PRIVACY POLICY
GLUR [Digital Pals Technology and Consultancy LLC] (“GLUR”, “we”, “us”) cares about the privacy of your personal data. This document is to inform you about how we collect and protect any personal information you provide to us and how you can control what personal information we collect from you and what we do with it. It sets out how we intend to use your information, who we will share it with and what rights you have about use of your information.
As a data controller we process personal data of all people related to us including but not limited to the people provided with the goods and services.
This notice applies to all our activities under the above brand and however you provide personal information to us, whether you visit us online at any of our websites or visit our stores or contact us via social media or whether you telephone, email, write to or text us.
In this scope, this Privacy Policy (the “Policy”) describes how and for what purposes the personal data of the following persons is collected, processed and shared with third parties by GLUR:
- Natural person customers/service recipient and/or natural person prospective customers/ service recipient and contact persons of the corporate customers/service recipient and/or prospective customers/ service recipient;
- Natural person suppliers or the contact persons of the corporate suppliers which provides goods or services to GLUR;
- Website (“https://www.glur.co/”) users of GLUR;
- Any other individuals about whom GLUR obtains personal data.
Specifically, we use the following terms in this Privacy Policy:
Personal Data: All kinds of information and data related to an identified or identifiable natural person. (For example, your name, surname, date of birth, identity number, electronic mail address, phone number etc. shared with us are named and termed as Personal Data for the purposes hereof)
Data Subject: Any identified or identifiable natural person whose Personal Data are processed by the Controller.
Processing: Any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, limiting, erasure or destruction.
Data Controller: The natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing operation.
The Data Controller is GLUR [Digital Pals Technology and Consultancy LLC], registered in Wyoming, USA, with the registered address “30N North Gould Street, Sheridan, WY, 82801 USA”.
Personal Data Processed by The Data Controller
We collect, use, and share the data listed below, in connection with the our websites, mobile apps, and other services we provide to you ("Services").
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THE CATEGORY AND CONTENT OF THE COLLECTED PERSONAL DATA |
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Identity Data |
Name-surname, ID number, sex, place and date of birth, marital status, signature, passport number, nationality, title/position, postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address, your interests, preferences, feedback and competition and survey responses |
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Contact Data |
Residence or office address, e-mail address, home, office and mobile telephone number. your correspondence and communications with us |
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Financial Data |
Information on financial transactions, debt and credit balance, IBAN number, bank account number, tax number and tax office, invoice details, payment history, commercial and legal payment obligations, purchases and orders made by you. |
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Transaction Security Data |
Log registrations, website login and exit information. |
We do not collect or transfer your personal data other than the ones you share with us directly with your explicit consent.
The above-mentioned Personal Data are collected in physical or electronic platforms directly from sources depending on the manner in which they are shared with GLUR and processed and transferred within the scope of the purposes mentioned below. Automatic data processing systems are used.
We collect and process your personal data in order to;
- contact you for sharing the information on goods and services requested by you,
- realize the payment,
- verify your identity,
- manage any account(s) you hold with us;
- evaluate and resolve the complaints related to the goods and services (customer services)
- receive feedback for improvement of our services and products
- confirm the validity of your payment method (in collaboration with our partners listed below)
- send you e-mails related to your purchase
- contact you electronically about promotional offers, events, products and services which we think may interest you
- use or disclose your information where we have a legal right or duty (for example in relation to an investigation by a public authority or in a legal dispute)
If you are an EEA, Switzerland, UK or Turkish resident, aaccording to relevant act personal data of an individual can be processed if there are lawful basis. According to relevant law processing personal data lawful only if and to the extent that at least one of the following applies:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which the controller is subject;
- processing is necessary in order to protect the vital interests of the data subject or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
For the abovementioned purposes and in scope of the above, we process your personal data based on your explicit consent; or without your consent where the processing is necessary for the establishment or performance of our agreement with you, or when it is requested by the legal or government authorities in scope of a legal proceeding or to the extent our legitimate interests require, provided that it does not harm your fundamental rights and freedoms.
If you are not a resident of a Country not mentioned above, the laws of your country of residence shall apply. Your data will be processed and transferred on your explicit consent in any case.
