Thank you for choosing to be part of our community at TRUE GLASSY LTD, doing business as True Glassy (“True Glassy,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at hello@trueglassy.com.

This privacy notice describes how we might use your information if you:

Download and use our mobile application — True Glassy
Engage with us in other related ways ― including any sales, marketing, or events
In this privacy notice, if we refer to:

“App,” we are referring to any application of ours that references or links to this policy, including True Glassy.
“Services,” we are referring to our App, and other related services, including any sales, marketing, or events.
The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the App, express an interest in obtaining information about us or our products and Services, participate in activities on the App (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contact us.

The personal information that we collect depends on the context of your interactions with us and the App, the choices you make, and the products and features you use. The personal information we collect can include the following:

Personal Information Provided by You. We collect names; email addresses; usernames; passwords; contact or authentication data; and other similar information.

Social Media Login Data. We provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when you visit our App.

We automatically collect certain information when you visit, use, or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App, and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our App, which we record in log files. This log data may include your IP address, device information, browser type, and settings, information about your activity in the App, device event information, and hardware settings.
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the App. This device data can include your IP address, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the App. You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note, however, if you choose to opt-out, you may not be able to use certain aspects of the Services.

 

 

Information collected through our App

In Short: We collect information regarding your mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our App you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our App, for troubleshooting, and for our internal analytics and reporting purposes.

 

 

 

 

2. HOW DO WE USE YOUR INFORMATION?

In Summary: We utilize your information based on legitimate business necessities, to fulfill our contract with you, adhere to our legal responsibilities, and/or with your permission.

We employ the personal information gathered via our App for various business objectives detailed below. We process your personal data relying on our legitimate business interests, to enter into or execute a contract with you, with your approval, and/or for abiding by our legal duties. Next to each purpose listed below, we specify the particular processing grounds we depend on.

We utilize the information we collect or receive for the following purposes:

To Facilitate Account Creation and Login: If you opt to link your account with us to a third-party account (like your Google or Facebook account), we use the information you permitted us to collect from those third parties to ease the account creation and login process as part of the contract performance. Refer to the "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" section for more information.
To Post Testimonials: We display testimonials on our App that might include personal information. Before posting a testimonial, we will acquire your consent to use your name and the content of the testimonial. If you desire to update or erase your testimonial, please reach out to us at hello@trueglassy.com, ensuring to include your name, testimonial location, and contact information.
Request Feedback: We may employ your information to seek feedback and to get in touch with you regarding your use of our App.
To Enable User-to-User Communications: With each user’s consent, we may use your information to allow user-to-user communications.
To Manage User Accounts: We may utilize your information for managing our account and maintaining its functionality.
To Send Administrative Information: We use your personal data to send information about products, services, and new features, as well as updates to our terms, conditions, and policies.
To Safeguard our Services: We may use your information as part of our initiatives to keep our App secure (for instance, for fraud monitoring and prevention).
To Enforce Our Terms, Conditions, and Policies: This is necessary for business purposes, to abide by legal and regulatory requirements, or in connection with our contract.
To Respond to Legal Requests and Prevent Harm: If we receive a legal subpoena or request, we may need to inspect the data we hold to decide on our response.
Fulfill and Manage Orders: We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the App.
Administer Prize Draws and Competitions: We may use your information to conduct prize draws and competitions when you choose to participate in them.
To Deliver and Facilitate Delivery of Services: We use your information to provide and facilitate the delivery of services you request.
To Respond to User Inquiries/Offer Support: We may use your information to respond to your queries and address any potential issues you might encounter while using our Services.
To Send Marketing and Promotional Communications: We and/or our third-party marketing partners may use the personal information you provide for our marketing purposes if it aligns with your marketing preferences. For instance, when expressing an interest in obtaining information about us or our App, subscribing to marketing, or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (refer to the "WHAT ARE YOUR PRIVACY RIGHTS?" section below).

 

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Summary: We share your information only when it is necessary and with your consent, to abide by laws, provide our services, safeguard your rights, or adhere to business obligations.

