GlowLocal Privacy Policy

GlowLocal LLC ("GlowLocal," "we," "us," or "our") respects the privacy of individuals who visit our website, use the GlowLocal platform, or interact with us.

This Privacy Policy describes how we collect, use, disclose, and protect information in connection with the GlowLocal website, platform, software, and related services (collectively, the "Services").

GlowLocal is a business-to-business service designed for franchisors, multi-location businesses, and other organizations that purchase or administer the Services (each, a "Customer"), and the individuals authorized to use the Services on their behalf ("Authorized Users").

1. Contact Information

GlowLocal LLC

50 Sapphire

Irvine, CA 92602

United States

Email: privacy@glowlocal.ai

2. Information We Collect

The information we collect depends on how an individual interacts with GlowLocal.

Account and Business Information

When a Customer or Authorized User uses GlowLocal, we may collect information such as:

• name;
• business email address;
• business telephone number;
• job title or role;
• company or franchise brand;
• business location;
• business address;
• location identification information;
• account credentials; and
• account permissions.

Platform Activity

We may collect information about activity within GlowLocal, including:

• missions assigned;
• missions completed;
• opportunities viewed or completed;
• vendors or organizations viewed or added;
• GlowPoints earned;
• GlowScore;
• leaderboard information;
• platform engagement;
• feature usage;
• mission edits;
• timestamps;
• administrative actions; and
• other interactions with the Services.

Uploaded Content

Authorized Users may upload photographs, images, text, or other materials to demonstrate completion of missions or opportunities or otherwise use the Services.

We process this information to provide the Services to the Customer and its Authorized Users. GlowLocal is not intended to collect information about a Customer's end consumers.

Customers and Authorized Users should not intentionally upload consumer personal information, sensitive personal information, or content they do not have the right or authorization to provide to GlowLocal, unless GlowLocal expressly requests the information for a legitimate business purpose. Where uploaded content incidentally contains information about third parties, Customers and Authorized Users are responsible for using reasonable care to minimize unnecessary personal information and for having any authorization required to provide the content.

Payment Information

Customers may pay through credit card, ACH, invoice, or other approved payment methods. Payment transactions may be processed through GlowLocal’s designated third-party payment processor. When payment information is submitted through GlowLocal’s designated third-party payment processor, GlowLocal does not directly receive or store full payment-card numbers or bank-account credentials on its own systems. GlowLocal may receive and retain limited payment-related information, such as billing contact information, payment status, transaction identifiers, payment method type, and the last four digits of a payment method, as reasonably necessary for billing, accounting, support, and recordkeeping.

Communications

If you contact GlowLocal, request information, communicate with our team, or participate in sales or support conversations, we may collect:

• your name;
• email address;
• company;
• telephone number;
• message contents; and
• related communication records.

Automatically Collected Information

When you access our website or Services, GlowLocal and its service providers may automatically collect technical information such as:

• IP address;
• browser type;
• device type;
• operating system;
• referring pages;
• pages or features accessed;
• dates and times of activity;
• session information;
• approximate geographic information derived from an IP address; and
• application performance or error information.

We may use cookies, local storage, log files, software development kits, or similar technologies for these purposes.

Sources of Information

Depending on the context, we may obtain information:

• directly from Customers, Authorized Users, website visitors, prospects, or other individuals;
• from the Customer that created or administers an Authorized User account;
• automatically from browsers, devices, and use of the Services;
• from service providers that support our operations; and
• from publicly available business, event, organization, and community sources as described in Section 5.

3. How We Use Information

We may use information to:

• provide and operate GlowLocal;
• create and administer accounts;
• authenticate users;
• personalize the Services by brand or location;
• generate roadmaps and missions;
• identify local opportunities;
• identify potential vendors and organizations;
• generate AI-powered recommendations and playbooks;
• track mission completion;
• calculate GlowPoints and GlowScore;
• operate leaderboards;
• provide analytics and reporting to Customer administrators;
• process billing and payments;
• provide customer support;
• troubleshoot issues;
• maintain and improve the Services;
• understand how the Services are used;
• develop new functionality;
• protect accounts and prevent misuse;
• enforce our agreements;
• comply with legal obligations;
• communicate with Customers and users; and
• operate our business.

4. Artificial Intelligence

GlowLocal uses artificial intelligence and automated systems to help generate recommendations such as:

• marketing missions;
• local opportunities;
• potential vendors;
• potential organizations;
• playbooks; and
• related local marketing recommendations.

Information associated with a Customer, location, Authorized User, or request may be processed by technology providers that assist us in operating these features.

GlowLocal does not use Customer Content or personal information collected through the Services to train generalized artificial intelligence models for third parties. Where third-party AI providers are used, GlowLocal seeks to use contractual terms, technical settings, or service configurations that restrict the provider's use of Customer data to providing services to GlowLocal, where available. GlowLocal may use aggregated or de-identified information to improve GlowLocal features, recommendations, scoring, and analytics as described in Section 8.

We do not intend for Customers or Authorized Users to submit sensitive consumer information for AI processing.

