Gleam's Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, Gleam Modern Parenting Solutions Inc. (“Gleam” “we”, “our” or “us”) use, collect and store Personal Information (as defined below) we collect or receive from or about you or your family (“user”, “you”) in connection with the following use cases:

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(i) ‍

When you make use of the App on mobile software applications, and any other mobile software application that we license (each individually, and, collectively, the “Gleam Services” or “App”).  some text

a. When you sign up for an account.

b. When you make use of our Services through the App (e.g., monitor your child's activities, when setting a "challenge", chatting with other parents on the app etc.)

c. When you interact with our Chatbot or a Gleam team member.

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‍(ii)

When you make use of, or interact with, our website, https://www.togleam.com/ (“Websites”)

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‍(iii)

Other practicessome text

a. When we acquire your Personal Information from third-party sources (such as children's app stores or educational marketplaces) 

b.When we use the Personal Information of our service providers, distributors, resellers, agents and/or partners.

c. When you interact with us on our social me

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Table of contents:

  • Introduction
  • Terms of use 
  • What information we collect, why we collect it, and how it is used
  • Period of storage of collected information 
  • How we protect your Personal Information
  • How we share your Personal Information
  • Additional information regarding transfers of Personal Information
  • Your privacy rights
  • Use by children
  • How can I delete my account?
  • Links to, and interaction with, third party products
  • Log files 
  • Analytic Tools
  • Specific provisions applicable under California privacy law 
  • How to contact us

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1. INTRODUCTION

The Gleam Service is designed to address a concern about excessive and low-quality screen time  for your children while allowing you and your children to enjoy the benefits of interacting with the many educational and children-friendly sites accessible via the internet. It features a user-friendly dashboard that provides valuable insights at every stage of your child's online exploration. You can easily monitor your child's activities, be it learning, playing, or otherwise. To encourage desired behaviors, you can also incentivize your child to engage in defined categories of pastimes. The Gleam Service is designed to help you set ground rules and guide your child’s experience as they explore online. Your child will become part of your Gleam family group, which you can use to share the Gleam Service with your child. You’ll be able to add another parent later to help supervise your child’s account. Parents can use Gleam to do things like:

  • Set screen time limits on your child’s ChromeOS or Android devices;
  • Approve your child’s downloads and purchases in the Apple Store or on Google Play or limit the visibility of content based on maturity ratings;
  • Help your child choose the types of activity that can be saved in their Gleam Account and how it may be used to personalize their experience;
  • Manage settings such as SafeSearch for Google Search;
  • Review your child’s app permissions, such as microphone, camera, and contacts access on ChromeOS and on Android;
  • Change the content, access and other settings for YouTube experiences (where available), including YouTube and YouTube Kids.

The app displays the child's weekly screen time usage, indicating how much time was spent on different customizable categories of activities. All of the above and additional functionality  of the App, as it is enhanced over time, is referred to herein as the “Services”.  

While Gleam's parental controls can help you supervise and manage your child's experience, there are limitations that you should keep in mind:

  • While many of Gleam’s parental controls can be managed on the web, you’ll need the Gleam Parent app on iOS or Android to manage certain features like screen time limits.
  • Settings like SafeSearch, Chrome website restrictions, and AppleStore or GoogleStore filters can help limit access to inappropriate content, but they are not perfect. Even with these controls on, your child may still access content you don’t want them to see.
  • Parental approval is not required when your child re-downloads an app or other content that was previously approved, installs an update to an app (even an update that adds content or asks for additional data or permissions), or downloads shared content from your family library.
  • Some Gleam features have limited availability, and require specific settings and circumstances in order to work. For example, blocking apps is only available when your child is signed in to a compatible Android device (Apple iOS in development), and seeing your child’s device location in the Gleam app is only available when their Android device is powered on and connected to the internet.

When your child turns 13 (age may vary by country), they can choose to manage their account on their own without your supervision.

We respect your privacy, which is why we make every effort to provide Services that would live up to recognized privacy and cybersecurity standards. Please read this Privacy Policy carefully, so that you can fully understand our practices in relation to Personal Information. “Personal Information” means any information that can be used, alone or together with other information, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for  individuals living in the European Union or the U.K.

You are not legally obligated to provide us Personal Information and providing us Personal Information is at your own free will. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site. 

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TERMS OF USE 

This Privacy Policy forms part of our Terms of Use which are available at https://www.togleam.com/terms-of-use. 

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2.WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

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  • Use of the Gleam Services: When you Create an account, sign up for an account, and during the use of the Service

We will collect the following personal data about you and your child: [Full name, Age, Email address, Phone number (Optional), User password, age, Gender (Optional), [Country, Language,] Mobile phone details (type/OS version, UDID), Apps tracking (Name of app and time the user used the app)] . Without this data, your account cannot be created, we won't be able to contact you in connection with technical support for the Services, [we cannot determine appropriate language settings to operate the App,] we cannot determine appropriate technical characteristics, establish reliable server communication to provide reliable Services and we won't be able to provide you the "Service".

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  • When you make use of our Services through the Gleam Service

When you and your child will use the Gleam Service, when you monitor your child's use of the Apps, when you challenge or incentivize your child [or use other parents' recommendations of challenges or incentives] we will collect the following: User Interface ("UI") actions and operations performed by you via the App, such as log-in, log-out, device connect and disconnect, use of in-App services [and other user actions], App tracking (Name and time the user used the app). If this data is not provided, you cannot make use of the Services, we cannot discover, investigate and improve technical issues in the Services for you and other users, develop new services and provide you reliable technical support in connection with the Services. 