Your personal data shared with GLUR is being kept and stored in GLUR’s local/foreign secure servers in strict compliance with the applicable laws and regulations, the provisions of the Law. GLUR takes the necessary technical and administrative security measures specified under the legislation to protect the security of your personal data.
Once the purposes for processing the data no longer exist (e.g. you delete your account) and/or upon expiration of the legal retention periods during which we are obliged to retain your personal data (e.g. for the legal purposes, security or financial recording purposes), your personal data will be deleted, destroyed or anonymized.
We may continue to retain your information or information about you even after you request deletion of your data if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legal rights and other interests.
We may share your personal data;
- with competent courts and other governmental bodies and public entities for the performance of our legal duties and obligations.
- in connection with your visit to our website to ensure your security and to fulfill GLUR’s obligations under the applicable legislation with the authorities and institutions.
- with third party service providers to provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities or potential violations of our Terms and Conditions or policies; provide technical and customer support; and/or to provide other support to you, us, and/or to the Service.
- with any subsidiaries, joint ventures, or other companies or products under our common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy.
If another company acquires our company, business, or assets, that company will possess the information collected by us and will assume the rights and obligations regarding your information and information about you as described in this Privacy Policy.
Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect information from you. We have no control over and cannot be responsible for these third-party websites or their content. Please be aware that this Privacy Policy does not apply to these third-party websites or their content, or to any collection of your information or information about you after you click on links to such third-party websites.
We transfer personal data;
- To our local/global business partners and services providers in order to receive services on information technologies or consultancy services requiring expertise (companies providing services on database, consultancy etc.) and/or to our business partners and service providers abroad,
- To administrative and legal authorities in order to fulfill our legal duties to provide information and documents and to use our legal rights,
- To our business partners in order to provide our services or our providers from which we receive products or services,
- To our business partners for educational and compliance purposes; to our lawyers, financial advisors, occupational safety specialists etc. in order to fulfill our legal duties; to our customers abroad in order to build connections, conclude, execute and fulfill agreements.
The list of our service providers and business partners and their privacy policies are as follows:
- Adjust https://www.adjust.com/terms/privacy-policy
- Google LLC (Firebase) https://policies.google.com/privacy
- Google LLC (Google Ads) https://policies.google.com/privacy
- Apple https://www.apple.com/privacy/
- Tiktok https://ads.tiktok.com/i18n/official/policy/privacy
- Instagram https://privacycenter.instagram.com/policy
- Shopify https://www.shopify.com/legal/privacy
If you are an EEA, Switzerland, UK, USA or Turkish resident, you have the following rights related to your personal data:
- learn whether any of your personal data is subject to processing;
- request information regarding the processing activities;
- learn the purposes for processing;
- know local and foreign third persons if, and to whom, personal data are transferred;
- request correction of personal data if processed incompletely or inaccurately;
- request deletion or destruction of personal data if the purposes for processing no longer exist;
- request notification of deletion or correction to third parties to whom personal data is transferred;
- object to negative consequences which arise as a result of processing of personal data by automatic means; and
- request indemnification if you suffer damage as a result of illegal processing of your personal data.
If you request to use your rights above, contact us info@glur.co.
Additionally, if you are a EEAropean resident, we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through our website), or otherwise to pursue our legitimate business interests listed above.
If you are not a resident of a country not mentioned above, the laws of your country of residence shall apply and GLUR will evaluate your requests accordingly.
We do not intentionally gather information from visitors who are under the age of 13. Our Terms and Conditions require all users to be at least 18 years old. Minors who are at least 13 years old but are under 18 years old may use a parent or guardian’s account, but only with the supervision of the account holder. If a child under 13 submits identifiable information to us and we learn that the identifiable information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any identifiable information from a child under 13, please contact us at info@glur.co
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@glur.co
This Privacy Policy may be updated periodically to reflect changes in our personal information practices. For significant changes, we will notify you by posting a prominent notice on our website indicating at the top of the Policy when it was most recently updated.
This version of our Privacy Policy was last updated on February 1st, 2024.