PRIVACY POLICY

Last updated: July 20, 2026

This Privacy Policy explains how Glo Digital Inc. ("Glo," "we," or "us") collects, uses, shares, and protects your information when you visit www.glo.com, use our apps, or otherwise interact with our products and services (the "Service"). It applies to our website and to all of the products and services we offer, including our software and our mobile and connected-device apps. If you have questions about anything in this policy, you can reach us using the contact information at the end.

1. What we collect

Information you give us

When you create an account, start a trial, make a purchase, or otherwise use the Service, we collect the information you provide. That typically includes your name, email address, phone number, password, gender, and payment details (stored encrypted), along with anything else you choose to share with us.

We may combine this information with data from other Glo services or trusted partners (for example, when you sign in through a social account) to give you a more useful experience.

We also collect information about how you find and first interact with Glo, such as referral sources, campaign identifiers, the landing pages you arrive on, and the choices you make during onboarding. We use this information to personalize the Service, including initial recommendations, sequencing, and the messaging you see, subject to your cookie and consent preferences as described in "Cookies, pixels, and similar technologies" and "Your choices."

Biometric sign-in

Glo offers optional biometric sign-in using Apple Face ID, Apple Touch ID, or Google biometric authentication so you can sign in to your Glo account without typing your password. This is for sign-in convenience only. The biometric matching is performed by Apple or Google on your device. Glo does not collect, store, or have access to your biometric data. We only receive a confirmation from Apple or Google that you have authenticated successfully. You can turn biometric sign-in off in your device settings or in the Glo app at any time.

Wellness Information

You may choose to share information related to wellness topics (such as fitness goals, sleep, mental wellbeing, menstrual cycle, pregnancy, or injury history) through questionnaires, journal entries, voice notes, profile data, ratings, feedback, or by syncing data from Apple Health or Apple HealthKit. We call this "Wellness Information."

We collect Wellness Information where you choose to provide it. Where applicable law requires consent for its collection or use, we obtain that consent before processing, and you can withdraw it at any time through "Your choices" below. Data you sync from Apple Health or Apple HealthKit is always collected only with your permission, which you grant and can revoke through your device settings.

Cookies, pixels, and similar technologies

When you visit our website, we and our partners use cookies, pixels, web beacons, SDKs, and similar technologies to run the site, remember your preferences, measure usage, prevent fraud, and deliver and measure advertising.

These technologies collect information such as device identifiers, IP address, browser type, language, operating system, the pages you came from and went to next, time spent on each page, clicks, scroll depth, and the date and time of your visit. You control non-essential cookies through the "Cookie Preferences" link in the footer and, where applicable law requires opt-in consent (including in the European Economic Area, the United Kingdom, Switzerland, and Quebec), through the cookie consent banner shown on your first visit, as described in "Your choices."

We use both session cookies (which clear when you close your browser) and persistent cookies (which remain until they expire or you delete them). The categories of third parties that collect data through the website are listed in the next section. To manage these technologies, see "Your choices" and the California section.

Session-replay and similar diagnostic tools are configured to respect your cookie and consent preferences and are designed to avoid capturing sensitive inputs (such as password fields and payment details) where reasonably practicable.

Referral sources, campaign identifiers, landing-page interactions, and similar marketing and analytics signals are collected and used for personalization and analytics only where consent is given or is not required by applicable law. Where consent is required and you decline or withdraw it through our cookie banner or other consent mechanism, we will not use those signals to personalize the Service or for analytics, and any associated cookies, pixels, or device identifiers covered by your choice will not be set or read.

Activity, log, and device information

When you use the Service, our servers and our analytics partners automatically record information your browser or device sends. This includes your IP address, device and browser type, operating system, language, the URLs you came from and went to, the pages you viewed and the order you viewed them, the time spent on each, the date and time, and unique cookie or device identifiers. We use this information for security, fraud prevention, performance, analytics, and advertising as described in this policy.

IP address

Your IP address is assigned automatically when your device connects to the internet. We retain it to diagnose technical issues, operate the website, recognize return visitors, derive approximate location (country, region, or city), enforce our Terms, and help protect Glo, our members, and others.

Communications with us

When you email, text, or otherwise contact Glo (including through the Coaching Service), we retain those communications so we can respond to you and improve the Service.

Content you post on the Service

If the Service lets you post text, images, audio, video, comments, messages, or other materials ("Member Content"), the Member Content you make available through the Service, and information about it (such as when and from where it was posted), may be visible to other members or to the public, depending on the feature. Member Content is governed by the license you grant Glo in the Terms of Use and Conditions. We treat metadata about your Member Content (such as posting time, device, and engagement) as activity information described above, and we apply this policy to any personal information contained in Member Content the same way we apply it to other information you provide.