AI-generated recommendations may also rely on publicly available information about businesses, events, organizations, and communities. AI-generated outputs may be incomplete or inaccurate and should be reviewed by users as appropriate before being relied upon.

5. Publicly Available Information

GlowLocal may collect or process publicly available business information in order to identify relevant local opportunities, organizations, events, vendors, and other potential community relationships.

This may include information available through:

• business websites;
• event websites;
• directories;
• search services;
• publicly accessible web pages; and
• other publicly available sources.

Such information is primarily used to provide location-specific recommendations through the Services.

6. How We Disclose Information

GlowLocal does not sell personal information or share personal information for cross-context behavioral advertising, as those terms are defined under applicable privacy law.

We may disclose information in the following circumstances.

Customer Administrators

Because GlowLocal is a business platform purchased or administered by the Customer, information associated with an Authorized User's use of the Services may be visible to the Customer.

For example, Customer administrators may be able to see:

• whether a user is using the platform;
• missions completed;
• uploaded completion evidence;
• points;
• scores;
• leaderboard position;
• location activity; and
• other participation analytics.

Authorized Users should understand that their GlowLocal account is a business account operated on behalf of the Customer and is not a private personal account.

Service Providers and Subprocessors

We may disclose information to vendors, service providers, contractors, and subprocessors that help us operate our business and provide the Services.

These providers may support functions such as:

• hosting and infrastructure;
• payments;
• artificial intelligence;
• search and data retrieval;
• analytics;
• security;
• communications;
• customer support; and
• software development.

Our providers may change as the Services evolve. Information about key subprocessors may be made available to Customers upon request by contacting privacy@glowlocal.ai.

Business Transactions

If GlowLocal is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, information may be disclosed or transferred as part of that transaction.

Legal and Safety Purposes

We may disclose information when reasonably necessary to:

• comply with applicable law;
• respond to lawful legal process;
• enforce our contracts;
• investigate suspected fraud or misuse;
• protect the security of the Services;
• protect GlowLocal, our Customers, users, or third parties; or
• establish, exercise, or defend legal claims.

With Your Direction

We may disclose information when a Customer or Authorized User directs or authorizes us to do so.

7. Customer-Controlled Information and Processing Roles

GlowLocal provides its Services under agreements with franchisors, multi-location businesses, and other Customers.

For information processed through a Customer account, the Customer generally determines why its Authorized Users use GlowLocal and how information associated with the Customer account is used. In those circumstances, GlowLocal generally processes personal information on behalf of the Customer as a service provider or processor, subject to the applicable Customer agreement.

GlowLocal may separately determine the purposes and means of processing for information relating to its own website visitors, prospects, direct business contacts, billing and account administration, security, legal compliance, and internal business operations.

If you are an Authorized User and have questions or a privacy request concerning information associated with your organization's account, you may also wish to contact your company's GlowLocal administrator. Where appropriate, GlowLocal may refer or coordinate a request with the Customer that controls the account.

8. Aggregated and De-Identified Information

We may create aggregated or de-identified information that does not reasonably identify a particular individual or Customer.

We may use such information to:

• analyze platform performance;
• understand usage trends;
• improve recommendations;
• improve artificial intelligence systems used by GlowLocal;
• develop new features;
• improve scoring and analytics methodologies; and
• operate and improve our business.

Where required by applicable law, we will maintain de-identified information in de-identified form and will not attempt to reidentify it except as permitted by law.

9. Cookies and Similar Technologies

GlowLocal and its service providers may use cookies and similar technologies to maintain sessions, remember preferences, understand website usage, improve performance, detect security issues, and support the operation of the Services.

Some third-party technologies incorporated into our website or Services may collect information directly from a user's browser or device. The specific technologies used may change as GlowLocal develops its website and Services.

10. Do Not Track and Browser Privacy Signals

Some web browsers transmit "Do Not Track" signals. Because there is not a universally adopted technical standard for interpreting every Do Not Track signal, our Services may not respond to traditional browser Do Not Track signals.

To the extent applicable law requires GlowLocal to recognize a legally valid browser-based privacy preference signal, including a Global Privacy Control signal where applicable, GlowLocal will honor that signal as required by law.

11. Sale and Sharing of Personal Information

GlowLocal does not sell personal information and does not share personal information for cross-context behavioral advertising, as those terms are defined under applicable privacy laws.

GlowLocal does not use personal information collected through the Services for cross-context behavioral advertising.

If GlowLocal's practices change in a manner that creates additional rights under applicable privacy law, we will update this Privacy Policy and provide any required choices or notices.

12. Data Retention

We retain information for as long as reasonably necessary to:

• provide the Services;
• maintain Customer accounts;
• fulfill contractual obligations;
• comply with legal, accounting, or reporting requirements;
• resolve disputes;
• enforce agreements;
• maintain security;
• prevent fraud or abuse; and
• support legitimate business operations.

Retention periods vary depending on the type of information, the Customer relationship, the reason the information was collected, applicable legal requirements, and whether the information is needed to establish, exercise, or defend legal claims.

After an account is terminated, certain information may remain in backups, logs, or records for a reasonable period before deletion or de-identification. Where applicable law requires more specific retention disclosures, GlowLocal will provide them as required.

