I. INTRODUCTION

When you use GlowOrder, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

LAST MODIFIED: May 01, 2020
EFFECTIVE DATE: May 01, 2020

II. OVERVIEW

A. SCOPE

This notice applies to users of GlowOrder’s services, including users of GlowOrder’s apps, websites, features, or other services.This notice describes how GlowOrder and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy notice.

This notice also governs GlowOrder’s other collections of personal data in connection with GlowOrder’s services. For example, we may collect the contact information of individuals who use accounts owned by GlowOrder for business customers or of owners of GlowOrder’s partners, or we may collect other personal data in connection with our mapping technology and features.

All those subject to this notice are referred to as “users” in this notice, and include bother bar patrons (also, “customers”), bartenders, and bar owners (also, “establishments”).

In addition, please note the following:

For California users: Information regarding GlowOrder’s privacy practices related to the California Consumer Privacy Act (CCPA) is available upon request at info@gloworder.com.

For those accompanying users without a GlowOrder account: The personal data of users who accompany the owner of a GlowOrder account, such as when a customer places an order by way of the owner of a GlowOrder account, is processed in accordance with our contract with the owner of that account, and not as otherwise described in this notice. Such processing may include sharing of location data with the owner of that account. Please contact the owner of such account for more information.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice only if permitted under the laws of those places. Please contact us at info@gloworder.com with any questions regarding our practices in a particular city, state or region.

B. DATA CONTROLLER AND TRANSFER

GlowOrder LLCis the data controller for the personal data collected in connection with use of GlowOrder’s services.Questions, comments, and complaints about GlowOrder’s data practices can be submitted to support@gloworder.com.

III. DATA COLLECTIONS AND USES

A. THE DATA WE COLLECT

GlowOrder collects:

  • Data provided by users to GlowOrder, such as during account creation
  • Data created during use of our services, such as location, app usage, and device data
  • Data from other sources, such as GlowOrder partners and third parties that use GlowOrder APIs

The following data is collected by or on behalf of GlowOrder:

1. DATA PROVIDED BY USERS. THIS INCLUDES:
a. USER PROFILE

We collect data when users create or update their GlowOrder accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes menu selection preferences and user settings. We may use the photos submitted by users to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”

b. IDENTITY VERIFICATION

We collect identity verification information for users. This may include information such as name, age, address, driver’s license number, and/or any other information typically contained on a government issued identification document. This information may be collected by an authorized vendor on GlowOrder’s behalf.

c. DEMOGRAPHIC DATA

We may collect demographic data about users, including through user surveys. We may also receive demographic data about users from third parties.

d. USER CONTENT

We collect the information users submit when they use GlowOrder services, contact GlowOrder customer support, or otherwise contact GlowOrder. This may include feedback, questions, complaints,comments, photographs or other recordings collected by users.

DATA CREATED DURING USE OF OUR SERVICES. THIS INCLUDES:
a. LOCATION DATA

We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. GlowOrder collects this data when the GlowOrder app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.GlowOrder may also collect this data when the GlowOrder app is running in the background of the user’s mobile device. Users may use the GlowOrder apps without enabling GlowOrder to collect location data from their mobile devices, but this will affect some functionality available in the GlowOrder apps. For example, a user who has not enabled location data collection will be required to scan an establishment’s unique QR code to order using GlowOrder. In addition, the location data collected from a user’s device will be linked to the user’s account, even if they have not enabled location data to be collected from their device, including for purposes of receipt generation, chargeback mitigation, customer support, fraud detection, insurance, and litigation.

b. TRANSACTION INFORMATION

We collect transaction information related to the use of our services, including the type of itemsordered, specific order details, location information, date and time services were provided, amount charged, gratuity amount selected, relative distance from participating locations, distance traveled, and/or payment method(s). Additionally, if someone uses a promotion code that may be assigned to you, we may associate your name with that person.

c. USAGE DATA

We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.

d. DEVICE DATA

We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

e. COMMUNICATIONS DATA

We enable users to communicate with each other and GlowOrder through GlowOrder’s mobile apps and websites. For example, we enable customers and bartenders to view data transmitted to and/or from each other. To provide this service, GlowOrder receives some data regarding the content of the communications (typically the order details), the date and time of the communications, and the financial details of the communications. GlowOrder may also use this data for risk mitigation, for customer support services (including to resolve disputes), for safety and security purposes, to improve our products and services, and for analytics.

