(a) you visit our website (“Visitor”) at www.glisser.com or via an embedded software component (“Site” or “website” or “component”) (regardless of where you visit it from); or
(b) you use our software solution (“Solution”) as a subscriber (“Customer”); or
(c) you use our software application (“Application”) as an audience (“Audience Member”); and,
tell you about your privacy rights and how the law protects you.
For the purpose of the Act, Glisser are the data controller and our data controller registration number is ZA062440. For the purposes of GDPR legislation Glisser may also act as the data processor on behalf of its clients. For additional guidance, please see paragraph 10.8.
Glisser (office 325/6)
Metal Box Factory,
30 Great Guildford Street,
London, SE1 0HS
132 W 31st St, 9th Floor
New York, NY 10001
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate your giving us the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our EU representative is Ruben Onderdelinden and can be contacted at email@example.com.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.1 We need to collect certain personal details from you as Customer when you use the Solution available through our Site to facilitate the provision of this Solution and to maintain our quality standards. These details may include your name, email address, contact details, company name and other basic information (together, “Customer Personal Data”). You can amend or update the information you have entered into the Site at any time.
1.2 We need to collect a unique identifier from you as Audience Member when you use the Mobile Application in order to facilitate the provision of the Solution allowing you to participate in the Event and receive the Content. As standard we only collect an Audience Member’s email address (“Audience Personal Data”) unless an alternative unique identifier is selected by our Customer.
1.3 By registering your details on the Site you permit us to process your Customer Personal Data and contact you via email or telephone, for the purposes of monitoring the provision of the services through the Site, the Application and the Solution, in order to fulfil our contract to you as a Customer.
1.4 By registering your details on the Site as a free user you permit us to process your Customer Personal Data and contact you via email or telephone, for the purposes providing you with relevant information pertaining to our Site, the Application and the Solution, and ensuring you are happy with the level of service you are receiving, on the basis of legitimate interest as a Customer.
1.5 By registering your details on the Application, you consent to us, and the providers of any presentations you attend via the Solution, to process your Audience Personal Data in order for the Application and the Solution to function allowing you to participate in the Event and receive the Content, and participate in any interactivity, on the basis of legitimate interest as an Audience Member.
1.6 When registering your details on the Application you are able to provide clear consent to the processing and use of your Audience Personal Data for a specific purpose, as defined by us and/or our Customers at the point of providing that data. You have the option of not providing consent, in which case your personal details will only be held in order to provide product functionality according to our Terms.
1.7 Provided that you consent to receiving such communications, we (where the Presenter is using our free Solution) or our Customers (the providers of any Presentations you have attended via the Solution) may send you promotional emails about our or their own or third parties’ product developments, new products or special offers, or other information which we or they think you may find interesting, or for market research purposes, as defined at the point of consent.
1.8 Visitors to our website have the opportunity to download content by providing basic information including an email address (“Visitor Personal Data”). By registering your details on the Site in order to download information as a Visitor you are able to provide clear consent to the processing and use of your Visitor Personal Data for a specific purpose, as defined by us at the point of providing that data.
1.9 We will not share, trade or sell your personal information to any company or parties not directly associated with its proper use within the Site or as described above, except when you give us explicit permission.
1.10 We collate information about site traffic, sales, Interaction Data and other commercial information which we may use for internal purposes and/or pass on to third parties (whether within or outside the EEA) but this information does not include any information which can identify you personally and are therefore not Personal Data.
1.11 In certain circumstances we may have a legal obligation to disclose personal information, and we reserve the right to do so.
1.12 Under certain conditions the individual has the right to invoke binding arbitration,
1.13 Reasonable and appropriate measures are taken to protect personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction. Risks are analysed and controlled under the ISO27001 certification.
2.1 Customer Personal Data and Audience Personal Data will be held by Glisser using appropriate safeguards to maintain its privacy and security. However, it should be noted that data transfers take place over Wi-Fi or mobile networks over which we have no control. No Customer Personal Data and only very limited Audience Personal Data is transferred between devices via our Application. This is limited to the email address entered into the device of the Audience Member using the Mobile Application. Twitter data is shared according to Twitter’s security policies. Email address details are only stored on our password-protected website.