We may process or share your data based on the following legal justifications:

Consent: We process your data when you have given us explicit permission to use your personal information for a specific purpose.
Legitimate Interests: We process your data when it is reasonably necessary to fulfill our legitimate business interests.
Performance of a Contract: When a contract is in place between us, we process your personal information to fulfill the terms of the contract.
Legal Obligations: We may disclose your information when we are required by law to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes (such as responding to a court order or subpoena, including for national security or law enforcement requirements).
Vital Interests: We may disclose your information when we believe it is necessary to investigate, prevent, or act upon potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following scenarios:

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf, requiring access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. Selected third parties may use tracking technology on the App, which enables them to collect data on our behalf about how you interact with our App over time. This data may be used to, among other things, analyze and track data, determine the popularity of certain content, pages, or features, and understand online activity. Unless specified in this notice, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. Contracts are in place with our data processors, designed to help safeguard your personal information. They cannot use or share your personal information unless we instruct them to, and they must protect the data they hold on our behalf and retain it for the period we instruct.
Other Users: When you share personal information (e.g., by posting comments, contributions, or other content to the App) or interact with public areas of the App, such personal information may be viewed by all users and may be publicly made available outside the App indefinitely. If you interact with other users of our App and register through a social network (such as Facebook), your social network contacts will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our App, and view your profile.

 

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Summary: We only share your information with specific categories of third parties.

We share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".

Data Services
To understand more about the data collected by third-party services, their purpose, and how data protection is ensured, please visit the following pages:
AWS policy
Data protection in Amazon Cognito

 

 

5. Social Networks

In Short: If you opt to register or log in to our services through a social media account, we may access certain details about you.

Our App provides the option to register and log in using your third-party social media account details (such as Facebook or Google logins). When you choose this option, we receive specific profile information about you from your social media provider. The extent of the profile information we receive can vary depending on the social media provider, but it often includes your name, email address, friends list, profile picture, and other information you decide to make public on the social media platform.

We will only use the information we receive for the purposes outlined in this privacy policy or otherwise made clear to you within the relevant App. Please be aware that we do not control and are not responsible for other uses of your personal information by your third-party social media provider. We advise reviewing their privacy policy to understand how they collect, use, and share your personal information, and how you can adjust your privacy settings on their platforms and apps.

 

 

 

6. AFFILIATE DISCLAIMER

In Short: Our mobile application may include links to affiliate websites, and we earn a commission for any purchases made by you on the affiliate website through these links.

Our App may feature links to various affiliate websites. When you click on these links and make a purchase on the affiliate website, we may receive a commission. This is a common practice and helps support the maintenance of our App and the creation of content.

It is important to note that we only recommend products or services that we believe in and think could be beneficial to our users. We aim to be transparent about our affiliate relationships to avoid any potential bias or conflicts of interest.

If you have any questions or need more information about our affiliate partnerships, feel free to contact us at the provided contact information in this privacy policy.

 

 

 

EXTERNAL LINKS DISCLAIMER

Our mobile application may feature links to external websites or content owned or stemming from third parties, or contain links to websites and features in banners or other forms of advertising. We do not investigate, monitor, or check these external links for accuracy, adequacy, validity, reliability, availability, or completeness. WE MAKE NO WARRANTIES, ENDORSEMENTS, GUARANTEES, AND DISCLAIM ALL RESPONSIBILITY FOR ANY INFORMATION PROVIDED BY THIRD-PARTY WEBSITES LINKED THROUGH OUR APP OR ANY WEBSITE OR FEATURE LINKED IN ANY BANNER OR OTHER ADVERTISING. WE WILL NOT BE INVOLVED OR RESPONSIBLE IN ANY WAY FOR MONITORING ANY TRANSACTION BETWEEN YOU AND THIRD-PARTY PRODUCT OR SERVICE PROVIDERS.

AFFILIATES DISCLAIMER

Our mobile application may contain links to affiliate websites, and we earn a commission for any purchases made by you on these affiliate websites through such links.

 

DATA SHARING

We do not share your personal data with our affiliate partners.

TESTIMONIALS DISCLAIMER

Our App may feature testimonials from users of our products and/or services. These testimonials represent the real-life experiences and opinions of such users. However, these experiences are personal to those specific users, and may not be indicative of all users of our products and/or services. We do not claim, nor should you assume, that all users will have the same experiences. INDIVIDUAL RESULTS MAY VARY.

