Glow Privacy Policy

Last Updated: 20 May, 2019

Thank you for registering at www.glow.co or on the Glow mobile app (together, the “Site”). At Glow and our corporate affiliates (collectively, “Glow,” “we,” “us” or “our”) highly value and respect your (“you” or “your”) privacy. Please read the following to learn more about our Privacy Policy. Feel free to email us at help@glow.co if you have any questions.

By using or accessing the Site in any manner, regardless of whether you register or create an Account through the Site, you acknowledge that you agree to this Privacy Policy. If you do not agree to this Privacy Policy or Terms of Service, please do not access or otherwise use the Site or any information contained herein.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using the Site, and to the treatment of personally identifiable information by our partners. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information in connection with the Site. In certain cases, we may also share some Personal Information with third parties, but only as described below.

How do we collect and use Personal Information?

We receive and store any information you knowingly provide to us. Glow also maintains data that has been provided to us or uploaded to Glow by you, as well as our “Business Partners” (those vendors, partners, and providers we work with to run our business – and who have written agreements with us that specifically indicate how they will protect your information).

You must only submit to us information that is accurate and not misleading, and you must keep it up to date and inform us of any changes. For any Personal Information you provide, we may collect or verify the same or similar information from our affiliates and other third parties, such as employers, insurers, brokers or agents, credit agencies, and financial institutions, healthcare providers, and other sources.

Personal Information we collect	Why we collect it?
Information pertaining to your business, location, payroll, revenue, and vehicles.	We need this in order to determine the appropriate insurance price based on a risk assessment of your business, the type of work you do, your employees, claims history, insurance coverage information, benefits, and other attributes.
Information pertaining to your employees, contractors, and subcontractors.	We need this in order to determine eligibility for products and price based on a risk assessment of your employees and contractors and what type of work they do, when and where they work and other attributes. If the information you provide includes Personal Information of individuals (including your employees), you represent that you have provided notice to that third party and have obtained his or her consent.
Your name, address, and employment information.	We need this in order to determine the appropriate insurance price and eligibility for products based on a risk assessment of your claims history, financial, family, activity, health information, and other attributes. We may contact you about your care and benefits by regular mail.
Your email address.	This is part of the account creation process. It’s also the way that we will contact you with policy, service, claims, availability in your region, and news-related communications. We may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more relevant and improve our Site. By providing your email address, you are consenting to receive email communications from us even if you don’t don’t purchase insurance.
Your phone number.	We need this in order to contact you. We may share your phone number with our partners and service providers who need to coordinate with you. To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, you can adjust the types of notifications you receive and when you receive them by editing your SMS notification settings. We may also use your information to notify you about safety programs, payment information and/or to communicate with you about your Account. You will have the ability to opt out of any marketing or advertising communications, but we may still send you communications relating to your Account for purposes important to the Site, such as password recovery or a payment reminder.
Your payment information.	This is needed to process your payment. Since we use a third-party payment processor, we have only limited information about your payment transactions.
Social accounts.	This may be your preferred method for account creation. You may also use social connection as a way to invite others to Glow.
Contact/Address book.	You may use your contact list to invite others to Glow.
App, device usage statistics and location data.	We aggregate and anonymize this data to look for statistical patterns that can help us give you, and all our users, more precise rates and coverage, as well as to improve overall performance and experience. When you use the Site through the App on a device, we may collect information about your location. We identify your location only to provide a more tailored experience for you.
The type of incident, date, and time.	We need this in order to create a record of your claim. We maintain claims information and in some cases, we may request additional consent from you if we think that there is other information that we can use to help you.

Personal Information we collect

Why we collect it?

Information pertaining to your business, location, payroll, revenue, and vehicles.

We need this in order to determine the appropriate insurance price based on a risk assessment of your business, the type of work you do, your employees, claims history, insurance coverage information, benefits, and other attributes.

Information pertaining to your employees, contractors, and subcontractors.

We need this in order to determine eligibility for products and price based on a risk assessment of your employees and contractors and what type of work they do, when and where they work and other attributes. If the information you provide includes Personal Information of individuals (including your employees), you represent that you have provided notice to that third party and have obtained his or her consent.