2.2 Personal information related payment is managed by a third-party supplier who is PCI compliant. For more information please see: https://www.chargebee.com/security/
2.3 Your Personal Data is stored on our dedicated UK-based servers and in the Microsoft Azure Cloud in the EEC. Backups are also held securely inside the European Economic Area (“EEA”) and/or the UK. More information on the physical security at these data centres are available from vXtream (https://www.vxtream.com/london-colocation/) and Microsoft: https://www.microsoft.com/en-us/trustcenter/privacy/
2.4 Your Personal Data may be transferred to, and stored or otherwise processed at a destination within the EEA, in the UK or outside the EEA. Your Personal Data may be shared with a subsidiary or an affiliate entity within the Glisser corporate family. This will involve transferring your data outside the EEA.
2.5 Many of our external third parties including partner entities, vendors and service agencies that we may engage to assist us are based in the UK and/or outside the EEA so their processing of your Personal Data will involve a transfer of data outside the UK and EEA.
2.6 Whenever we transfer your Personal Data out of the UK and/or EEA for storage or processing, we will take all reasonable steps necessary to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
– We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK (as applicable).
– If we transfer your Personal Data to any other country which is not subject to an adequacy decision of the European Commission or the UK (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the EEA or the UK (as applicable).
– Where we use certain service providers, we may use specific contracts approved by the European Commission or the UK (as applicable) which give Personal Data the same protection it has in the EEA or the UK (as applicable).
– We may transfer your Personal Data to countries that have legal framework(s) for data protection that substantially mirror the GDPR.
2.7 Notwithstanding clause 2.6, we will not transfer your Personal Data to the United States [unless accessed by your users in the United States].
2.8 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.
2.10 The transmission of information via the internet is not completely secure. Although we do our best to protect Customer Personal Data and Audience Personal Data, and while we transfer all data over https we cannot guarantee the security of your data whilst it is being transmitted to or from our website; any transmission is at your own risk.
3.1 We will retain Customer Personal Data for two years after the Customer has ceased their use of the Solution and email contact with Glisser.
3.2 We will retain Audience Personal Data collected on behalf of Customers for six months after the associated Customer has ceased their use of the Solution and email contact with Glisser, unless otherwise requested by the Customer.
3.3 We will retain Audience Personal Data collected by use of the Glisser free Solution for two years after the point at which that Personal Data was collected via the Solution.
3.4 We will retain Visitor Personal Data for two years after the point at which it was submitted to our website or the last email contact with that individual.
3.5 The individual can choose (opt out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorised by the individuals.
3.6 Sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual) is not collected by the organisation.
4.1 You have the right to request copies of all Personal Data processed by us relating to you, and the right to erasure of any Personal Data (except that processes based upon legal obligation or public task). You have the right to withdraw consent for us to process your data based upon this consent. You can request erasure or withdraw consent at any time via the contact form on this website. We will not charge for initial requests, but may make a small charge to cover our administrative costs on repeat requests.
4.2 Glisser are required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and its liability in cases of onward transfers to third parties.
4.3 Individuals have the right to contact Glisser via email, telephone, letter, in order to limit the use and disclosure of their Personal Data.
4.4 For security reasons we may ask for proof of your identity before we disclose information about you, or to you, via email or over the telephone.
5.2. To transfer personal information to a third party acting as a controller, Glisser complies with the Notice and Choice Principles. Organizations must also enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify the organization if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made the third-party controller ceases processing or takes other reasonable and appropriate steps to remediate.
5.3 To transfer personal data to a third party acting as an agent, Glisser must: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) require the agent to notify Glisser if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request.
7.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
(a) distinguish you from other users of the website;
(b) remember searched locations for quick future reference by visitors; and
(c) save login information.
7.4 We may use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of the website.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to the website. This enables us to personalise our content for you, greet you by name and remember your preferences.