3. DATA FROM OTHER SOURCES

This includes:

  • User feedback, including questions, comments, or compliments.
  • Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
  • GlowOrder account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts.
  • Users or others providing information in connection with claims or disputes.
  • GlowOrder business partners through which users create or access their GlowOrder account, such as payment providers, social media services, or apps or websites that use GlowOrder’s APIs or whose APIs GlowOrder uses.
  • Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
  • Insuranceor financial services providers.
  • Publicly available sources.
  • Marketing service providers.

GlowOrder may combine the data collected from these sources with other data in its possession.

B. HOW WE USE PERSONAL DATA

GlowOrder collects and uses data to enable reliable and convenient services. We also use the data we collect:

  • To enhance the safety and security of our users and services
  • For customer support
  • For research and development
  • To send marketing and non-marketing communications to users
  • In connection with legal proceedings

GlowOrder does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.GlowOrder uses the data it collects for the following purposes.

1. PROVIDING SERVICES AND FEATURES.

GlowOrder uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

  • Create and update users’ accounts.
  • Verify user’s identity andpayment capabilities.
  • Enable services.
  • Offer, process, or facilitate payments for our services.
  • Offer, obtain, provide, or facilitate invoicing or financing solutions in connection with our services.
  • Track and share the information necessary to provide our services.
  • Enable features that allow users to share information, such as when users submit feedback about an establishment, refer a friend to GlowOrder, sharelocation history data,or order history data.
  • Enable features to personalize users’ GlowOrder accounts, such as creating bookmarks for favorite places, storing favorite drinks, reorder previously-ordered rounds, and to enable quick access to previous orders. We may, for example, present a user with personalized recommendations based on their prior locationhistory and/or orders. Please see the section of this notice titled “Choice and transparency” to learn how to object to this use of personal data.
  • Enable accessibility features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing drivers to alert other users of their disabilities, allow text messages from users, and enable additional notification options.
  • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
2. SAFETY AND SECURITY.

We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

  • Basic verification and screening ofusers and establishments before enabling use of our services and at subsequent intervals, to help mitigate risks and/or prevent fraud.
  • Using data from devices to help identify potentially unsafe behavior such as excessive ordering and to inform them of ride sharing options.
  • Using information derived from driver’s license photos, and other photos submitted to GlowOrder, for safety and security purposes. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity.
  • Using device, location, profile, usage, and other data to mitigate risks, and to prevent, detect, and combat fraud or unsafe activities.
  • Using user feedback to encourage compliance with our Community Guidelines.
3. CUSTOMER SUPPORT.

GlowOrder uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

  • Direct questions to the appropriate customer support person
  • Investigate and address user concerns
  • Monitor and improve our customer support responses and processes
4. RESEARCH AND DEVELOPMENT.

We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5. ENABLING COMMUNICATIONS BETWEEN USERS.

For example, an establishment may call or message a user to alert them to an issue with their payment or to retrieve a lost item.

6. MARKETING.

GlowOrder may use the data we collect to market our services to our users. This includes sending users communications about GlowOrder services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by GlowOrder partners. For example, if a user has placed a particular order or placed an order at a particular establishment, we may provide recommendations, promotions, or ads about similar products, services, or establishments. Although we may send users communications about GlowOrder partners’ products and services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of GlowOrder’s services, user preferences, and user settings.

7. NON-MARKETING COMMUNICATIONS.

GlowOrder may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of GlowOrder or its partners.

