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Privacy Policy for Glowby

Last Updated: October 8, 2025

1. Introduction

Welcome to Glowby ("we," "our," or "us"). This Privacy Policy explains how SIA Digital Publisher, based in Riga, Latvia, collects, uses, discloses, and safeguards your information when you use our mobile application Glowby (the "App").

Please read this Privacy Policy carefully. By using the App, you agree to the collection and use of information in accordance with this policy.

2. Company Information

3. Information We Collect

3.1 Personal Information

When you use Glowby, we may collect the following personal information:

• Account Information: Email address, name, profile information
• Authentication Data: Sign-in credentials, authentication tokens
• Contact Information: Email address for support communications
• User-Generated Content: Vision boards, goals, checkpoints, notes, and images you create

3.2 Device Information

We automatically collect certain information about your device:

• Device Identifiers: Device ID, advertising ID (IDFA/GAID)
• Device Type: Model, manufacturer, operating system version
• Device Settings: Language preference, timezone, region
• Network Information: IP address, carrier, connection type

3.3 Usage Data

We collect information about how you interact with the App:

• App Usage: Features used, screens viewed, time spent in app
• Interaction Data: Taps, scrolls, navigation patterns
• Performance Data: Crash reports, error logs, app performance metrics
• Session Data: Login times, session duration, frequency of use
• Notification Data: Notification preferences and interactions

3.4 Location Data

We may collect approximate location data based on your IP address and device settings for analytics purposes.

4. How We Use Your Information

We use the collected information for the following purposes:

4.1 Core App Functionality

• Provide and maintain the App's core features
• Create and manage your vision boards
• Sync your data across devices
• Send you reminders and notifications you've enabled
• Provide customer support

4.2 Marketing and Communications

• Send you promotional emails about new features and updates
• Conduct marketing campaigns and promotions
• Personalize your app experience
• Send you surveys and feedback requests

4.3 Analytics and Improvement

• Analyze app usage patterns and user behavior
• Improve app features and user experience
• Conduct A/B testing and experiments
• Generate usage statistics and reports

4.4 Advertising and Targeting

• Deliver personalized advertisements
• Measure ad campaign effectiveness
• Create custom and lookalike audiences
• Retarget users across different platforms

4.5 Legal and Security

• Comply with legal obligations
• Protect against fraud and abuse
• Enforce our Terms of Service
• Resolve disputes

5. Third-Party Services and Data Sharing

We share your information with the following third-party service providers:

5.1 Analytics Services

• Meta (Facebook) Pixel/SDK: For analytics, advertising, and user attribution
• TikTok Pixel/SDK: For analytics and advertising campaigns
• RevenueCat: For subscription management and revenue analytics
• Other Analytics Tools: For app performance monitoring and user behavior analysis

5.2 Advertising Networks

We share data with advertising partners including Meta and TikTok to:

• Display targeted advertisements
• Measure ad performance
• Create custom audiences
• Conduct retargeting campaigns

5.3 Service Providers

• Email Service Providers: For sending transactional and marketing emails
• Cloud Storage: For storing your data securely
• Authentication Services: For managing sign-in functionality
• Customer Support Tools: For handling support requests

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

5.5 Legal Requirements

We may disclose your information if required by law, legal process, or government request.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide you with the App services
• Comply with legal obligations
• Resolve disputes and enforce agreements
• Conduct analytics and marketing activities

Account data is retained until you request deletion. Usage and analytics data may be retained in aggregated form indefinitely.

7. Your Rights and Choices

Depending on your location, you may have the following rights:

7.1 Access and Correction

• Request access to your personal data
• Correct inaccurate information
• Update your account information

7.2 Deletion

• Request deletion of your account and data
• Contact us at ask@glowby.app to request deletion
• Note: Some data may be retained for legal compliance

7.3 Marketing Communications

• Opt-out of marketing emails via unsubscribe link
• Manage notification preferences in app settings
• Contact us to stop all marketing communications

7.4 Advertising

Opt-out of personalized advertising via device settings:

• iOS: Settings > Privacy > Tracking
• Disable "Allow Apps to Request to Track"
• Use "Limit Ad Tracking" (iOS) or "Opt out of Ads Personalization" (Android)

7.5 Data Portability (GDPR)

EU/EEA users can request a copy of their data in a portable format.

7.6 Right to Object (GDPR)

Object to processing based on legitimate interests, including marketing and profiling.

8. International Data Transfers

Your information may be transferred to and processed in countries other than Latvia, including the United States and other jurisdictions where our service providers operate. We ensure appropriate safeguards are in place for such transfers in compliance with GDPR and other applicable laws.

9. Children's Privacy

Glowby is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at ask@glowby.app.

10. Data Security

We implement appropriate technical and organizational measures to protect your information:

• Encryption of data in transit and at rest
• Secure authentication mechanisms
• Regular security audits and updates
• Access controls and monitoring

However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect usage data and improve your experience. This includes:

• Session cookies for app functionality
• Analytics cookies to understand usage patterns
• Advertising cookies for personalized ads
• Third-party SDKs that may use their own tracking technologies

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to deletion of personal information
• Right to non-discrimination for exercising your rights

We do not sell your personal information in the traditional sense, but sharing with advertising partners may constitute a "sale" under CCPA. You can opt-out via device tracking settings.

13. European Privacy Rights (GDPR)

If you are in the EU/EEA, you have the following rights:

• Right of access to your data
• Right to rectification
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

Legal Basis for Processing:

• Consent: For marketing and advertising
• Contract: To provide the App services
• Legitimate Interest: For analytics and app improvement
• Legal Obligation: For compliance with laws

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy in the App
• Updating the "Last Updated" date
• Sending you an email notification (for material changes)

Your continued use of the App after changes constitutes acceptance of the updated policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

16. Supervisory Authority

If you are in the EU/EEA and have concerns about our data practices, you have the right to lodge a complaint with your local data protection authority.

For Latvia:

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Effective Date: October 8, 2025

By using Glowby, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

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