(d) Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them below:
Session cookie. This cookie allows users to stay logged into the website whilst using it. This cookie is essential for the website as it enables us to manage communication between our servers. The session cookie contains the API key and an expiry time stamp. When the user logs out the cookie is destroyed.
Google Analytics Tracking. This cookie allows us to estimate our audience size view and analyse site usage. This cookie does not store information that can be used to identify individual users.
Google Adwords Remarketing Cookie. This cookie resides on the user’s computer and allows Google Adwords to show ads promoting Glisser to previous site visitors.
7.5 By using this website, you agree that we can place these types of cookies on your device.
7.8 Except for essential cookies, all cookies will expire after 1 hour.
If you send a message to Audiences via the website or Solution then in doing so you are providing them with the information in that message. Glisser will not have any responsibility for how these Audiences use this information.
9.1 We’re committed to the Principles all personal data received from the EU in reliance on the Privacy Shield.
9.3 Glisser commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
9.4 Glissers internal complaints mechanism listed below: firstname.lastname@example.org
Glisser (office 325/6)
Metal Box Factory,
30 Great Guildford Street,
9.5 Glisser is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
9.6 Glisser is liable in cases of onward transfers to third parties (see 5.1 & 5.2).
10.1 What is privacy all about?
Privacy (which is also known as Personal Information Management or PIM) is the discipline of handling personal information in a strictly controlled manner, to meet the following objectives:
– To be transparent about any personal information that is collected and what it will be used for
– To protect the information from accidental or malicious loss, damage, unlawful processing or disclosure
– For legal compliance
10.2 Is my personal information secure with Glisser?
While the safety of your personal information can never be 100% guaranteed, we take privacy extremely seriously and adopt many measures to minimise the risks. Furthermore, we are ISO27001 certified, committing to Integrity, Availability and Confidentiality of our Information Security Management System.
10.3 What can I do to protect my personal information?
There are a number of measures that you can take to protect your personal information, including:
Use strong passwords for all your online accounts:
– Do not use trivial passwords (such as single dictionary words)
– Do not use the same password for multiple accounts
– Do use very long passwords (at least 10 characters, but preferably much longer)
– Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
– Do keep passwords securely (never written down, or shared with anyone) and changed periodically
Don’t automatically trust every web site or email which asks you to provide your personal information. Take time to check that the request is valid, and that the personal information requested is absolutely necessary for the services that you are looking to use.
10.4 What is Personal Data?
The definition of personal data varies by different laws and regulations established around the world. Under the GDPR, Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). It includes your name, email address, telephone number, or mailing address, and other information that directly identifies who you are. It also includes information that may be used to uniquely identify you, or a device you use, such as a cookie, or unique identifier. The Internet Protocol (IP) address associated with a computer you use to access our Site, Solution or Application is considered personal data.
10.5 Will Glisser sell my information if I sign up?
At Glisser, our users are not our products. We will not sell, rent or lease your Personal Data we collect from you.
10.6 What are cookies?
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. Cookies allow a website to identify a user’s device whenever that user returns to the website and are commonly used to make websites work more efficiently and enrich the user experience, as well as to provide information about your use of the site.
10.7 How can I manage cookies?
Most current browsers allow you to manage cookies stored on our computer. You may choose to reject all cookies, but this may result in our website not being accessible or have degraded functionality.
– Apple Safari
– Google Chrome
– Mozilla Firefox
10.8 Where does Glisser act as the Data Controller and where does Glisser act as the Data Processor?
– Glisser is the Data Controller of “Customer Personal Data” collected as Customers sign up to the Solution
– Glisser is the Data Processor of “Content” uploaded into the platform by Customers
– Glisser is the Data Controller, jointly with the Customer, of “Audience Personal Data” collected by the Application
– Glisser is the Data Processor of additional “Personally Identifiable Information” collected via the platform as “Interaction Data”
– Glisser is the Data Controller of “Visitor Personal Data” submitted when downloading materials from our Website
Contact us on email@example.com for any questions or more information.