Privacy Policy

Introduction

This U.S. Privacy Notice provides information for residents of the United States and describes the information practices of Glimboo Inc., a Texas corporation located at 1101 E Arapaho Rd, STE 2420, Richardson, TX 75081, (“we,” “us,” or “our”) relating to the processing of personal information when you interact with our website (which serves as both Glimboo’s official brand website and our online store), applications, products or services (collectively, the “Services”). This Privacy Notice also applies to personal information we collect offline, such as at events and trade shows, and in connection with our retail, wholesale, distribution, and other business relationships. Depending on how you interact or engage with us, we may provide you with supplementary privacy statements with additional details about our privacy practices. This Privacy Notice applies to “personal information,” which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information does not include publicly available information, lawfully available information from federal, state, or local government records, or information that has been deidentified or aggregated in accordance with applicable law.

This Privacy Notice does not apply to any specific contracts or relationships that may be governed by further privacy agreements. If you are engaging with us on behalf of an organization, your employer, or are otherwise providing the personal information of others, by engaging with us, you acknowledge and agree that you have the consent of the organization, your employer, or the other individual to provide that personal information to Glimboo. Please note that the organization (e.g., your employer or another entity or person) that entered into the contract or relationship with us controls the content submitted through the Services and any associated personal information. If you purchase Glimboo products from a retailer or other third-party seller, that seller’s privacy policy (not this Privacy Notice) governs how that seller collects and uses your personal information. This Privacy Notice applies to the personal information that Glimboo itself collects, for example, when you visit our website, contact us, or scan a QR code or tap an NFC tag on a Glimboo product.

Personal Information We Collect

Depending on how you interact with our Services, we collect the following categories of personal information:

• Identifiers: Name, alias, postal address, email address, telephone number, unique online identifier, IP address, account name, or other similar identifiers.
• Customer Records: Name, account name, email, address, phone number, communications preferences, billing and payment information, customer service and support tickets and records.
• Commercial Information: Records of products or services purchased, obtained, considered, viewed, added to cart, returned, refunded, including other purchasing or consuming histories or tendencies.
• Internet or Other Electronic Network Activity Information: Login data, device ID, browser type and version, browsing history, clickstream data, search history, app version, log data, and information regarding interactions with our Services, advertisements, or emails.
• Geolocation Data: Including approximate location derived from IP address and, where you have consented, more precise geolocation information from your device, such as GPS data.
• Audio, Electronic, or Similar Information: Call recordings when you contact customer service or any photos or videos you share to the Services.
• Inferences:Inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.
• Sensitive Personal Information: In limited circumstances, we may collect government identification numbers for prize verification, precise geolocation, information about dietary restrictions for events, or demographic information. We do not use or disclose sensitive personal information for purposes other than those specified at the time of collection or as permitted by law.
• Program Participation Information: Social media handles, photos, content submissions, demographic details, activity or interest data, and other information you choose to provide when participating in our programs, events, or campaigns.
• Investor Relation Requests: Name, email address, and phone number, as well as any information you provide when requesting investor materials or updates.
• Business inquiry and business partner information: Name, email address, phone number, company information, and any information you provide when making business, retail, wholesale, distribution, investor, media, or partnership inquiries, as well as, for representatives of our retail, wholesale, distribution, and other business partners, business contact details (such as job title), communications, and records of business transactions with us.
• QR code, NFC, and digital interaction information: Such as the SKU or product identifier, campaign identifier, landing page visited, and interaction activity when you scan a QR code, tap an NFC-enabled product, or visit a product-specific digital experience. We may associate unique identifiers with individual products for authentication, campaign management, fraud prevention, analytics, and rewards.

Sources of Personal Information

We generally collect personal information from the following categories of sources:

• Directly or indirectly from you;
• Our affiliates and subsidiaries;
• Our business partners, such as retailers, distributors, and wholesale customers;
• Social networks;
• Operating systems and platforms;
• Publicly available sources;
• Advertising and analytics partners; and
• Our vendors and service providers.