Affiliated and linked websites

We sometimes offer Services through, or in connection with, other websites and platforms. Information you give those websites is sent to Glo to deliver the Service and is processed under this policy. Those affiliated and linked websites have their own privacy practices. Please read their policies as well.

2. The third parties that work with us

We work with third-party service providers to run, secure, analyze, and market the Service. They use cookies, pixels, SDKs, and similar technologies to collect data such as your IP address, device and browser information, page URLs, and event data (page views, clicks, sign-ups, purchases). They use this data to measure performance, attribute conversions, build audiences, and deliver more relevant advertising on Glo and elsewhere.

The categories of partners we work with are listed below, with illustrative examples in each. Specific partners change over time as we test, add, replace, or remove vendors, and we may work with additional partners in the same categories. We will update this policy if we begin working with a category of partner not described below.

These partners collect information from your device only to the extent your cookie preferences allow. You can manage your preferences through the "Cookie Preferences" and "Do Not Sell or Share My Personal Information" links in the footer, your browser settings, the cookie consent banner (shown on your first visit where applicable law requires opt-in consent, including in the European Economic Area, the United Kingdom, Switzerland, and Quebec), and the choices described elsewhere in this policy. We honor Global Privacy Control signals as described in the California section.

Category of partner	What they help us do	Examples (illustrative, not exhaustive)
Analytics and product measurement providers	Measure traffic, engagement, and feature usage; identify performance issues; inform product decisions	Google Analytics, PostHog, RudderStack
Advertising platforms and conversion-tracking pixels	Deliver, measure, attribute, and optimize advertising on Glo and on third-party platforms; build and target audiences, including by sharing hashed identifiers with these platforms	Search engines, social media platforms, and ad networks
Tag management and consent management providers	Deploy and manage tags and pixels on the website; honor your consent choices	Google Tag Manager
Mobile attribution and app analytics providers	Attribute mobile installs and in-app events; measure app performance	Apple App Store analytics, Apple Search Ads, Google Play Console, Singular
Member engagement, support, and lifecycle providers	Deliver email, SMS, push, and in-app messaging; provide member support, and may share identifiers with advertising platforms to support marketing	Braze, Zendesk
Cancellation and retention providers	Provide the cancellation flow and offer alternatives during cancellation; receive subscription status, cancellation reason, and account identifiers	Churnkey, Brightback
Session replay, heatmap, and user-experience research providers	Understand how members interact with the website to identify usability issues and improve the Service	PostHog (session replay)
AI and personalization providers	Provide artificial intelligence, machine learning, and recommendation services that help us personalize content, recommendations, and communications based on your activity, onboarding responses, and how you found Glo, and that support our engineering and product development	Anthropic (Claude API), OpenAI, AWS Bedrock, AWS Personalize
Infrastructure, security, and fraud-prevention providers	Host the website; deliver content; detect and prevent fraud, abuse, bots, and security incidents	Cloud hosting, content delivery networks, web application firewalls, bot management, and fraud detection providers

Merchant-of-record payment services. In certain markets, Stripe acts as the merchant of record for purchases made through our website. For those transactions, Stripe processes your payment, transaction, and related account information as an independent business under its own privacy policy and terms (including Stripe Link, which provides purchase management and transaction support), not solely as a service provider acting on Glo's behalf. For those purchases, Stripe is the seller of record and an independent controller of the payment and transaction data it collects, and its collection and use of that data are governed by Stripe's and Link's own privacy notices. Glo receives subscription status, transaction outcome, and related account information from Stripe so we can activate and operate your membership, and we handle that information under this policy. Stripe's privacy policy is available at stripe.com/privacy.

Opt-out resources. You can opt out of interest-based advertising from many of these companies through the Digital Advertising Alliance at youradchoices.com or aboutads.info, through the Network Advertising Initiative at networkadvertising.org/choices, and through the European Interactive Digital Advertising Alliance at youronlinechoices.eu. You can also limit data collection for advertising on your device, using "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android. Each partner above publishes its own privacy policy and opt-out tools, and you can find those on the partner’s website. Opting out does not stop you from seeing advertising; it makes the advertising you see less personalized.

