal information from children under these ages. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete that information from our records as soon as possible.

• Parental Control: If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately. We will take appropriate measures to promptly remove any such information.

• Age Restrictions: We encourage parents and guardians to monitor their children's online activity and to help enforce our Privacy Policy by instructing their children never to provide personal information on our services without their permission.

• COPPA Compliance: We comply with the Children's Online Privacy Protection Act (COPPA) and other applicable laws designed to protect children's privacy.

If you have any questions or concerns about children's privacy, please contact us.

EU Data Act Compliance

Effective September 12, 2025, the EU Data Act introduces new rights for data portability and switching between service providers. As part of our commitment to compliance:

Data Portability: You have the right to export all your data from Glincker in a machine-readable format. This includes documents, account settings, and associated metadata. You can initiate an export at any time from your account settings.

Switching Rights: You have the right to switch to another service provider. We will:

• Provide your data in a commonly used, machine-readable format
• Not impose unreasonable switching fees
• Not create technical barriers to switching
• Support reasonable transition periods to minimize disruption

Interoperability: We are committed to supporting interoperability standards that allow your data to be used with other compatible services.

Data Access: Where applicable, you may request access to non-personal data generated through your use of our services, including aggregated usage data and performance metrics.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other reasons. When we make changes, we will:

• Post the Updated Policy: We will post the updated Privacy Policy on this page with a new "Last Updated" date at the top of the policy to indicate when the changes were made.

• Provide Notification: If the changes are significant, we will provide a more prominent notice, such as an email notification or a notice on our website or within our services, to inform you about the changes.

• Review and Acceptance: By continuing to access or use our services after those changes become effective, you agree to be bound by the revised Privacy Policy. If you do not agree to the new terms, please discontinue using our services.

• Your Responsibility to Review: We encourage you to review this Privacy Policy periodically for any changes. Your continued use of our services following the posting of changes constitutes your acceptance of such changes.

• Historical Versions: If you would like to review previous versions of our Privacy Policy, please contact us, and we will provide a copy of the policy that was in effect during your use of our services.

If you have any questions about changes to this Privacy Policy, please contact us. We are committed to safeguarding your privacy and will notify you of any significant changes in a manner that allows you to stay informed about how we handle your personal information.

Data Protection Officer and Contact Information

If you have any questions or concerns about our Privacy Policy or the data we hold about you, or if you wish to exercise any of your rights, please contact our Data Protection Officer (DPO) or Privacy Team:

• Data Protection Officer (DPO): Gagan Deep Singh
• Email: [email protected]

We are committed to addressing any concerns you may have regarding your privacy and the protection of your personal information.

Artificial Intelligence and Automated Decision-Making

AI-Powered Features

Glincker uses artificial intelligence (AI) and machine learning technologies to enhance our services. We are committed to transparency about how these technologies process your data:

AI Features We Use:

• Smart Suggestions: AI helps provide content recommendations and autocomplete suggestions based on your usage patterns
• Search Enhancement: Machine learning improves search relevance and results ranking
• Anomaly Detection: AI monitors for unusual account activity to protect your security
• Support Automation: AI-powered chatbots may assist with common support inquiries

How AI Processes Your Data:

• AI models may analyze your content to provide relevant features (e.g., suggestions, categorization)
• We do not train general-purpose AI models on your private content without explicit consent
• AI processing occurs on secure infrastructure with the same protections as other data processing

Automated Decision-Making (GDPR Article 22)

We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you. All significant decisions involving your account are subject to human review.

Your Rights Regarding AI:

• Transparency: You can request information about how AI features use your data
• Opt-Out: You can disable certain AI-powered features in your account settings
• Human Review: You can request human review of any automated decision that affects you
• Explanation: You have the right to meaningful information about the logic involved in automated processing

Profiling

We may engage in profiling to personalize your experience and provide relevant recommendations. This includes:

• Analyzing usage patterns to suggest relevant features
• Categorizing users for product improvement purposes
• Tailoring communications based on your preferences

You can opt out of profiling for marketing purposes at any time through your account settings or by contacting us.

Do Not Track Signals

Our services do not respond to "Do Not Track" (DNT) signals. DNT is a privacy preference that users can set in their web browsers to indicate that they do not want certain information about their webpage visits collected across websites. If you wish to learn more about "Do Not Track," please visit All About DNT.

Data Breach Notification

In the event of a data breach that may compromise your personal information, we will:

• Notify affected individuals within 72 hours of becoming aware of the breach (where required by GDPR)
• Notify relevant supervisory authorities as required by law
• Provide information about what data was affected and what steps we are taking
• Offer guidance on protective measures you can take

We take all necessary measures to mitigate any potential adverse effects of such a breach.

Your Privacy Rights (California and EU Residents)

In addition to the general rights outlined above, residents of California and the European Union have specific rights under the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR), respectively.

California Residents (CCPA/CPRA)

• Right to Know: You have the right to request information about the categories and specific pieces of personal data we have collected about you, the sources of that data, the purposes for collection, and with whom we share it.
• Right to Delete: You have the right to request deletion of your personal data, subject to certain exceptions.
• Right to Opt-Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your personal data. Note: We do not sell your personal information.
• Right to Correct: You have the right to request correction of inaccurate personal data.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive personal information.
• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your privacy rights.

EU/EEA Residents (GDPR)

• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Erasure ("Right to Be Forgotten"): You have the right to request that we erase your personal data, subject to certain conditions.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local Data Protection Authority.

US State Privacy Laws (2025)

In addition to California, several US states have enacted comprehensive privacy laws that took effect in 2024-2025. If you reside in one of these states, you may have additional rights:

States with Active Privacy Laws:

• Virginia (VCDPA) - Effective January 2023
• Colorado (CPA) - Effective July 2023
• Connecticut (CTDPA) - Effective July 2023
• Utah (UCPA) - Effective December 2023
• Oregon (OCPA) - Effective July 2024
• Texas (TDPSA) - Effective July 2024
• Montana (MCDPA) - Effective October 2024
• Delaware (DPDPA) - Effective January 2025
• Iowa (ICDPA) - Effective January 2025
• New Hampshire (SB255) - Effective January 2025
• New Jersey (SB332) - Effective January 2025
• Tennessee (TIPA) - Effective July 2025
• Minnesota (MCDPA) - Effective July 2025
• Maryland (MODPA) - Effective October 2025

Common Rights Under These Laws:

• Right to know what personal data is collected
• Right to access your personal data
• Right to delete your personal data
• Right to correct inaccurate data
• Right to opt out of targeted advertising
• Right to opt out of sale of personal data
• Right to data portability

How to Exercise Your Rights: Regardless of your state of residence, you can exercise any available privacy rights by contacting us at [email protected] or through your account settings.

To exercise these rights, please contact us using the information provided in the "Contact Information" section.

Contact Us

If you have any questions, concerns, or requests regarding our Privacy Policy or your personal information, or if you would like to exercise your rights, please feel free to contact us through any of the following methods:

• Email: [email protected]

• Contact Form: Visit our website and fill out the contact form at www.glincker.com/contact.

We are committed to addressing your inquiries and concerns promptly and will respond to your request within the time frame required by applicable law (typically within 30 days). Your privacy is important to us, and we strive to ensure your personal information is handled securely and in accordance with this Privacy Policy.