Children’s Privacy

The Services are not directed to children under 18 years of age, and we do not knowingly collect personal information from children under 18. If you are under 18, please do not use the Services or provide any personal information to us. If we learn that we have collected personal information from a child under the age of 18 we will promptly delete that information. We do not “sell” or “share” children’s personal information.

Purposes for Collecting and Disclosing Personal Information

In general, we collect and otherwise process the personal information we collect for the following business or commercial purposes:

• To provide Services and support, such as creating and managing your account; processing transactions; fulfilling orders; determining whether our online store can ship to the address you provide; providing customer service and technical support; and enabling the features you request.
• Analytics and improvement of our products and Services, such as understanding how users interact with the Services; analyzing aggregate usage; conducting research; and developing new products, features, and services.
• Marketing and advertising, including first-party direct marketing and, where permitted, targeted advertising.
• Planning and managing events and running sweepstakes and competitions, program participation and operations.
• Research and surveys, including personalization of the Services, such as customizing content, recommendations, and features based on your interests and interactions.
• Security and protection of rights, such as detecting, investigating, and preventing security incidents, fraud, and illegal activity; protecting the rights, property, or safety of us, our users, or others.
• Compliance and legal process, including complying with applicable laws and government requests; enforcing our terms of service; and establishing, exercising, or defending legal claims.
• General business and operational support.
• Managing our retail, wholesale, distribution, and other business relationships, such as responding to business inquiries and inquiries about where our products are available, communicating with representatives of our business partners, and processing and fulfilling business orders.
• Investor relations or corporate transactions in connection with a merger, acquisition, financing reorganization, bankruptcy, or sale.

Retention of Personal Information

We retain your personal information for as long as needed to fulfill the purposes described in this Privacy Notice, to comply with our legal obligations, to resolve disputes, to enforce our agreements, or as otherwise permitted consistent with applicable law. When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

Data Security

We implement reasonable technical, administrative, and organizational security measures designed to protect the personal information we collect, both during transmission and once it is received. While we use reasonable efforts to safeguard the confidentiality of your personal information, please note that no data transmissions over the internet are 100% secure, so we cannot guarantee the security of any personal information you provide to us. You understand that any personal information you send is at your own risk. You are responsible for safeguarding your account credentials and promptly reporting any suspected security incidents.

Financial Incentives and Loyalty Programs

This section applies to residents of the U.S. when we offer financial incentive programs or bona fide loyalty programs in exchange for personal information. The specific personal information requested in connection with each offer, along with the material terms, will be provided at the point you sign up.

For example, when you sign up for our email list or provide contact information in connection with discounts or special offers, you opt in to a financial incentive or bona fide loyalty program. You may withdraw at any time by unsubscribing from our emails or by contacting us. When legally required, we assign a good-faith value to the personal information related to the estimated cost of providing the relevant incentive(s), based on the expected revenue generated or cost savings realized in connection with the contact information and personal information provided.

Disclosure of Personal Information to Third Parties and Other Recipients

The categories of personal information we have disclosed for a business purpose in the preceding 12 months include: identifiers, customer records, Internet or other electronic network activity information, geolocation data, audio, video, and other electronic data, inferences. The categories of third parties and other recipients to whom we may disclose personal information for a business purpose may include: affiliates, subsidiaries, and business partners, vendors and service providers, acquirers of business assets, professional advisors, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks.

Sales and Sharing of Personal Information; Targeted Advertising

We do not sell personal information for monetary consideration. We work with third-party advertising and analytics partners and social media sites, and these partnerships may be considered a “sale” or “sharing” under the California Consumer Privacy Act and similar U.S. state privacy laws, even though no money changes hands. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “share” the following categories of personal information due to our use of advertising and analytics tools on our websites: identifiers, and Internet or other electronic network activity information. We disclose these categories to third-party advertising networks, analytics providers such as Google Analytics, PostHog, and Klaviyo, and social networks for purposes of marketing and advertising. We do not sell or share personal information about individuals we know are under age 18. For more information about our use of cookies and similar online tracking technologies, please see the “Cookies and Similar Online Tracking Technologies” section below. For information about how you may control the collection of your personal information via these tools, see the section, “Your U.S. Privacy Rights” below.