13. Data Security

GlowLocal uses commercially reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, or alteration.

However, no online service, network, or storage system can guarantee absolute security.

Users are responsible for maintaining the security of their credentials and notifying GlowLocal of suspected unauthorized account access.

14. Children's Privacy

Authorized Users must be at least 16 years old. If an Authorized User is under 18 or has not reached the age of majority in their jurisdiction, Customer represents that the individual’s use of the Services has been appropriately authorized and Customer accepts responsibility for that individual’s use of the Services. Individuals under 13 may not use the Services.

GlowLocal does not knowingly seek to collect personal information from children under 13. If you believe a child has provided personal information to GlowLocal in violation of this section, contact us at privacy@glowlocal.ai.

15. Privacy Rights

Depending on where you reside and which privacy laws apply to GlowLocal, you may have rights regarding personal information, which can include rights to:

• request access to personal information;
• request correction of inaccurate information;
• request deletion of certain information;
• obtain information regarding how personal information is used or disclosed;
• opt out of certain uses or disclosures where applicable; and
• exercise privacy rights without unlawful discrimination or retaliation.

These rights are subject to applicable legal exceptions and may not apply in every circumstance.

To submit a privacy request, contact privacy@glowlocal.ai. We may need to verify your identity or authority before completing a request.

If the information relates to an account administered by your employer, franchisor, or other Customer, we may direct your request to that Customer or coordinate with the Customer as appropriate.

16. California Privacy Information

California residents may have additional rights under applicable California privacy laws. This section supplements the rest of this Privacy Policy.

Where GlowLocal is subject to the California Consumer Privacy Act, as amended ("CCPA"), eligible California residents may have rights including the right to:

• know the categories and specific pieces of personal information collected;
• know the sources and purposes for which personal information is collected or used;
• know the categories of third parties to whom personal information is disclosed;
• request deletion, subject to exceptions;
• request correction;
• opt out of the sale or sharing of personal information where applicable;
• limit certain uses or disclosures of sensitive personal information where applicable; and
• not receive discriminatory treatment or retaliation for exercising applicable privacy rights.

Categories of Personal Information

Depending on how an individual interacts with GlowLocal, during the preceding 12 months GlowLocal may have collected the following categories of personal information described by California law:

• identifiers, such as name, business email address, telephone number, IP address, account identifiers, and similar identifiers;
• customer records information, such as business contact information and account-related information;
• commercial information, such as subscription, billing, transaction, or service relationship information;
• internet or other electronic network activity information, such as browser, device, session, feature-use, and interaction data;
• approximate geolocation information, such as location inferred from an IP address;
• professional or employment-related information, such as job title, role, company, franchise brand, or business location;
• inferences or profiles derived from activity or account information, where applicable to features such as scoring, recommendations, or analytics; and
• sensitive personal information in limited circumstances, such as account login credentials. Payment providers may separately process financial account or payment card information as described in Section 2.

The specific personal information collected within each category is described more fully in Section 2. GlowLocal may not collect every category from every individual.

Sources, Purposes, and Disclosures

The categories of sources from which GlowLocal obtains personal information are described in Section 2. The business and commercial purposes for collecting, using, and disclosing personal information are described in Sections 3 through 8. Categories of recipients may include the Customer that administers an account, service providers and contractors, parties involved in a business transaction, government authorities or other recipients required by law, and parties to whom disclosure is directed or authorized.

GlowLocal does not sell personal information and does not share personal information for cross-context behavioral advertising. GlowLocal does not use or disclose sensitive personal information for purposes that require a right to limit under the CCPA, unless otherwise disclosed and required by law.

Our retention approach is described in Section 12.

California Requests

California privacy requests may be submitted to privacy@glowlocal.ai. We may request information reasonably necessary to verify the request. Where a request concerns information GlowLocal processes on behalf of a Customer, we may refer the request to or coordinate with that Customer as appropriate.

Nothing in this Privacy Policy is intended to provide rights beyond those required by applicable law.

17. Third-Party Websites and Services

GlowLocal may display or link to third-party businesses, vendors, organizations, events, services, or websites.

GlowLocal does not control the privacy practices of those third parties. Information you provide directly to a third party is governed by that third party's privacy practices rather than this Privacy Policy.

18. International Users

GlowLocal is operated from the United States.

If individuals access the Services from outside the United States, information may be processed in the United States or other locations in which GlowLocal's service providers operate. Different jurisdictions may provide different levels of data protection.

If GlowLocal materially expands into jurisdictions requiring additional privacy notices, data-processing terms, or transfer mechanisms, we may supplement this Privacy Policy accordingly.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our Services, technology, business practices, vendors, or legal obligations.

When we make material changes, we will update the "Last Updated" date and may provide additional notice through the website, platform, or email where appropriate.

Your continued use of the Services after an updated Privacy Policy becomes effective is subject to the updated policy, except where applicable law requires another form of notice or consent.

20. Contact Us

Questions, requests, or concerns regarding this Privacy Policy or GlowLocal's privacy practices may be sent to:

GlowLocal LLC

50 Sapphire

Irvine, CA 92602

United States

Email: privacy@glowlocal.ai