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  • When you contact us (e.g. customer support)

We will collect the following data; Full name, Email address, your request in order to reply and/or respond to your request or question.

 

  • Marketing

We collect data to send you more information about Gleam, [special deals and other materials].

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  • When we acquire your Personal Information from third-party sources (such as children's app stores or educational market spaces)

We will collect Contact information. 

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  • When we use the Personal Information of our service providers, distributors, resellers, agents and/or partners.

Full name, email address, and any other Information you decide to provide. 

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  • When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn, TikTok)

Full name, Email address and any other Information you decide to provide.

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  • Location information

We do not track location.

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  • Payments: See our “Terms of Use” regarding payments. Our payment providers collect certain payment data which is processed according to their terms and privacy policy which is provided to you during the payment process. You can visit [list sites of payment processors] for further information. We may contract additional payment gateways, and their conditions will be provided to you during the payment process

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3. Purposes for Processing

We collect personal data about you for various purposes related to our services. These purposes include, communicating with you, managing your Gleam Account, and providing you with our Services. Additionally, the data we collect are utilized to measure and enhance the functionality of our Services, and, if you have given your consent, share newsletters and general communications about our Services, products, updates, and promotional offers. Furthermore, we use your data to ensure compliance with our Terms, applicable laws, and other legal obligations to which we are required to adhere.

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4.Legal basis

To process your data lawfully, we rely on the following legal bases:

  • Preparation and performance of Contract: Processing your data is necessary to fulfill our contractual obligations to you.
  • Legitimate Interest: We have a legitimate interest in processing your Registration Data for the purpose of conducting and managing our business, providing you with the best service and experience possible, and ensuring appropriate security for you and your data. We carefully consider and balance any potential impact on you, both positive and negative, and respect your rights. We do not use your personal data for activities that would override your interests unless we have obtained your consent or are legally required or permitted to do so.
  • Legal reasons. We will share personal information with companies, organizations or individuals outside of Gleam if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:some text
    • meet any applicable law, regulation, legal process or enforceable governmental request;
    • enforce applicable Terms of Service, including investigation of potential violations;
    • detect, prevent, or otherwise address fraud, security or technical issues;
    • protect against harm to the rights, property or safety of our users or the public as required or permitted by law.

We may also share non-personally identifiable information (such as trends about the general use of our services) publicly and with our partners — like publishers, advertisers, developers, or rights holders. For example, we share information publicly to show trends about the general use of our services. We also allow specific partners to collect information from browsers or devices for advertising and measurement purposes using their own cookies or similar technologies.

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5. PERIOD OF STORAGE OF COLLECTED INFORMATION 

Personal Information. Your Personal Information (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request.  In some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings. We do not retain your Personal Information perpetually unless it is de-identified.

Cookies. The period of storage and collected information depends on the cookie. You may also control and delete these cookies through your browser settings. Some cookies (e.g. essential cookies) cannot be disabled. For more information, please consult our cookie policy.

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6. HOW WE PROTECT YOUR PERSONAL INFORMATION

Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

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7. HOW WE SHARE YOUR PERSONAL INFORMATION 

In addition to the recipients described above, we may share your information as follows:

  • With our business partners with whom we jointly offer products or services. 
  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will disclose information to a potential or actual third-party purchaser of our business or assets (to the minimum extent required). In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events. 
  • Where you have provided your consent to us sharing the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

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8. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION 

a. Storage: The personal information is stored by Amazon Web Services (AWS) managed service [– Amazon Relational Database Service (Amazon RDS) with servers located in the United States. De-identified information is stored also by Google BigQuery - fully-managed, serverless data warehouse for data analysis with storage located in the United States. Intercom services and data are hosted in AWS facilities in the United States.]

b.Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

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9. OUR PRIVACY RIGHTS some text

  1. Rights: The following rights (which may be subject to certain exemptions or derogations depending on where you live) shall apply to certain individuals:
  • You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at support@togleam.com.  Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes before processing and/or honoring your request. We reserve the right to charge a fee when permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all-in accordance with applicable law.

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10. USE BY CHILDREN

In order for a child under the age of 13 located in the United States and 18 in the EU and the rest of the world to use the Gleam Services, his/her parent or legal guardian must approve the registration. Therefore, we will obtain consent from the parents/legal guardian to this Privacy Policy. When we intend to collect Personal Information from or about children, we take additional steps to protect children's privacy, including, without limitation, limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted. We Comply with The Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA is designed to protect the privacy of your children. 

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11. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by contacting our Customer’s support via the App or emailing support@togleam.com.  If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public, unless otherwise prohibited by law.

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12. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS 

The App may enable you to interact with or contain links to third party Websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

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13. LOG FILES  

Log files are used to record important events and actions that occur within a computer system or application. In general, logs provide a way to track the behavior of the system and its users and to identify any errors or issues that may arise.

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

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14. ANALYTIC  TOOLS 

Google Analytics. The Websites use a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes Information specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your Information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

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15 SPECIFIC PROVISIONS UNDER CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@togleam.com . Please note that we are only required to respond to one request per customer each year. We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Services. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to support@togleam.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

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CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at support@togleam.com.

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Last updated: May 30th, 2023

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