3. How we use and share information

We use the information described above for the purposes set out in this policy and any service-specific notice we provide, including to:

Run, operate, and improve the Service, including delivering content tailored to your practice, and personalize the product experience through our AI Features, which are integral to providing the Service, based on your activity, preferences, and history with Glo, including how you found and first interacted with the Service (such as referral sources, campaign identifiers, onboarding flows, landing-page interactions, and pre-signup interactions);
Understand member behavior and engagement, including by analyzing general usage, engagement, transactional, referral, campaign, onboarding, and preference data, to operate, secure, and improve the Service and develop new products, features, and services, subject to applicable law and your choices;
Market and advertise the Service, including developing, refining, and activating advertising and marketing strategies (such as audience development, ad targeting, lifecycle marketing, measurement, and performance optimization); measuring, attributing, and personalizing advertising on Glo and on third-party platforms based on signals such as engagement patterns, content preferences, and lifecycle stage; and understanding and improving our marketing and growth performance, in each case subject to applicable law and your cookie, tracking, and marketing choices;
Engage service providers that perform core functions on our behalf, such as hosting, billing, payment processing, data storage, analytics, member support, security, and reporting (in certain markets, payments for website purchases are processed by Stripe as merchant of record, as described in Section 2, rather than by a service provider acting on our behalf);
Determine your approximate location to deliver location-aware features and content;
Verify your identity and authenticate access to your account;
Follow up on transactions and inquiries you start through the website, the apps, or by email;
Audit, research, and analyze to maintain, protect, and improve the Service; and
Keep our network running and detect, investigate, and prevent fraud, abuse, and security incidents.

How we use Wellness Information

We use Wellness Information to provide, personalize, secure, and improve the Service, give you feedback on your activity, support AI personalization within the Service, and develop, train, fine-tune, evaluate, and improve our AI Features and the models that power them, in each case as described in "AI personalization and automated features." Where the GDPR, UK GDPR, or a similar law applies, we process Wellness Information for these purposes only with your explicit consent.

We share Wellness Information with third parties where (i) you direct us to share it with a third-party wellness, motion, or fitness service, (ii) we have your consent, or (iii) we are otherwise permitted or required to do so by applicable law. Apart from disclosures you direct, we share Wellness Information only with service providers that process it on our behalf to operate, secure, personalize, and improve the Service, under written contracts that prohibit any other use. We do not sell Wellness Information, and we do not share it with advertising platforms, ad networks, or measurement partners, or use it to target advertising. Where the GDPR, UK GDPR, or analogous laws apply, we process Wellness Information only with your explicit consent under Article 9(2)(a); we do not rely on performance of contract or legitimate interests for Wellness Information.

Aggregate or de-identified information about feature usage (for example, how many members completed a class) is not treated as Wellness Information under this policy. Likewise, standard engagement and conversion events that do not reveal wellness topics (for example, the fact that a member signed up, started a subscription, or completed a class, without the class title, category, or other content details) are activity data rather than Wellness Information and may be shared as described in this policy.

Sharing with service providers and affiliates

We share information with our subsidiaries, affiliates, and other trusted third parties that process it on our behalf. Each is contractually required to use the information only for the purposes we authorize and to apply appropriate confidentiality and security safeguards. Where Stripe acts as the merchant of record for purchases in certain markets, Stripe processes your payment and transaction information as an independent business under its own privacy policy and terms, not solely on our behalf, as described in Section 2.

Other disclosures

We may disclose personal information, including Wellness Information, when:

required by law or where we have a good-faith belief that disclosure is necessary to comply with legal process, protect our rights or property, or address exigent circumstances involving public or member safety;
in connection with a merger, acquisition, financing, sale of assets, or other change-of-control transaction (including in bankruptcy), subject to confidentiality protections; or
with your consent.

Internal analysis versus external activation

We distinguish between (i) internal use of personal data, including for analytics, personalization, product improvement, and to inform our product, marketing, and advertising strategy, and (ii) external sharing with advertising platforms, ad networks, measurement partners, and similar third parties, which is subject to your cookie, tracking, advertising-identifier, and marketing preferences, including any consent, opt-out, or universal-opt-out signals required by applicable law (and, for users in the European Economic Area, the United Kingdom, Switzerland, and Quebec, the choices you make through our cookie banner). As part of external sharing, we may share pseudonymized identifiers (such as hashed email addresses or device or advertising identifiers), together with generic transactional and engagement conversion events (such as sign-up, trial start, purchase, or class completion), with advertising platforms to support audience creation, retargeting, lookalike or similar-audience modeling, suppression, attribution, and measurement, in each case subject to applicable law and your choices. External sharing under this paragraph never includes Wellness Information (see "How we use Wellness Information").

We may use aggregated, de-identified, or pseudonymized information about how members use the Service (for example, which content categories are most popular, how members typically progress through a program, or how different cohorts respond to onboarding flows or campaigns) to build, refine, and evaluate audience segments and our marketing and advertising strategy, including to understand which types of users, content, messages, and campaigns perform best, and to develop new products and features. We do not attempt to re-identify aggregated or de-identified data we use for these purposes.