Cookies and Similar Online Tracking Technologies

We, and third parties acting on our behalf, may use cookies, Software Development Kits, web beacons, pixels, or similar online tracking technologies (collectively, “cookies”) to improve your experience on the Services, such as remembering you when you return to the Services, track interest in and collect aggregate information on the Services, and analyze traffic patterns on the Services and the performance of our advertising and marketing. We may also work with service providers that use cookies to collect information about your visits to the Services and to other websites you may visit, and to serve advertisements to you across the Internet based on that information.

How long these cookies stay on your device depends on what they need to do. For example, some cookies only work while you are visiting our Services and get deleted when you’re done (session cookies). Others may stay on your device unless you choose to delete them (persistent cookies). Cookies may be placed by us (first party cookies) or by other businesses (third party cookies) when you visit our Services or other online properties.

The cookies used on our Services can be classified using the International Chamber of Commerce guide for cookie categories: Strictly Necessary, Performance, Functional, and Targeting. We may use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas of our Services or areas requiring your acknowledgment or consent to proceed.
• Performance/analytics cookies. These cookies from third-party services allow us to recognize and count the number of visitors and to see how visitors move around our Services when they are using them. This helps us improve the way our Services work, for example, by ensuring that users find what they are looking for easily.
• Functional cookies. These are used to recognize you when you return to our Services. These enable us to personalize our content for you, greet you by name or remember your preferences (for example, your choice of language or region).
• Targeting/advertising cookies. These cookies record your visit to our Services, the pages you have visited, the links you have followed, and your interaction with our advertising and marketing. We may use this information to make our Services more relevant to your interests. We may also share this information with third parties for this purpose.

Your Cookie Choices

Browser Settings.You may be able to block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Check your browser’s HELP menu to learn the correct way to change or update your cookies. You can also visit www.aboutcookies.org, which contains more information on how to do this on many different browsers. Please see your mobile phone’s manual or other instructions for information on how to do this on your phone’s browser. Please note that if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our Services. Further information on popular browsers and their cookie management links is below.

• Google Chrome: support.google.com/chrome/answer/95647
• Firefox: support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
• Opera: help.opera.com/en/latest/web-preferences/
• Microsoft Internet Explorer: support.microsoft.com/en-us/windows/delete-and-manage-cookies
• Apple Safari: support.apple.com/en-il/guide/safari/sfri11471/mac
• Microsoft Edge: support.microsoft.com/en-US/edge/manage-cookies-in-microsoft-edge

Advertising Cookie Opt-Out.In the United States, you may opt out of companies participating in the Digital Advertising Alliance (“DAA”) program by opting out at https://optout.aboutads.info. For information and to download DAA’s AppChoices tool, see https://youradchoices.com/appchoices. Note that opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your preferences and usage patterns.

Google Analytics.To help facilitate the delivery of relevant content, we use Google Analytics and have implemented all Google Advertising Features, including Remarketing, Impression Reporting, and Demographics, and Interest Reporting. Google Analytics uses cookies to report on user interactions on our and others’ websites. We use the data collected for optimizing marketing, refining advertising and/or programming strategies, and generally making advertising more effective. Google provides a complete privacy policy here: www.google.com/intl/en/analytics/privacyoverview.html and instructions on opting out of Google Analytics using a specific plug-in available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt out is specific to Google activities and does not affect the activities of other advertising networks or analytics providers that we may use.

Meta Pixels.We use the Meta Pixel to analyze user activity on our Services for remarketing and behavioral targeting. The Meta Pixel is triggered when you perform certain activities on the Services and aids us in displaying ads to users who have visited our Services, or users who share certain characteristics with visitors to our Services. Meta may track your activity over time and across websites. For more information about the personal information Meta collects and choices you may have to control this personal information collection, please visit Meta’s privacy policy at: www.facebook.com/privacy/policy.