Your name, address, and employment information.

We need this in order to determine the appropriate insurance price and eligibility for products based on a risk assessment of your claims history, financial, family, activity, health information, and other attributes. We may contact you about your care and benefits by regular mail.

Your email address.

This is part of the account creation process. It’s also the way that we will contact you with policy, service, claims, availability in your region, and news-related communications. We may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more relevant and improve our Site. By providing your email address, you are consenting to receive email communications from us even if you don’t don’t purchase insurance.

Your phone number.

We need this in order to contact you. We may share your phone number with our partners and service providers who need to coordinate with you.

To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, you can adjust the types of notifications you receive and when you receive them by editing your SMS notification settings. We may also use your information to notify you about safety programs, payment information and/or to communicate with you about your Account. You will have the ability to opt out of any marketing or advertising communications, but we may still send you communications relating to your Account for purposes important to the Site, such as password recovery or a payment reminder.

Your payment information.

This is needed to process your payment. Since we use a third-party payment processor, we have only limited information about your payment transactions.

Social accounts.

This may be your preferred method for account creation. You may also use social connection as a way to invite others to Glow.

Contact/Address book.

You may use your contact list to invite others to Glow.

App, device usage statistics and location data.

We aggregate and anonymize this data to look for statistical patterns that can help us give you, and all our users, more precise rates and coverage, as well as to improve overall performance and experience.

When you use the Site through the App on a device, we may collect information about your location. We identify your location only to provide a more tailored experience for you.

The type of incident, date, and time.

We need this in order to create a record of your claim. We maintain claims information and in some cases, we may request additional consent from you if we think that there is other information that we can use to help you.

How do we share Personal Information?

We do not rent or sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information with third parties as described in this section.

Glow will not sell, license, transmit or disclose outside of Glow the information you provide to us unless (a) expressly authorized by you, (b) necessary to enable our Business Partners to perform certain functions for us, (c) required or permitted by law.In all cases, we will disclose the information consistent with applicable laws and regulations and we will require the recipient to protect the information and use it only for the purpose it was provided and as necessary to assist us.

We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use the Site, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

We will retain your information for as long as your Account is active or as needed to provide you the Site. Notwithstanding any provision to the contrary, we will retain, access, use and disclose your information as we believe is necessary to comply with our legal obligations, resolve disputes, enforce our Terms of Service and other agreements, or to protect the rights, property or safety of Glow, our employees, our users or others. For more information about our privacy practices, including what information is provided to our Business Partners for payment, claim management, operations, please contact us at help@glow.co.

How do we protect your information?

We restrict access to your information to our employees and others who we feel must use it to provide our products and services. We also maintain electronic and procedural safeguards to protect your information that comply with federal law.

What information do we collect from Third Parties?

When you register for a Glow account and/or apply for the insurance products offered through the Site, we will collect information from third parties to, among other things, verify your identity; assist in the underwriting of your application; make eligibility, risk rating, policy issuance and enrollment determinations; obtain reinsurance; administer coverage; administer claims; protect against fraud; and conduct other legally permissible activities. In addition, if another company refers you to us, we may collect your information from that company in order to process your application for the insurance products offered through the Site. We may also search across various public Internet sources about you or your company. Glow bears no liability for the content’s accuracy, suitability, legality, or offensiveness.

Security?

Glow has adopted and adheres to stringent security standards designed to protect non-public personal information at glow.co against accidental or unauthorized access or disclosure. Among the safeguards that Glow has developed for this Site are administrative, physical and technical barriers that together form a protective firewall around the information stored at this Site. We periodically subject the Site to simulated intrusion tests and have developed comprehensive disaster recovery plans. We also review Business Partners’ privacy and security policies on a regular basis.

What Personal Information can I access?

In some cases, registered users will be able to change their password and update the information that they provide to us. In other cases, registered users may need to contact the appropriate state or federal institutions to update their information. Registered and unregistered users can access and delete cookies through their web browser settings.

The information you can view, update, and delete may change as the Site changes. If you have any questions about viewing or updating information we have on file about you, please contact us at help@glow.co. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to help@glow.co.