AI personalization and automated features

Glo uses artificial intelligence and machine learning (together, "AI Features") to personalize the Service. Personalization through AI Features is a core function of the Service, not an optional add-on, and for personal data other than Wellness Information we provide it as part of performing your Service contract. This includes recommending classes, sequences, programs, and content; sequencing and adapting programs to your practice; explaining why a particular recommendation was made; and generating educational text or voice guidance.

AI Features draw on information you provide directly (such as profile data, goals, preferences, journal entries, voice notes, messages to instructors, ratings, feedback, and other inputs you submit through interactive features), information about how you use the Service (such as classes viewed, completed, or skipped, session duration, and inferred attributes like fitness level or program progress), information about your relationship with Glo (such as account, subscription, and transaction history), and information about how you found and first interacted with Glo (such as referral source, campaign identifiers, landing pages, onboarding flows, and pre-signup interactions). We refer to this collectively as "Member Inputs," consistent with the defined term in the Terms of Use.

Some Member Inputs may relate to health, mental wellbeing, sleep, menstrual cycle, pregnancy, or injury history. We treat this as sensitive information and process it only as needed to deliver the Service you have requested and, where applicable law requires it, with your explicit consent, as described in Section 8.

Glo uses personal data, including Wellness Information, to personalize the Service and recommend the most relevant classes and content for you, using Amazon Web Services (AWS) Personalize, which applies machine learning and AI models as well as rules-based models to provide recommendations, and the Service. For personal data other than Wellness Information, this use rests on the lawful bases described in this policy, including our legitimate interests. As a general practice, we use de-identified, aggregated, or pseudonymized data for model training and evaluation. Identifiable data, including identifiable Wellness Information, is used only in a limited, internal capacity for development, testing, debugging, quality assurance, and safety review of AI Features. We process Wellness Information to operate, personalize, and improve the Service and our features, on the lawful bases described in Section 3 and, where applicable law requires consent, only with your consent. It covers all health-related information you choose to provide at any point during your membership, including onboarding responses, journal entries, communications to instructors, program selections, and inferences we derive from any of these, and it allows us to use that information to personalize the Service and to develop, train, evaluate, and improve our models and AI Features. Consent you give once applies to all such information without further prompts. You can withdraw it at any time, with prospective effect only, through the choices described in "Your choices" or by emailing support@glo.com, without affecting the lawfulness of processing carried out before withdrawal.

We use third-party AI service providers (for example, Anthropic, OpenAI, AWS Bedrock, AWS Personalize) to help deliver these features and to support our engineering, analytics, customer-support, and product-development work. These providers process information on Glo's behalf under written confidentiality, security, and use-restriction obligations that prohibit them from using Glo user data to train their own models or for any purpose other than providing services to Glo.

AI Features use automated processing to generate recommendations and explanations. These outputs are wellness suggestions only. They are not decisions that produce legal or similarly significant effects, and you are never required to follow them.

Where applicable law provides rights regarding automated processing or personalization, including (depending on your jurisdiction) the right to object to or restrict automated processing, request human review of significant automated decisions, receive meaningful information about the logic involved, or opt out of profiling that produces legal or similarly significant effects, you may exercise those rights by emailing support@glo.com or as described in Section 10 (California) and Section 8 (international visitors).

Where applicable law requires it, members may submit deletion or opt-out requests by emailing support@glo.com or as described in Sections 8 and 10. Because AI personalization is integral to how the Service operates, disabling it where the law requires us to offer that option may materially reduce the functionality available to you.

We may share information that has been anonymized or aggregated so that it cannot reasonably be used to identify you.

Your consent to our information practices

We process your information on the lawful bases described in this policy. By creating an account or using the Service, you acknowledge the practices described in this policy and, where applicable law treats account creation or continued use as a form of consent, you consent to:

the use of cookies, pixels, SDKs, session-replay tools, analytics, and advertising and device identifiers, including those operated by the partners listed in Section 2;
the recording, storage, and analysis of your interactions with the Service (including pages viewed, audio and video played, search queries, in-app messages, and support communications) for the purposes described in this policy; and
receipt of electronic communications from us (email, push notifications, in-app messages, and SMS where you have provided your number), in accordance with applicable law.

We rely on this consent, together with the other lawful bases described here, to support our processing under federal and state communications and privacy laws. Consent is not the sole or default basis on which we process personal information; for most processing, we rely on performance of the Service contract or our legitimate interests, and we rely on consent only where applicable law requires it for a specific activity (such as non-essential cookies, marketing communications, processing of Wellness Information and other sensitive data, or training AI and machine-learning models on Wellness Information). This Section describes consent under United States federal and state communications and privacy laws; it does not establish consent where the GDPR, UK GDPR, or another law requiring a GDPR-standard consent governs, and where those laws apply we obtain consent as described elsewhere in this policy.