8. LEGAL PROCEEDINGS AND REQUIREMENTS.

We may use the personal data we collect to investigate or address claims or disputes relating to use of GlowOrder’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

9. AUTOMATED DECISION-MAKING

We use personal data to make automated decisions relating to use of our services. This includes:

  • Enabling dynamic pricing, in which the fee assessed to an order may relate to the method of payment used.
  • Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm GlowOrder, its users, and others. In some cases, such as when a user is determined to be abusing GlowOrder’s referral program, such behavior may result in automatic deactivation.
  • Using user account details, user settings, user history, and user location informationto identify potential fraud.

C. COOKIES AND THIRD-PARTY TECHNOLOGIES

GlowOrder and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. GlowOrder uses cookies and similar technologies for purposes such as:

  • Authenticating users
  • Remembering user preferences and settings
  • Determining the popularity of content
  • Delivering and measuring the effectiveness of advertising campaigns
  • Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

D. DATA SHARING AND DISCLOSURE

Some of GlowOrder’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

GlowOrder may share the data we collect:

1. WITH OTHER USERS

This includes sharing:

  • Users’ name, “favorite drinks,” general and/or specific order history, and/or location history with establishments.
  • Users’ first name, user image,and geo-location information for use when a user elects to use a ride-sharing app.
  • For those who participate in GlowOrder’s referral program, we share certain personal data of referred users, such as usage history, with the user who referred them, to the extent relevant to determining the referral bonus.
2. AT THE USER’S REQUEST

This includes sharing data with:

  • GlowOrder business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, GlowOrder may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; suppliers or services; those with an API or service with which we integrate; or other GlowOrder partners and their users in connection with promotions, contests, or specialized services.
3. WITH THE GENERAL PUBLIC

Questions or comments from users submitted through public forums such as GlowOrder blogs and GlowOrder social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4. WITH THE GLOWORDER ACCOUNT OWNER

Use of a GlowOrder account by anyone other than the owner of that account is prohibited. GlowOrder relies upon multiple layers of verification to ensure that only the account owner uses his/her account. However, if a user places an order using an account owned by another party, we may share their order information, payment information, or anyother information, including real-time location data, with the owner of that account.

5. WITH GLOWORDER SUBSIDIARIES AND AFFILIATES

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

6. WITH GLOWORDER SERVICE PROVIDERS AND BUSINESS PARTNERS

GlowOrder provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

  • Payment processors and facilitators
  • Identity verification providers
  • Cloud storage providers
  • Marketing partners and marketing platform providers, including social media advertising services
  • Data analytics providers
  • Research partners, including those performing surveys or research projects in partnership with GlowOrder or on GlowOrder’s behalf
  • Vendors that assist GlowOrder to enhance the safety and security of its apps
  • Consultants, lawyers, accountants, and other professional service providers
  • Insurance and financing partners
  • Establishment partners and/or their point of sale providers
7. FOR LEGAL REASONS OR IN THE EVENT OF A DISPUTE

GlowOrder may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect GlowOrder’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including location and/or order information, with the owner of that credit card.This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. WITH CONSENT

GlowOrder may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

E. DATA RETENTION AND DELETION

GlowOrder retains user profile, transaction, and other personal data for as long as a user maintains their GlowOrder account.GlowOrder may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements and/or to permit for adequate recordkeeping.

GlowOrder retains user profile, transaction, and other information for as long as a user maintains their GlowOrder account. GlowOrder also maintains identity verification information (to the extent permitted by law) for as long as the user maintains aGlowOrder account.

Users may request deletion of their account at any time through the Settings > Privacy menus in the GlowOrder app, or through GlowOrder’s Help Center. Following such requests, GlowOrder deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, GlowOrder retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, GlowOrder may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, GlowOrder will delete the account as described above.

GlowOrder may also retain certain information, if necessary, for purposes of safety, security, and fraud prevention. For example, if GlowOrder deactivates a user’s account because of unsafe or fraudulent behavior, GlowOrder may retain certain information about that account to prevent that user from opening a new GlowOrder account in the future.