Browser Signals.The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers. At this time, not all browsers support DNT. We honor opt out preference signals, such as the Global Privacy Control (“GPC”), as another way to opt out of the “sale” of your personal information or its “sharing” for targeted advertising purposes. More information on the GPC is available here.

Our Use of Session Replay Technology

We may use session replay and heatmap technology to understand how users interact with our websites. These tools capture information such as mouse movements, clicks, scrolling, and page interactions, and may record the content of your interactions on sensitive portions of the Services. Information collected through these tools may be shared with the technology providers for product improvement purposes, which may constitute a “sale” or “sharing” under the applicable laws. For cookie-based session replay tools, you may opt out by using the GPC signal or contact us.

Disclaimer Regarding Video Content

Our Services may contain video content, audiovisual content, or content of a like nature (collectively, “Video Content”). In connection with our provision of Video Content, our Services may utilize online tracking technologies and code-based tools, including, but not limited to, Software Development Kits (“SDKs”), pixels, and advertising and analytics cookies (collectively, “cookies”) that track information about your activity and webpage-viewing history on the website. Cookies on or used by the Services may result in information about your activity on our Services being transmitted from your browser to us and third parties, which, in turn, may result in the display of targeted advertisements on third-party websites, platforms, and services, including advertisements for our content. In addition, whether cookies on the Services result in your browser’s transmission of information to third parties depends on a number of factors that may be outside of our knowledge or control, including what third-party services you use, what personal information you have provided to such third parties, and whether (and the extent to which) you have limited the use of cookies by the operators of those third-party websites, platforms, and services.

Disclaimer Regarding SMS Messaging

We may offer an SMS messaging program. For purposes of this program, no mobile information will be shared with third parties or their affiliates for marketing or promotional purposes. All other categories of personal information shared with third parties and their affiliates exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties or their affiliates, excluding aggregators and providers of text message services.

Disclaimer Regarding Chat Features

Glimboo may incorporate a third-party interactive chat feature (“Chat Feature”), which may use Artificial Intelligence, for customer support purposes. If you interact with these Chat Features, you are not communicating with a human representative of Glimboo. Instead, you are communicating with software that generates responses to your input based on machine-learning algorithms. These Chat Features may collect the content of your communications, including any personal information you provide it. Any personal information you provide to these Chat Features will be used, shared, and stored in accordance with this Privacy Notice and any applicable Terms of Use. Please discontinue use of these Chat Features if you do not consent to the collection and use of such personal information by Glimboo and any third-party operators of these Chat Features.

Public Posting Areas

Please note that any information you include in a message you post to any blogs, social media pages, forums, or other public posting areas (collectively, “public posting areas”) is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN ANY PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF ANY PERSONAL DATA THAT YOU DISCLOSE IN ANY PUBLIC POSTING AREAS.

International Data Transfers

The Services are operated primarily in the United States. If you are accessing the Services from outside the United States, please be aware that personal information may be transferred to, stored in, and processed in the United States. By using the Services, you acknowledge that the data-protection laws of the United States may differ from, or be less protective than, those of your country of residence.

Your U.S. Privacy Rights

Certain U.S. states, such as California, Texas, and Delaware, provide residents of those states with certain rights regarding their personal information. In general, these residents have the following rights with respect to their personal information, subject to certain exceptions:

• Right to Know/Access. With respect to the personal information, we have collected about you, you have the right to request:
  • The categories of personal information we collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purposes for collecting, selling, or sharing personal information;
  • The categories of or specific third parties to whom we have disclosed personal information; and
  • A copy of the specific pieces of personal information we have collected about you.
• Right to Correct. You have the right to request that we correct inaccurate personal information.
• Right to Delete. You have the right to request we delete your personal information.
• Right to Opt-Out of Sales and Sharing.You have the right to opt-out of “sales” and “sharing” of your personal information, and to opt-out of the use of your personal information for “targeted advertising” as those terms are defined under the CCPA. To submit an opt-out request, please contact us at support@glimboo.com and include ‘California Opt-Out Request’ in the subject line. If we later provide a dedicated ‘Do Not Sell or Share My Personal Information’ or ‘Your Privacy Choices’ link, you may also use that link to submit your request.