Where applicable law requires a more specific or separate consent (for example, opt-in consent under the GDPR, UK GDPR, or PECR, or under Quebec's Law 25, for non-essential cookies), we will obtain that consent through the cookie consent banner (shown where such consent is required) or another appropriate mechanism. The consent you give through that mechanism controls over this Section.

Nothing in this Section limits rights you have under applicable privacy or consumer-protection law that cannot be waived.

4. Your choices

Cookie consent and preferences

Where applicable law requires opt-in consent for non-essential cookies (including in the European Economic Area, the United Kingdom, Switzerland, and Quebec), we show a cookie consent banner on your first visit, and again after a defined period or a material change, where you can accept or decline categories of non-essential cookies and similar technologies, including analytics and advertising cookies. You can change your choices at any time using the "Cookie Preferences" link in the footer.

In the United States and other jurisdictions where opt-out rather than opt-in consent applies, we do not show the banner. You can manage non-essential cookies and tracking at any time through the "Cookie Preferences" link in the footer, your browser and device settings, and the Digital Advertising Alliance and Network Advertising Initiative opt-out tools described in "The third parties that work with us." If you are a US resident, you can also use the "Do Not Sell or Share My Personal Information" link in the footer, and we honor Global Privacy Control signals as a request to opt out of sale or sharing, as described in the California section.

Browser and device controls

Most browsers let you refuse all cookies, accept only specific cookies, or notify you when one is being set. If you disable cookies, some parts of the website may not work properly. You can also limit data collection for advertising through device-level controls, as noted above.

Marketing emails and texts

If you opt in to receive SMS or text messages from Glo, you consent to receive recurring promotional, transactional, and operational text messages, which may include information about Glo's products, pricing, features, instructors, new content, and partnerships, sent using an automated telephone dialing system at the mobile number you provide. The frequency of messages varies based on your interaction with us. After opting in, you may receive welcome and confirmation messages.

Message and data rates may apply, depending on your mobile carrier and plan. You are responsible for any such charges. You can opt out of SMS at any time by texting STOP to the number from which you received the message, and you can get help by texting HELP or contacting support@glo.com. We honor all opt-out requests.

To stop receiving promotional emails, follow the unsubscribe instructions in the message or contact us at support@glo.com. You will continue to receive transactional and account-related communications regardless of your marketing preferences.

Biometric sign-in

You can turn off biometric sign-in (Apple Face ID, Apple Touch ID, or Google biometric authentication) at any time through your device settings or the Glo app.

Wellness Information

To withdraw your consent to our collection of Wellness Information through Apple Health or Apple HealthKit, adjust your device settings or contact us. Where applicable law requires consent for other collection or use of Wellness Information, you can withdraw that consent at any time by contacting us. Withdrawal takes effect prospectively only: we will stop the consented collection and use going forward, and withdrawal does not affect the lawfulness of processing carried out before it. De-identified and aggregated data and Training Derivatives are unaffected by withdrawal or account deletion and may be retained and used as described in Sections 3 and 10.

Account information

You can access, update, or correct information in your Glo account through your account settings or by contacting us. You may also delete your account and the personal information associated with it directly in the Glo app, or by emailing support@glo.com, subject to exceptions permitted by applicable law. Members in the European Economic Area, the United Kingdom, Switzerland, and California have additional rights described in Sections 8 and 10. We provide reasonable access free of charge, except where doing so would require disproportionate effort.

5. Subscriptions, billing, and cancellation

Subscription terms, including pricing, billing frequency, automatic renewal, free-trial conversion, and how to cancel, are set out in Section 9 of the Terms of Use and Conditions. If you subscribed through our website, you can cancel online at any time through your account settings, without being required to call or speak with anyone. We will not charge you for a paid subscription without first obtaining your express affirmative consent and disclosing the renewal price, billing frequency, and how to cancel.

6. Data security

We use reasonable administrative, technical, and physical safeguards to protect personal information against unauthorized access, alteration, disclosure, or destruction. These include access controls and encryption in transit and at rest where appropriate. Access is limited to Glo personnel and contractors who need it to operate, support, or improve the Service, and who are bound by confidentiality obligations.

No method of transmission or electronic storage is completely secure, so while we work to protect your information, we cannot guarantee its absolute security.

7. Third-party websites and content beyond our control

Our website may contain links to, embed content from, or be embedded within, third-party websites and applications. We may also participate in co-branding and similar arrangements. We do not control these third parties, each of which has its own privacy practices. We are not responsible for those practices or the content of those sites. Please review their policies before sharing personal information.