F. GROUNDS FOR PROCESSING

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of GlowOrder’s legitimate interests, or those of other parties, to fulfill our legal obligations, or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

TO PROVIDE REQUESTED SERVICES AND FEATURES

In order to provide our services, we must collect and use certain personal data. This includes:

  • User profile data, which we use to establish and maintain user accounts; verify user identity; communicate users about their location, orders, and accounts; and enable users to make or receive payments;
  • Establishment information used to verify an establishment’s eligibility to be auser;
  • Usage data, which is necessary to maintain, optimize, and enhance GlowOrder’s services, including to determine incentives, connect users and establishments, and calculate costs and payments;
  • Transaction information;
  • Information relating to customer support.
1. FOR PURPOSES OF THE LEGITIMATE INTERESTS OF GLOWORDER OR OTHER PARTIES

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in fraudulent, inappropriate, or dangerous behavior, such as by retaining data of banned users to prevent their use of GlowOrder’s apps. We also use usage data to prevent connectingusers for whom there is higher risk of conflict (for instance, because they have been the subject of prior disputes).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing GlowOrder’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with chargebacks, legal or insurance claims, and to protect the rights and safety of others.

2. TO FULFILL GLOWORDER’S LEGAL OBLIGATIONS

We collect and use personal data to comply with any legal requirement by anygovernment or other authority.

GlowOrder may also share data with law enforcement regarding criminal acts or threats, or requests by third parties pursuant to legal processes.

3. WITH CONSENT

GlowOrder may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

IV. CHOICE AND TRANSPARENCY

GlowOrder enables users to access and control the data that GlowOrder collects, including through:

  • In-app settings
  • Device permissions
  • Marketing opt-outs

GlowOrder also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that GlowOrder restrict its processing of user personal data.

A. PRIVACY SETTINGS

Settings menus in the GlowOrder app for users give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from GlowOrder. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

1. LOCATION DATA

GlowOrder uses users’ device location services to enable users to log into a participating establishment. Location data helps improve our services.

Users may enable or disallow GlowOrder to collect location data from their mobile devices through the Settings > Privacy menus in the GlowOrder app. Users and delivery recipients can enable or disallow such collections through the settings on their mobile device. However, this will affect the provision of GlowOrder services.

2. NOTIFICATIONS: DISCOUNTS AND NEWS

Users may enable GlowOrder to send push notifications about discounts and news from GlowOrder. Push notifications may be enabled or disabled through the Settings > Privacy menus in the GlowOrder app.

3. COMMUNICATIONS FROM ESTABLISHMENT PARTNERS

Delivery recipients who have opted in to communications from establishment partners may stop sharing their data with each partner in their GlowOrder account settings.

B. DEVICE PERMISSIONS

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the GlowOrder app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the GlowOrder app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

C. MARKETING OPT-OUTS

Users may opt out of receiving promotional emails from GlowOrder by visiting the GlowOrder website. Users may also opt out of receiving emails and other messages from GlowOrder by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as transaction receipts or information about their account.

D. USER DATA REQUESTS

GlowOrder provides users with a variety of ways to learn about, control, and submit questions and comments about GlowOrder’s handling of their data.

  • Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
  • Receiving data: Users can ask for a copy of data that GlowOrder collects from them with their consent or as necessary to provide our services.
  • Changing or updating data: Users can edit the name, phone number, email address, payment method, and other details through the Settings menu in the GlowOrderapp. They may also ask that GlowOrder change or update their data, including if they believe such data is inaccurate or incomplete.
  • Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the GlowOrder app, or through GlowOrder’s website.
  • Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. GlowOrder may continue to process data after such objection or request to the extent required or permitted by the terms of this Privacy Policy or by law.

In addition, depending on their location, users may have the right to file a complaint relating to GlowOrder’s handling of their personal data with the data protection authority.

V. UPDATES TO THIS NOTICE

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the GlowOrder apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, use of our services by users will be understood as consent to the updates to the extent permitted by law.