What choices do I have?

You can use certain features of the Site without registering, thereby limiting the types of information that we collect. You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

If you have registered on the Site, you may be able to add, update, or delete information in your Account as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your Account by emailing us at help@glow.co. Some or all of your information may remain in our records after your deletion of such information from your Account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete your Account, but not in a manner that would identify you personally.

Will Glow ever change this Privacy Policy?

As Glow evolves, we may need to update this policy. No matter what we change, we will always maintain our commitment to protecting your privacy. We will provide notice and ask for your consent to policy changes if required by applicable law; in other cases, please note that your continued use of the Site after any change means that you agree with, and consent to be bound by, the new Privacy Policy.

Your email?

We welcome your comments or questions about our Site and services. You can email your comments to our customer service center at help@glow.co. We will share your comments and questions with our customer service representatives and those employees most capable of addressing your questions and concerns. Please note that your email, like all non-encrypted Internet email communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. For that reason, to protect your privacy, please do not use email to communicate information to us that you consider confidential.

How can you stop receiving emails?

Each marketing email we send to you contains an unsubscribe link through which you may easily opt-out of receiving future commercial emails from us. If you do not wish to receive additional commercial emails from Glow, simply click the unsubscribe link and follow the instructions to unsubscribe your email address. If you have unsubscribed but continue to receive email from us or from one of our customers, you may report this to us at help@glow.co. Please note that unsubscribe requests may take up to 7 – 10 days to process. You will have the ability to opt out of any marketing or advertising communications, but we may still send you communications relating to your Account for purposes important to the Site, such as password recovery or a payment reminder.

Linking to other sites?

From time to time, Glow may provide links to other websites that we think might be useful or interesting – these are not owned or controlled by Glow and may be subject to separate terms and conditions and privacy policies. While we try to be proactive and ensure that appropriate protections are in place, we cannot be responsible for the privacy practices used by other website owners or the content or accuracy of those other websites. Links to various non-Glow websites do not constitute or imply endorsement by Glow of these websites, any products or services described on these sites, or of any other material contained in them.

Other information; “cookies” and “Online Tracking”?

You should also be aware that when you use the Site, we collect certain “usage data,” such as the number of visitors we receive or what pages are visited most often. This data helps us to analyze and improve the usefulness of the information of the Site.

We may also collect, or receive from third parties, information based on your IP address that provides us your geolocation data in order to identify relevant markets for users down to a zip code level of detail and to provide a better mobile experience. We do not store, sell, disclose or use this data to serve advertisements.

Like most commercial website owners, we may use what is known as “cookie” technology. A “cookie” is an element of data that a website can send to your browser when you link to that website. It is not a computer program and has no ability to read data residing on your computer or instruct it to perform any step or function. By assigning a unique data element to each visitor, the website is able to recognize repeat users, track usage patterns and better serve you when you return to that site. Our cookies do not extract other personal information about you, such as your name or address. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. We may also use what is known as “client-side page tagging,” which uses code on each page to write certain information about the page and the visitor to a log when a page is rendered by your web browser. This technique is also commonly used on commercial websites. “Tagging” does result in a JavaScript program running on your computer, but it is limited to providing information about the page that you are requesting and the configuration of your browser. It will not read any of your data files, or execute any additional programs. It does not extract any personal information about you, such as your name or address. You can prevent tagging by disabling JavaScript in your browser, but that may prevent you from using all of the Site’s functions.

Because a “Do No Track” (DNT) standard has not yet been adopted, we do not currently respond to DNT signals.

Who should use Glow’s website and App?

Our products and services are intended for anyone 18 years of age and older; we do not market any products or services to children under the age of thirteen or knowingly collect any information from children under the age of thirteen. If we become aware that information is or has been submitted by or collected from a child under the age of thirteen, we will delete this information.

General, Governing Law and Jurisdiction

We reserve the right to discontinue or modify any aspect of the Site at any time. This Policy, together with our Terms of Service and any other legal notices published by us on our website and in the App, shall constitute the entire agreement between us concerning the Site. If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

This Policy shall be governed by the laws of the State of California, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the courts located in the State where the policy was issued, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.