8. International visitors

The disclosures in this section describe rights that may be available to you under your local data protection laws.

European Economic Area, United Kingdom, and Switzerland

If you visit our website or use the Service from the European Economic Area, the United Kingdom, or Switzerland, the following applies in addition to the rest of this policy.

We process personal information under one or more lawful bases identified by the GDPR and UK GDPR, including: performance of your Service contract under Article 6(1)(b), which covers delivering and personalizing the Service, including through the AI Features that are integral to how the Service works; for Wellness Information, your explicit consent under Article 9(2)(a), which is the only lawful basis on which we process Wellness Information; our legitimate interests under Article 6(1)(f) in operating, securing, improving, and developing the Service, including operating and improving our AI Features and models using personal data other than Wellness Information, balanced against your rights and freedoms; compliance with legal obligations under Article 6(1)(c); and consent under Article 6(1)(a) where we ask for it for a specific purpose.

The other lawful bases under the GDPR and UK GDPR on which we rely are:

Consent, for non-essential cookies and marketing communications, and explicit consent for processing of Wellness Information and other special-category data;
Performance of a contract, to deliver the Service you have requested, manage your account, and process transactions;
Legal obligations, to comply with applicable laws, regulatory requirements, and lawful requests; and
Legitimate interests, to secure and improve the Service, prevent fraud, and conduct internal analytics, where these interests are not overridden by your rights.

You can withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

Personal information we collect may be transferred to, and stored in, the United States and other jurisdictions whose data protection laws may differ from those in your country. Where required, we rely on appropriate safeguards for these transfers, such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Agreement or Addendum. You can contact us for more information about the safeguards we use for a specific transfer.

Where the GDPR, UK GDPR, or Swiss Federal Act on Data Protection applies, you have the right to:

access the personal information we hold about you;
request correction of inaccurate or incomplete information;
request deletion of your information ("right to be forgotten");
restrict or object to certain processing, including direct marketing and profiling;
receive your information in a portable format and have it transmitted to another controller where technically feasible; and
withdraw any consent you have given.

To exercise these rights, contact us using the details at the end of this policy. You also have the right to lodge a complaint with the data protection supervisory authority in your country of residence.

Quebec residents

If you are a Quebec resident, you have additional rights under Quebec’s Law 25, including:

The right to be informed when a decision affecting you is based exclusively on automated processing, and to receive information about the principal factors and parameters used in that processing;
The right to have the decision reviewed by a person;
The right to be informed of any technology that allows you to be located, identified, or profiled, and to deactivate that technology;
The right to data portability, including the right to receive your personal information in a structured, commonly used technological format and to have it transmitted to another organization where technically feasible; and
The right to know whether and how we use biometric information about you. Glo offers optional biometric sign-in using Apple Face ID, Apple Touch ID, or Google biometric authentication so you can sign in without typing your password. The biometric matching is performed by Apple or Google on your device. Glo does not collect, store, or have access to your biometric data, and we do not use biometric information for any other purpose.

To exercise these rights, contact us at support@glo.com. The person in charge of the protection of personal information is the Privacy Officer, Glo Digital Inc., who can be reached at the same address.

United States state privacy laws

Under applicable U.S. state laws, we process personal information for the business and commercial purposes disclosed in this policy, and we obtain opt-in consent for processing of sensitive personal information where those laws require it.

Consumer health data — Washington, Nevada, and Connecticut residents

If you are a Connecticut resident, we treat consumer health data as sensitive data under the Connecticut Data Privacy Act and process it only with your consent, as described in this policy. If you are a Washington or Nevada resident, Glo maintains a separate Consumer Health Data Privacy Policy, available through the link in the footer of our website, describing our practices with respect to consumer health data under the Washington My Health My Data Act and Nevada SB 370.

Australia, New Zealand, and other jurisdictions

If you live in Australia, New Zealand, or another jurisdiction with privacy laws that grant additional rights, you may have rights similar to those described above. Contact us at support@glo.com to exercise any rights available to you under applicable law.

9. Nevada privacy rights

Under Nevada law, Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them. To exercise this right, email support@glo.com.

10. Your California privacy rights

This section provides the additional disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), and applies to "personal information" as defined under the CCPA.

Members with disabilities may request this notice in an alternative format by emailing support@glo.com.

What we collect, disclose, sell, and share

Glo does not sell your personal information for money. We do work with advertising and analytics partners (such as social media platforms, search engines, and ad networks) to deliver and measure marketing of our Service, and that involves disclosing certain personal information to them.