You also have the right to opt-out of “sales” and “sharing” of your personal information using an opt-out preference signal. If our site detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC—signal, we will opt that browser or device out of the use of cookies or other tools on our site that result in a “sale” or “sharing” of your personal information. If you come to our site from a different device or from a different browser on the same device, or if you clear your cookies, you will need to opt-out again, or use an opt-out preference signal, for that browser and/or device as well.

• Right to Limit Use.We do not engage in uses or disclosures of “sensitive personal information” that would trigger the right to limit use of sensitive personal information under the CCPA.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
• Right to Opt-out of Profilingwhere Automated Decision-Making Technology (“ADMT”) is used to make decisions about you that have a legal or similarly significant effect. You may also have the right to question the result of profiling, be informed of the reason the profiling resulted in a decision, review the personal information used in the profiling, and, where applicable, have the decision reevaluated based on corrected information.
• Right to Request Information about our Use of Automated Decision-Making Technologies (“ADMT”). Upon submission of a verifiable request, we will provide you with: (a) a plain-language explanation of the specific purpose for which we used ADMT; (b) how the ADMT processes personal information to make the significant decision, including the categories of personal information that affect the output; (c) the type of output generated by the ADMT and how that output is used to make the significant decision; and (d) the outcome of the decision, including any plans for future use of the output in significant decisions concerning you.

Exercising Your U.S. Privacy Rights

To exercise any of the rights described above, you (or your authorized agent) may submit a request by contacting us. We will respond to privacy rights requests as required by applicable law. Where permitted by law, we may limit, charge a reasonable fee for, or decline to act on certain repeat, excessive, manifestly unfounded, or technically infeasible requests.

• Email us at support@glimboo.com, please include “U.S. Privacy Request” in the subject line.
• Visit “Contact Us” at the bottom of our website.

Verification

Before responding to your request, we must first verify your identity using the personal information you recently provided to us. You must provide us with your full name and email address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Response Timelines

We will respond to your privacy rights request within the time period required by applicable law. In most cases, we will respond within forty-five (45) days after receiving your request. If a different response period applies under applicable law, we will respond within that period. Where permitted by law, we may extend the response period when reasonably necessary, taking into account the complexity and number of requests. If we extend the response period, we will notify you within the initial response period and explain the reason for the extension.

Appeal of Denied Requests

If we deny a request you submit (in whole or in part), we will provide you with a detailed explanation of the basis for the denial. You may appeal our decision by contacting us at support@glimboo.com with the subject line “Privacy Rights Appeal”. Please include: (a) your original request, (b) the denial response, and (c) the reasons you believe the denial was in error. We will respond to your appeal within the time period required by applicable law.

Additional Privacy Rights

Please review the information below for additional ways that you may be able to control your personal information.

• Opting Out of Marketing Communications: You may opt out of commercial communications by contacting us by email at support@glimboo.com or clicking the “unsubscribe” link in one of our marketing emails. We will process your requests as soon as possible, but please be aware that it may take us some time to respond to your request and, in some circumstances regarding opt-out requests, you may receive a few more messages until your request is processed.
• Text or SMS: In some circumstances, we might require you to opt-in to receive text messages from us. At any time, you may opt out of receiving particular text messages from us by texting STOP in response to any text message.
• Rights Under California Shine the Light Law:Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at support@glimboo.com, and include in your request a current California address and your attestation that you are a California resident.
• Nevada residents: Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties for monetary consideration. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time. If we make material changes, we will notify you by posting the updated Privacy Notice on our websites and updating the “Last Updated” date above. We encourage you to review this Privacy Notice periodically. Your continued use of the Services after an update may constitutes acceptance of the updated Privacy Notice, to the extent permitted by law.

How to Contact Us

If you have questions or concerns about this Privacy Notice or our data practices, or would like to exercise your privacy rights, you may contact us using the following active methods: