Gloo Privacy Statement

This Privacy Statement describes how Gloo, LLC (“Gloo” or “we”) collects, uses, shares, and safeguards personal information.

If you are located in the European Economic Area (EEA), UK or Switzerland (collectively, “EEA+”), please also see our Supplemental EEA+ Privacy Statement.

If you are a resident of California, please also see our Supplemental California Law Disclosures.

You can jump to particular topics by clicking on the following links:

Who are “you”?
Types of Information We Collect
Use and Processing of Information
Sharing of Information
Cookies and Similar Tracking Technologies
Your Choices
How We Protect Information
Other Important Information
Contact Information

We offer a variety of products, services, and software offerings (collectively, the “Services”) that help organizations know and understand their members, prospective members and communities, and measure their impact as they help people on their journey towards growth. As part of providing the Services, we collect information in a variety of ways, including information on our websites and applications, from our organizational customers and/or prospective customers, and from individuals that use the Services.

Who are “you”?

We refer to “you” a lot in this Privacy Statement. To better understand what information is most relevant to you, see the following useful definitions.

Champion Representatives: You access and/or use one or more of the Services provided through the Gloo platform on behalf of one of our customers or prospective customers (which we call a “Champion”). For example, you access the Gloo platform as an administrative user of a church or other organization to purchase, renew, administer or manage the Services purchased by your church or organization.

Growees: You have access to and/or participate in one of our Services designed to facilitate personal growth, such as Journey Studio, Spaces, GlooConnect, or Assessments. In some cases you may choose to access and/or participate in these Services as an individual. In other cases a Champion may engage us to provide you access to these Services.

Website Visitors: You are visiting one of our websites or a Champion’s website to view content because you are curious, or you have heard about us from our marketing and sales channels.

Types of Information We Collect About You

The following chart describes the types of information that are collected in various contexts.

Context	Types of Information	Primary Purpose for Collection and Use
Account Information	If you are a Champion Representative or Growee that registers an account with us, we collect your name, email address, and account password when you create an account. We also collect information relating to the actions that you perform while logged into your account, as well as any other information you choose to provide through your account.	We have a legitimate interest in providing account related functionalities, including, among other things, communicating with you about your account.
Cookies and Similar Tracking Technologies	We use data collection tools such as cookies, web beacons, pixels, scripts, tags, and other similar tracking technologies to automatically collect information on our websites, in connection with certain of our Services, and on websites of our customers. This information may include Device Information, Location Data, Technical Data, and Usage Data. If you receive email from us, we may use similar tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. For more information, please read the “Cookies and Similar Tracking Technologies” section below.	We have a legitimate interest in making our websites operate efficiently, understanding visitors to our websites or websites of our customers and providing the best possible user experience. Where required by law, we base the use of cookies upon consent. We also have a legitimate interest in understanding how you interact with our communications to you.
Communications with Us	If you contact us with questions or comments, request resources and publications, or submit information through a form or field on our websites, we will collect your name, email address or phone number, as well as any other information that you choose to provide.	We have a legitimate interest in responding to your inquiries and requests, receiving and acting upon your feedback and comments, and providing customer service and support.
Customer Contact Information	We collect the name, and contact information, of our customers and their employees with whom we may interact, such as Champion Representatives.	We have a legitimate interest in contacting our customers and communicating with them concerning normal business administration such as projects, services, and billing.
Job Applicants	If you apply for a job posting or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.	We use this information to process applications, make decisions about recruitment and in anticipation of a contract of employment. In some contexts, we are also required by law to collect information about applicants and/or employees. We also have a legitimate interest in using your information to evaluate candidates for job openings. We also have a legitimate interest in considering individuals for employment and managing onboarding and work force operations.
Mailing List	When you sign up to receive communications from us, or to participate in a webinar, we collect your email address and/or postal address.	We share information about our Services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our Services.
Payment Information	If you are a Champion Representative or a Growee that purchases one or more of our Services, we will ask you to provide your name, payment information, and billing address when you place your order.	We use this information to perform our contract to provide you with the requested Services, including to process your payment(s), fulfill your order(s), and to send you communications and updates about your order.
Web Log Information	When you visit our websites, our servers automatically gather certain information. This information may include but is not limited to your IP address, unique device identifier, date/time stamp, web browser or operating system, address domain name, click-activity, and referring website.	We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, we use this information to detect and prevent fraud, illegal activity, and/or the misuse of our websites. We also have a legitimate interest in understanding how visitors interact with our websites to better improve them.
Growee Services	If you are a Growee who accesses and/or participates in any of our Services designed to facilitate personal growth, we collect the information you share with us and/or submit through the Services. Depending on the nature of the Service, this information may include your name and contact information; demographic information (such as age, gender, marital status, and income); location information (such as zip code or location); religious information (such as your religious preferences and/or what religious organization(s) you attend); and growth signals, views and characteristics, such as your growth steps, assessment and other survey responses, interests, views, opinions, perspectives, traits, and characteristics. If a customer/Champion has engaged us to provide Services, we may receive some of this information from them so that we may begin to offer our Services to you.	We have a legitimate interest in providing you with Services, or in allowing our customers to provide you with our Services. The information collected as part of the Service may be used to develop aggregated insights that do not contain any personal information about you. We may give you the option, however, to consent to sharing your personal information with our customer or other third parties.

In addition to the information that we collect from you directly, we may also obtain information about you from other sources including our customers / Champions, third-party business partners, data providers or third-party databases, advertising networks, social media platforms and networks, and publicly available sources and other users. Note that, as described on our data integrity statement, the information that we may obtain from certain data providers, third-party databases, and advertising networks is de-identified (i.e., it is not reasonably linked to individual people).

Use and Processing of Information

In addition to the purposes and uses described above, we collect and use information for several purposes, including:

To enable you to access and use our websites and to provide Services you or a Champion requests.
To respond to your requests, questions, comments, and other inquiries.
To send you information regarding your account, changes to our terms, conditions and policies, and/or other administrative information.
To send marketing and promotional materials including information relating to our Services or those of our business partners.
To administer, maintain, evaluate, and improve our websites and Services, and to develop new products and services.
To conduct research and analytics related to our websites and Services, including combining any or all of the information that we collect or obtain.
To manage our business operations and perform our obligations and exercise our rights under any agreement that you or your organization has with us.
To provide online behavioral advertising.
As we believe to be necessary or appropriate to: (a) comply with judicial proceedings, court orders or legal processes or to respond to proper governmental request or investigation; (b) detect, prevent, or otherwise address fraud, security or technical issues; (c) protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, procedures, and terms and conditions; and (d) protect against harm to the rights, property or safety of Gloo, our users or the public.
For such other purposes as you may consent (from time to time) or as otherwise permitted or required by applicable law.

Although the sections above describe our primary purpose for collecting and using your information, in many situations we may have more than one purpose. For example, if you retain us to provide Services we may collect your information to perform our contract with you, but we also collect your information because we have a legitimate interest in understanding who our customers are and what services we perform on their behalf. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of Information

In addition to the specific situations discussed elsewhere in this Privacy Statement, we share information in the following situations, as permitted by applicable law:

Organizational Customers. We share information with Champions and other organizations with whom we have a contract to provide Services. For example, if you are a Champion Representative or a Growee whose account is associated with an organization using our Services, your account information may be shared with the administrative users of that organization. Also, if you are a Growee and your organization engaged us to administer an assessment, we may use your personal information to ask you to complete an assessment at your organization’s request. If you complete an assessment, we process the personal information you choose to provide to us to develop aggregated insights that do not contain any personal information about you or anyone else whom your organization asked to complete the assessment. We share these aggregated insights with your organization to facilitate your organization’s purposes for deploying the assessment. In addition, we may ask for your consent to share personal information from your assessment with your organization, as described below.
Third Parties. Certain Services are provided by third parties on Gloo’s platform. By selecting or purchasing a third-party Service, you instruct Gloo to share your name, email address and other contact information with the applicable third party. If you do not desire for Gloo to share your personal information with these third parties, do not select or purchase these third party Services. Further, if a third party has agreed to pay Fees for an Service on your behalf, you instruct Gloo to share your name and other contact information, and the Service you have purchased, with the applicable third party payor.
Other Disclosures with Your Consent. We may ask for your consent to share your information with other recipients not described elsewhere in this Privacy Statement. For example, our Services include certain social media and other features that allow you to share information with other users, persons and organizations when you use them. We provide you with notices while you use our Services that explain when one of the features you are using will result in the disclosure of your personal information to other users, persons and organizations. We also provide settings that allow you to configure to whom your posts and content are available. When you use these types of features, you instruct us to disclose your information according to our notices and your settings.
Service Providers. We share information with service providers as necessary for them to assist us with our business operations and provide services to us, subject to appropriate confidentiality and data protection agreements. Among other things, service providers assist us with website hosting, data storage, data analytics, helping with addressing security, fixing errors, processing payments, providing identity verification services, providing technical support, sending communications, providing assessments, fulfilling user requests, and other activities related to the management of our business and services.
To comply with law and protect legal interests. We may disclose information for legal reasons as we believe to be necessary or appropriate to: (a) satisfy any applicable law, legal process, or proper governmental request; (b) enforce any agreement we may have entered into with you or your organization, including investigating any violations or asserting remedies; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect against harm (whether tangible or intangible) to the rights, property or safety of Gloo, our users or the public as required or permitted by law; and (e) establish or exercise our rights, defend against a legal claim, and investigate, prevent or take action regarding possible illegal activities or a violation of our policies.
In connection with a sale or similar transaction. We may share information with a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction.

Cookies and Similar Tracking Technologies

We use cookies and similar tracking technologies to collect certain information on our websites, through our Services, or on the websites of our customers. We also permit certain third parties to use cookies and similar tracking technologies to collect information about your use of our websites or Services or the websites of our customers. The information collected by these tracking technologies may include (a) your internet protocol (IP) address, unique device identifiers, location, browser type, and Internet service provider information (“Technical Data”); (b) information about when and how you access and use our websites or Services, such as the domains you visit, what features you used and for how long, the website that referred you to us, and date/time stamps associated with your usage (“Usage Data”); (c) information about the device you use to access the websites or Services, such as device type, device ID, and device/browser settings (“Device Information”); and (d) location of the device used to access the websites or Services derived from GPS or WiFi use (“Location Information”).

The types of technologies we use may include:

Cookies: Cookies are small data files containing a string of characters that a website sends to your computer. Cookies are stored on the device that you use to access a website. We may place cookies on our websites, or on the websites of our customers.
Pixel tags (or web beacons): A pixel tag is a small image placed on a website or within the body of an email for the purpose of tracking activity when you visit a website, click on a link, or open an email, and is often used in combination with cookies. We may use pixel tags or web beacons on our websites, or in our emails, or on the websites or emails of our customers.
Website and mobile application log files: We may keep a record of any devices or IP addresses that visit our websites, or the websites of our customers.

We use the information collected through tracking technologies for several reasons, including:

To make our Services easier to use.
To gather metrics about how users interact with our Services, our websites, or the websites of our customers.
For security reasons.
To provide personalized content. For example, we may store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can identify you across devices and personalize the content you see.
To improve our Services.
To advertise to you. This may include delivering "targeted ads" based upon your activities. For more information, please read the “Online Behavioral Advertising” section below.

Your Choices

Promotional Emails. You can opt out of receiving marketing or promotional emails by following the unsubscribe instructions contained in marketing or promotional emails you receive from us. If you decide not to receive marketing or promotional emails, we may still send you service or transactional-related communications, such as notices about your account.
Promotional Text Messages. You can opt out of receiving text messages at any time by replying “STOP,” or following the unsubscribe instructions contained in the text message.
Accessing, Changing, Deleting or Exercising Other Rights in Relation to Your Personal Information. If you have registered for an account, you may review, update, correct, or delete certain personal information that you have provided to us by logging into your account.
Data Subject Rights. Depending on the state or country in which you reside, you may have additional rights with respect to your personal information, including the right to access, correct, update, or delete your personal information; receive a copy of your personal information; and/or restrict or object to how we process information about you. To submit a request to exercise any such rights (if they apply to you), please use our Data Subject Rights request form. Please note that we may take steps to verify your identity before processing your request. We may ask you to submit a notarized form or other information related to your relationship with us to validate your identity, or we may use a third-party vendor to provide identity verification services. For additional information or to understand if specific rights apply to you, please follow these instructions:
If you are located in the European Economic Area, UK or Switzerland, please see our Supplemental EEA+ Privacy Statement here for details.
If you are a resident of California, please see our Supplemental California Law Disclosures here for details.

How We Protect Information

We have implemented measures intended to protect your personal information from unauthorized access, use, or disclosure. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

The safety and security of your information also depends on you. You are responsible for keeping your account information and password secure and you should notify us of any unauthorized use of your account promptly.

Other Important Information

Transfers of Information to Other Countries. We are based in the United States. If you are located outside of the United States, you should be aware that your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States, and the laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.
Children. Our Services are not intended for persons under 13 years of age. We do not knowingly collect or maintain personal information from persons under 13 years of age. If we learn that we have collected personal information from persons under 13 through our Services, we will take appropriate steps to delete this information.
Third Parties and Links to Other Websites and Services. Our websites and Services may contain links to websites, content, or services owned or operated by third parties. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or shared.

In addition, we are not responsible for the privacy practices or disclosures of third parties that use our Services. Organizations that engage us to provide our Services to individuals associated with them have their own privacy practices and policies.

Social Media Networks, Plugins, and Third-Party Tools. Some of our websites and Services may include plugins, widgets, or other features offered by social media platforms and networks, such as Facebook and Instagram. If you choose to use these features, certain information may be shared with or collected by those social media companies. For more information about the privacy practices of those social media companies, including what information may be collected and shared, please review the privacy policies and terms of the applicable company.

Our websites and Services may also include functionalities and/or services provided by third parties. For example, some of our websites utilize the YouTube API Services to provide video content. When you interact with the YouTube functionality available through one of our websites, you will be subject to agree to the YouTube Terms of Service (https://www.youtube.com/t/terms) and Privacy Policy (http://www.google.com/policies/privacy). We also use Google Places API on some of our websites to make it easier for our users to perform place-related searches and to fill in address details automatically. The data collected by this feature is subject to Google’s Terms of Service, located at: https://www.google.com/intl/en/help/terms_maps.html; and Google's Privacy Policy, located at: https://www.google.com/policies/privacy/.

Online Behavioral Advertising. We may work with third-party entities, including ad networks and other advertising companies, for marketing and advertising purposes. These third parties may use tracking technologies (such as those described in the “Cookies and Similar Tracking Technologies” section above) to collect or receive information from our websites and elsewhere on the internet and use that information to provide advertising about products and services tailored to your interests. This is sometimes referred to as "interest-based" or "online behavioral" advertising.

Certain third parties provide ways to opt out of advertising cookies across multiple sites. You can learn more by visiting the sites of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://www.aboutads.info).

Please note, opting out of interest-based advertising does not mean you will no longer see advertising online. It does mean that the company or companies from which you opt out will no longer show ads that have been tailored to your interests. We do not guarantee that all of the third parties we work with will honor the elections you make using those options, but we strive to work with third parties that do.

How We Respond to “Do Not Track” Signals. Some web browsers incorporate a "Do Not Track" (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. Not all browsers offer a DNT option and there is currently no industry consensus for how to recognize or respond to a DNT signal. For these reasons, Gloo does not currently respond to DNT signals.
Changes to This Privacy Statement. We may update this Privacy Statement from time to time to reflect changes to our practices, technology, legal requirements, and other factors. When changes are made to this Privacy Statement, they will become effective immediately upon posting. You can check the date at the bottom of this page to see when this Privacy Statement was last revised. We encourage you to review this Privacy Statement periodically for the latest information on our information processing practices.

To the extent that our Privacy Statement changes in a material way, the Privacy Statement that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent (express or implied) to the new Privacy Statement where and as required by applicable law.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

Data Protection Officer
Gloo
831 Pearl Street
Boulder, CO 80305
privacy@gloo.us

Last Revised and Effective: December 10, 2020