Under the CCPA's broad definitions, some of these disclosures may qualify as "selling" or "sharing," even though no money changes hands and the data is used only to market the Service. You can opt out of these disclosures at any time through the "Do Not Sell or Share My Personal Information" link described below.

In the past 12 months, we have collected the categories of personal information described in the table below. The table identifies the sources of that information, the categories of third parties to which we disclose it for business purposes, and the categories to which we "sell" or "share" it under the CCPA's statutory definitions.

Categories of personal information	Collected (last 12 months)	Sources	Disclosed for business purposes to	“Sold” or “shared” under CCPA
Personal and online identifiers (name, email, phone, IP address, device IDs, cookie IDs, advertising IDs)	Yes	Members; affiliates; social networks; search engines	Service providers; affiliates; analytics providers; advertising platforms	Advertising platforms; analytics providers; affiliates
Financial information (payment card data, billing details)	Yes	Members; payment processors; Stripe (as merchant of record in certain markets)	Payment processors; service providers; affiliates; Stripe, an independent third party acting as merchant of record in certain markets	Not sold or shared
Protected classification characteristics (gender, age)	Yes	Members	Service providers; affiliates; analytics providers	Analytics providers; advertising platforms
Internet or network activity (browsing history, search history, page views, clicks, time on page, referring URLs, interactions with ads)	Yes	Members; cookies and similar technologies on the website	Service providers; analytics providers; advertising platforms	Advertising platforms; analytics providers
Wellness Information (only if voluntarily provided through Apple Health, Apple HealthKit, or wellness-related questionnaires)	Yes	Members (voluntarily provided)	Service providers performing health-related services	Not sold or shared
Geolocation information (approximate, derived from IP address)	Yes	Members; cookies	Service providers; analytics providers	Advertising platforms; analytics providers
Inferences (predicted preferences and characteristics for content and advertising personalization, excluding inferences derived from Wellness Information)	Yes	Derived from data above	Service providers; advertising platforms	Advertising platforms

For purposes of the CCPA, we collect the following categories of sensitive personal information: (i) account log-in credentials in combination with passwords or credentials that permit access to your account; and (ii) Wellness Information, including self-reported wellness inputs and data you sync from Apple Health or HealthKit.

We use sensitive personal information for the purposes described in this policy, including to deliver, secure, personalize, analyze, and improve the Service, in each case subject to applicable law and your choices. We do not sell or share Wellness Information, and we do not use it to target advertising, as described in Section 3. Inferences we derive from Wellness Information are treated as Wellness Information under this policy and are not sold, shared, or used to target advertising. California residents have the right to direct us to limit our use of sensitive personal information to certain permitted purposes, and may exercise that right as described below.

The categories of advertising and analytics partners we work with, with illustrative examples, are described in "The third parties that work with us" above. We do not knowingly sell or share the personal information of consumers under 16.

How long we keep your information

We retain personal information only for as long as we need it for the purposes described in this policy, and we set retention periods on a category-by-category basis. Following account deletion, we delete identifiable personal information except where we are required or permitted to retain it by law or for legitimate business purposes such as legal compliance, security, fraud prevention, dispute resolution, and legal, tax, or accounting recordkeeping. We may also retain and use de-identified and aggregated data that is not reasonably linkable to any individual (including Training Derivatives) to operate, secure, and improve the Service and to develop, train, evaluate, and improve our models, including after account deletion or withdrawal of a consent, to the extent permitted by applicable law. As a general matter:

Account and profile data is retained while your account is active and for a reasonable period afterward to support reactivation, dispute resolution, and our internal recordkeeping.
Wellness Information is retained while your account is active and is deleted or de-identified on a shorter timeline once it is no longer needed for the Service, subject to the exceptions described below.
Analytics, advertising, and similar technical data is retained for shorter, industry-standard periods that reflect its diminishing utility over time.
Billing and transaction records, and other data subject to legal, tax, accounting, or regulatory recordkeeping requirements, are retained for the periods those laws and obligations require.
Legal-hold and dispute data is retained for as long as needed to enforce our agreements, resolve disputes, defend against claims, or comply with legal process.
Training Derivatives (the de-identified data, model parameters, weights, embeddings, and other outputs that result when Member Inputs are de-identified for use in training AI and machine-learning models, as described in the Terms of Use) are designed not to be reasonably linkable to you, and Glo treats Training Derivatives as de-identified data to the extent permitted by applicable law. We do not attempt to re-identify Training Derivatives, and we contractually require anyone who receives them not to do so. We may retain and use Training Derivatives and de-identified datasets for as long as reasonably necessary to operate, secure, and improve the Service and to develop, train, evaluate, and improve our models, consistent with applicable law, including after you cancel your account, your account is terminated, or you withdraw a consent. Requests to delete identifiable Member Inputs do not require us to delete or alter Training Derivatives that have been de-identified as described above.

The specific factors we consider when setting and reviewing retention periods include:

The nature and sensitivity of the information;
The purposes for which we collected it, and whether those purposes are ongoing;
Whether you have an active account with us;
Our legal, tax, accounting, and recordkeeping obligations, which for billing and transaction records typically require retention for several years after the transaction;
Whether you have asked us to delete the information or withdrawn consent;
Whether the information is needed to enforce our agreements, resolve disputes, or defend against legal claims; and
Industry-standard retention periods for analytics, advertising, and similar technical data.

We may retain personal information for longer where required by law, where necessary to enforce our agreements, or where necessary to defend against legal claims.

Your California rights

Subject to certain exceptions, California residents have the right to:

Know the categories and specific pieces of personal information we collect, use, disclose, sell, and share about you, the sources of that information, our purposes for collecting or selling and sharing it, and the categories of third parties with which we have shared it;
Request that we delete personal information we have collected from you;
Request that we correct inaccurate personal information we maintain about you;
Opt out of the sale or sharing of your personal information, including for cross-context behavioral advertising;
Limit our use and disclosure of sensitive personal information to certain purposes; and
Not receive discriminatory treatment for exercising any of these rights.

How to exercise your rights

To exercise your right to know, delete, or correct, email support@glo.com with the subject line "California Privacy Request" and a description of what you are asking for. We will need to verify your identity before we process the request, and may ask for additional information for that purpose. You may designate an authorized agent to make a request on your behalf by emailing us a signed written authorization that includes the agent’s full name, phone number, and email address from your registered Glo email address.

Do Not Sell or Share My Personal Information

You have the right to opt out of the sale or sharing of your personal information, including for cross-context behavioral advertising. You can do this in any of these ways:

Click the "Do Not Sell or Share My Personal Information" link in the footer of our website to update your preferences;
Use the "Limit the Use of My Sensitive Personal Information" link in the footer of our website to limit the use of sensitive personal information;
Enable the Global Privacy Control signal in your browser. We treat valid Global Privacy Control signals as a request to opt out of the sale or sharing of personal information for the browser and device used to send the signal; or
Email support@glo.com with the subject line "Do Not Sell or Share."

Notice of financial incentive

We do not currently offer financial incentives in exchange for the collection, sale, or sharing of personal information. If we begin to do so, we will update this policy.

11. Enforcement and complaints

If you have questions or concerns, please contact us using the information at the end of this policy. We respond to formal written complaints and will cooperate with the appropriate regulatory authorities (including local data protection authorities) to resolve any complaint we cannot resolve with you directly.

12. Direct marketing

We may send you marketing communications for purposes disclosed to you and, where required by applicable law, with your consent. You can unsubscribe from direct marketing any time by following the unsubscribe instructions in the message or contacting us at support@glo.com. If you opt in to SMS messages, you can opt out any time by texting STOP to the number from which you received the message. Message and data rates may apply, and message frequency may vary.

You can opt out of push notifications through Glo apps any time by adjusting the settings on your device.

13. Members under 18

The Service is intended for adults. We do not direct the Service to, and we do not knowingly collect personal information from, anyone under 18. By creating an account or providing information through the Service, you represent that you are at least 18. If you are a parent or legal guardian and believe a person under 18 has created an account or provided personal information, contact us at support@glo.com. We will investigate and, if confirmed, terminate the account and delete the associated personal information. We may request information to verify a member's age, suspend access pending verification, and terminate any account we determine is held or used by a person under 18.

14. Changes to this policy

We may update this Policy from time to time. The "Last updated" date at the top shows when the current version became effective.

Non-material changes may take effect immediately upon posting.

For material changes, we will provide advance notice (for example, by email or in-product notice) and indicate the effective date. Where changes are materially adverse to you, we will provide at least 30 days' notice unless a shorter period is required by law or necessary for security, legal, or operational reasons.

Your continued use of the Service after the effective date constitutes acceptance of the updated Policy. If you do not agree to a change, you may stop using the Service before it takes effect.

15. Terms of Use and Conditions

The Terms of Use and Conditions is expressly incorporated into this policy by reference and is available on our website.

Contact

If you have any questions, comments, or concerns about this Privacy Policy, please contact us at:

Glo Digital Inc.
Attn: Legal
21750 Hardy Oak Blvd Ste 104 PMB 67075
San Antonio, Texas 78258-4946
Email: support@glo.com

For visitors from the European Economic Area, the United Kingdom, and Switzerland, you can reach our privacy team at support@glo.com.