The testimonials on our App are presented exactly as submitted by users in various forms such as text, audio, and/or video. We review all testimonials before posting them, and they are displayed exactly as provided by the users, except for corrections in grammar or typing errors. Some testimonials may be shortened if they contain information not relevant to the general audience.

The opinions expressed in the testimonials belong solely to the individual user and do not reflect our views and opinions. We are not associated with users who provide testimonials, and users are not paid or otherwise compensated for their testimonials.

The testimonials on our App are not intended to make claims that our products and/or services can be used to diagnose, treat, mitigate, cure, prevent, or otherwise be used for any disease or medical condition.

No testimonials have been clinically proven or evaluated.

 

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless a longer retention period is mandated or allowed by law.

We commit to retaining your personal information only for as long as required for the purposes stated in this privacy notice, unless a longer retention period is necessitated or permitted by law, including for tax, accounting, or other legal obligations. None of the purposes outlined in this notice will necessitate keeping your personal information for a period exceeding the duration of your user account with us.

In the event that we no longer have a continuing legitimate business need to process your personal information, we will proceed to delete or anonymize it. If this is not immediately possible (for example, due to the information being stored in backup archives), we will securely store your personal information and isolate it from further processing until deletion can be achieved.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We are committed to safeguarding your personal information through implementing various organizational and technical security measures.

We have instituted a range of appropriate technical and organizational measures designed to safeguard the personal information we handle. However, please be aware that, despite our best efforts, no security measures are perfect or impenetrable. Consequently, we cannot guarantee complete security against hacking, cybercrime, or other unauthorized third-party access to or interference with your personal information. While we strive to protect your personal data, the transmission of such information, to and from our App, is at your own risk. You are advised to only access the App within a secure environment.

7.1. WHERE IS YOUR DATA STORED?

The data we collect is stored in the cloud, with servers located within the UK and the US. This ensures that your data is kept within a jurisdiction with strong data protection and privacy regulations.

 

 

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You have a variety of rights concerning your personal data, particularly if you are situated in regions like the EEA or UK.

If you reside in the European Economic Area (EEA) or the United Kingdom (UK), you are afforded specific rights regarding your personal information under data protection laws. These rights enable you to:

Access: Request a copy of your personal information that we have on file.
Rectification: Request correction of any inaccuracies in your personal information that we have on file.
Erasure: Request deletion of your personal information from our records in certain circumstances.
Restrict Processing: Request that we limit how we process your personal information.
Data Portability: Request a copy of your personal information in a structured, commonly used, and machine-readable format, and have it transferred to another organization, where technically feasible.
Object: Object to our processing of your personal information in certain circumstances, especially where the processing is based on our legitimate interests.
To exercise these rights, please contact us using the contact details provided below. We will respond to and process each request in accordance with applicable data protection laws.

It is important to note that withdrawing your consent will not affect the lawfulness of any processing that took place prior to the withdrawal of consent. Additionally, we may still process your personal information based on legal grounds other than consent, as permitted by law.

If you have concerns regarding our processing of your personal information, you also have the right to lodge a complaint with your local data protection authority. In the EEA or UK, you can find their contact information here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have any questions or comments about your privacy rights, you can contact us at hello@trueglassy.com.

Account Information

At any time, you have the ability to:

Log into your account settings and update your user account.
Contact us via hello@trueglassy.com to request changes or termination of your account.
Upon receiving your request to terminate your account, we will deactivate or delete your account and remove your information from our active databases. However, some information might be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing emails at any time by clicking on the unsubscribe link in the emails that we send or by contacting us at hello@trueglassy.com. After doing so, you will be removed from the marketing email list. However, we may still need to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To opt-out of other forms of communication, you can:

Adjust your account settings accordingly.
Contact us at hello@trueglassy.com.

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting that you can activate to signal your privacy preference not to have information about your online browsing activities monitored and collected. As of now, there is no uniform standard for recognizing and implementing DNT signals. Consequently, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is established and we are required to follow it in the future, we will update our practices and inform you in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you have specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, allows our users who are California residents to request, once a year and free of charge, information regarding the categories of personal information (if any) we disclosed to third parties for direct marketing purposes within the preceding calendar year. Additionally, these users can obtain the names and addresses of all third parties with which we shared personal information during that time. If you are a California resident and wish to make such a request, please submit your request in writing to us using the contact information provided below.

