Effective Date: March 28, 2023
Table of Contents
- How we collect and use (process) your personal information
- Use of the glue.co website
- Cookies and tracking technologies
- Use of the Glue services
- When and how we share information with third parties
- Transferring personal data to the U.S.
- Data Subject rights
- Security of your information
- Data storage and retention
- Changes to this Privacy Notices
- Questions, concerns, or complaints
Mysteries Inc. d/b/a Glue ("we," "us," or "our") is an employee engagement platform. We provide a variety of tools to help our customers accomplish employee engagement goals, including tools that analyze connection data and tools that help you plan and execute virtual events.
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes the Glue’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.
How we collect and use (process) your personal information
Glue collects personal information about its website visitors, users, and customers.
Types of Personal Data. With a few exceptions, the information we collect is generally limited to:
- Email address
- Information needed to deliver goods, if you sign up for an event that involves delivered goods (address, phone number)
- Data related to authorized integrations with our customers’ internal systems, such as human resources information systems (HRIS), messaging platforms, and calendar applications
How We Collect Personal Data. Personal data is collected from a combination of sources, including:
- Directly from users when they create and use their accounts
- From employers when they provide information about their employees
- Through authorized integrations with our customers’ internal systems, such as HRIS, messaging platforms, and calendar applications
- Through third parties for the purposes of marketing our services. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third party website (e.g. LinkedIn)
Purposes of Collection and Processing. We use this information to provide our services to our customers and their employees. Our services include generating reports and analytics for employers to help them with employee engagement, morale, connection, and retention. We also use personal information to ensure the security and integrity
Data Sharing. We may use the personal data of users to provide reports and analytics to their employer. When providing reports and analytics to employers, our goal is to provide aggregated and anonymized information whenever possible. We do not sell personal information to anyone. We only share personal information with third parties who are facilitating the delivery of our services, or when required by law or to protect the rights and interests of Glue or our users.
Legal Basis for Data Processing. We process personal data based on the following legal grounds:
- Consent: Users or customers may provide explicit consent for processing their personal data or their employees’ personal data for specific purposes.
- Contractual necessity: Processing personal data may be necessary to fulfill the terms of the agreement between Glue and our customer.
- Legitimate interests: We may process personal data for purposes that align with the reasonable expectations of our customers and their employees, and which do not unduly impact individual privacy rights.
Use of the Glue Website
As is true of most other websites, Glue’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of Glue’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
Glue has a legitimate interest in understanding how users, customers and potential customers use its website. This assists Glue with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet member and customer needs.
Cookies and tracking technologies
- What are cookies? Cookies are small text files that are stored on your device when you visit a website. They allow the website to recognize your device and remember your preferences, such as login details, language settings, or other customizations. Similar tracking technologies, such as web beacons and pixels, function in a similar way.
- Types of cookies we use. We use the following types of cookies on our website and platform:
- Strictly Necessary Cookies: These cookies are essential for the operation of our website and platform. They enable you to navigate the site and use its features, such as accessing secure areas and remembering your login details.
- Performance Cookies: These cookies collect information about how visitors use our website, such as which pages they visit most often and if they receive any error messages. The information collected by these cookies is aggregated and anonymous, and it is used to improve the site's performance.
- Functional Cookies: These cookies allow our website to remember choices you make and provide enhanced, personalized features.
- Marketing Cookies: These cookies are used to deliver relevant advertising to visitors who have shown an interest in our services. They may be used to track user behavior across different websites and tailor advertising based on user preferences.
- How to manage your cookie preferences. You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, but this may affect the functionality of our website and platform. For more information on how to manage cookies, please consult your browser's help documentation. Please note that if you disable certain cookies, some features of our website and platform may not function properly, and we may not be able to provide you with the best possible user experience.
Sharing information with third parties
The personal information Glue collects from you is stored in one or more databases hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, Glue engages third parties to send information to you, including information about our products, services, and events.
We do not otherwise reveal your personal data to non-Glue persons or businesses for their independent use unless: (1) you request or authorize it; (2) it’s in connection with performing our services under an agreement or contract, which would typically be with your employer for employee engagement services; (3) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) to address emergencies or acts of God; or (6) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.
Transferring personal data to the U.S.
Glue has its headquarters in the United States. Information we collect about you will be processed in the United States. By using Glue’s services, you acknowledge that your personal information will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Pursuant to Article 46 of the GDPR, Glue is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.
Depending on the circumstance, Glue also collects and transfers to the U.S. personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Glue in a manner that does not outweigh your rights and freedoms. Glue endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Glue and the practices described in this Privacy Statement. Glue also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, Glue has received zero government requests for information.
For more information or if you have any questions, please contact us at privacy@Glue.co
Rights for Residents of Certain US States
Depending on where you live, you may have certain rights under state law, subject to certain exemptions and limitations. For questions or complaints concerning the processing of your personal data, you can email us at privacy@Glue.co.
- California Privacy Rights. If you are a California resident, you have certain rights under the California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA”). These rights include:
- The right to know about the personal information we collect about you and how it is used and shared.
- The right to request deletion of your personal information.
- The right to opt-out of the sale of your personal information (if applicable).
- The right to non-discrimination for exercising your privacy rights.
To exercise your rights under the CCPA, you can submit a verifiable consumer request to us by contacting us at email@example.com. We will respond to your request within 45 days. If we require more time, we will notify you of the reason and extension period in writing.
- California Resident Privacy Disclosures. Under the CCPA, California residents are entitled to the following additional disclosures about our data processing. These disclosures apply solely to users, customers, and site visitors who live in the State of California (“California Residents”). All terms used in this section have the same meaning as when used in the CCPA.
- Glue collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Commercial information
- Internet or other similar network activity
- For more information on the information collected, the sources of information, purposes of collection, and third party sharing, see the previous sections of this Privacy Notice.
European Union Data Subject rights
The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right of data portability
- Right to object
- Rights related to automated decision making including profiling
This Privacy Notice is intended to provide you with information about what personal data Glue collects about you and how it is used.
If you wish to confirm that Glue is processing your personal data, or to have access to the personal data Glue may have about you, please contact us.
You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Glue might have received the data from Glue; what the source of the information was (if you didn’t provide it directly to Glue); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Glue if it is inaccurate. You may request that Glue erase that data or cease processing it, subject to certain exceptions. You may also request that Glue cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Glue processes your personal data. When technically feasible, Glue will—at your request—provide your personal data to you.
Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Glue will provide you with a date when the information will be provided. If for some reason access is denied, Glue will provide an explanation as to why access has been denied.
Data storage and retention
Your personal data is stored by the Glue on its servers, and on the servers of the cloud-based database management services the Glue engages, located in the United States. The Glue retains service data for the duration of the customer’s business relationship with the Glue and for a period of time thereafter, to analyze the data for Glue’s own operations, and for historical and archiving purposes associated with Glue’s services. Glue retains prospect data until such time as it no longer has business value and is purged from Glue systems. All personal data that Glue controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: privacy@Glue.co
We do not knowingly attempt to solicit or receive information from children.
Changes to Our Privacy Notice
Glue reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice's effective date.
Questions, concerns or complaints
If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:
Mysteries Inc. d/b/a Glue
113 Cherry St
Seattle, Washington 98104-2205 US