Users of the App under 18 years of age, residing in California, who have a registered account with the App, have the right to request the removal of unwanted data that they publicly post on the App. To request removal of such data, contact us using the contact information provided below, ensuring to include the email address associated with your account and a statement confirming that you reside in California. We will ensure that the data is not publicly displayed on the App, but be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

 

The California Code of Regulations outlines specific definitions of a "resident":

(1) Any individual who is in the State of California for a purpose that is not temporary or transitory.

(2) Any individual who is domiciled in the State of California but is outside the state for a temporary or transitory purpose.

All other individuals are considered "non-residents."

If this definition of "resident" applies to you, specific rights and obligations pertain to your personal information.

What Categories of Personal Information Do We Collect?

Over the past twelve (12) months, we have collected the following categories of personal information:

[A list of the categories of personal information collected, which may include but is not limited to: Identifiers (such as contact information, cookies, IP addresses); personal information categories listed in the California Customer Records statute; protected classification characteristics under California or federal law; commercial information; biometric information; internet or other electronic network activity information; geolocation data; sensory data; professional or employment-related information; non-public education information (per the Family Educational Rights and Privacy Act); and inferences drawn from other personal information.]

Additionally, we may collect other types of personal information outside of these categories during your interactions with us, whether in-person, online, or via phone or mail, such as when:

You request assistance through our customer support channels;
You participate in customer surveys or contests; and
We facilitate the delivery of our Services and respond to your inquiries.

 

 

How Do We Use and Share Your Personal Information?

You can find more information about our data collection and sharing practices in this privacy notice.

You can reach out to us by emailing hello@trueglassy.com or by referring to the contact details at the bottom of this document.

Should you opt to use an authorized agent to exercise your right to opt out, we may deny the request if the authorized agent fails to provide valid proof of their authorization to act on your behalf.

 

 

 

 

Will Your Information be Shared with Anyone Else?

We may share your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as conducting internal research for technological development and demonstration. This is not considered "selling" your personal data.

TRUE GLASSY LTD has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

Category B: Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
Category C: Characteristics of protected classifications under California or federal law, such as gender or date of birth.
Category D: Commercial information, such as transaction information, purchase history, financial details, and payment information.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "Who Will Your Information be Shared With?"

TRUE GLASSY LTD has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. TRUE GLASSY LTD will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your Rights with Respect to Your Personal Data

Right to Request Deletion of the Data - Request to Delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be Informed - Request to Know

Depending on the circumstances, you have the right to know:

whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you for exercising your privacy rights.

 

 

Verification Process

Upon receiving your request to access or modify your personal information, we need to verify your identity to confirm that you are the individual about whom we have collected data. This verification process requires us to ask you for information to match it with the data you have previously provided. For example, the type of request you submit may require you to provide certain information so that we can match it with the information already in our records, or we may contact you through a communication method (e.g., phone or email) that you have previously provided. We might also employ other verification methods depending on the situation.

We will use the personal information provided in your request solely for the purpose of verifying your identity or authority to make the request. As much as possible, we aim to avoid asking for additional information for verification purposes. However, if we cannot verify your identity with the information already available to us, we may request additional information for identity verification and for security or fraud prevention purposes. Any additional information provided for these purposes will be promptly deleted once the verification process is complete.

Other Privacy Rights

You have the right to object to the processing of your personal data.
You may request correction of your personal information if it is incorrect, no longer relevant, or ask to restrict the processing of the data.
You can designate an authorized agent to submit requests under the CCPA on your behalf. We may deny a request from an authorized agent if they do not provide proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
You may request to opt-out from the future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at hello@trueglassy.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we encourage you to get in touch with us.

 

 

 

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hello@trueglassy.com or by post to:

True Glassy Ltd

71-75 Shelton Street

Covent Garden

London

WC2H 9JQ

United Kingdom

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact hello@trueglassy.com.

 

 

 

Last updated: 25 October 2023