GLX is committed to the highest standards of Corporate Governance and Social Responsibility.

Privacy Policy

Updated on February 1, 2017

Welcome to www.glx.com (the “Website”), operated by GLX, Inc. (“GLX”, “we”, “our”, or “us.”) The Website is a non-anonymous, password-only accessible website using real names and factual information provided by users. The Website contains proprietary content as well as content supplied from select market and news data vendors and user-provided information and content.

This Privacy Policy is intended to inform you about how your personally identifiable information (“PII”) and other information is collected by us in operating the Website. The Website may be accessible via a computer, laptop, mobile tablet, mobile phone, or via the glx.com App. “App” means any third-party app downloadable through Google play or the App Store or any other venue (including any updates/upgrades to that app). When the word “Website” is used herein, it encompasses the App.

This App facilitates the transmission of a list of installed apps on your device to a third party’s server. This information will be used to provide you with advertisements that are better suited to your interests. If you do not agree to the transmission of a list of your installed Apps to a third party, please do not install this App.

To assist you in reading our Privacy Policy, we have provided answers to the following frequently asked questions:

Who is the official Data Controller?

The Official Data Controller is GLX, who will ensure that the PII is processed pursuant to (i) the European Data Protection Legislation, namely the national provisions adopted pursuant to the Directive, applicable to GLX as the official Data Controller of the PII, (ii) the Federal Data Protection Act of 19 June 1992 (Switzerland), as applicable, and (ii) Directive 95/46/EC of the European Parliament and of the Council on the Protection of Individuals with Regard to the Processing of Personal Data and on the Free Movement of Such Data.

How does the Website work?

The Website offers visitors to the Website (“you” or “your”) the opportunity to browse the Website and use certain features on the Website. By using the Website, you consent to the collection and use of your information by GLX as described herein. GLX reserves the right to change how we handle the information we collect through the Website at any time. We will update this Privacy Policy to reflect any changes in our privacy collection and handling practices, and will indicate that changes to this Privacy Policy have been made by listing a new date under “Last Modified” at the end of this Agreement. Such changes will take effect immediately once posted to the Website.

Registration

In order for users to create an account on GLX, a user may be asked to provide his/her first and last name, email address, gender, and birth date, which are used to create a genuine member profile and for account validation. GLX may also ask for optional additional information to enhance users’ profiles and to better enable GLX to provide services to its users.

Invite a Member

If users use our “invite a member” services, GLX may collect from the user the invitees first and last name and email address. GLX will use this information to: (i) send the invitee the initial email; (ii) register the invitee if the invitation is accepted; and (iii) ensure that multiple invitations are not sent to the same email address. The information users provide for sending an invitation is used for no other purpose and will not be shared with anyone.

Why do we collect data?

  • Provide users with a member profile;
  • Provide users with website services, functionalities and content;
  • Personalize content and features for users;
  • Analyze use of the website to enable improvements;
  • Collect aggregate group metrics that summarize site activity and use;
  • Diagnose technical or service issues; and
  • Maintain site and database security.

Data Storage

GLX uses Amazon Web Services cloud based servers and hosting facilities to provide the necessary hardware, software, networking, storage, and related technology needed to provide the GLX online and digital delivery experience to users. Amazon employs industry standard and best practices to help protect against the loss, misuse, and alteration of users’ personal information that is under the control of GLX. More info can be found at: https://aws.amazon.com.

Passwords and Security

GLX takes reasonable steps, such as requiring a unique password, to verify user identity before granting users’ access to GLX. Users are responsible for maintaining the secrecy of user passwords and associated account information. In the event of any security breaches, GLX will immediately notify affected users via email and may notify data-protection authorities, as applicable. GLX may also implement additional security measures, such as a forced-reset of users’ passwords.

Information Sharing

GLX may share your PII with other entities who work on our behalf or with us. These entities may use your PII to help fulfill your requests in connection with the Website and to help us communicate with you about different resources offered as part of the Website. Also, our parent, subsidiary and affiliate companies, or entities to which any of our assets, products, sites or operations may be transferred, will be able to use your PII.

GLX does not rent, sell or share PII with other non-affiliated people or non-affiliated companies except when we have your express permission, however, we may also release your PII to third parties if we believe such release is necessary (i) to comply with the law (e.g., a legal process or a statutory authorization), (ii) to apply or enforce our user agreements, (iii) to protect our rights or property, (iv) as part of a corporate reorganization, consolidation, merger, or sale of substantially all of the assets of GLX, or (v) if we reasonably believe that a danger to any person requires disclosure of such PII.

What is the right of access, correction, deletion and opposition?

You have the right to access, correct or delete PII about you as well as the opportunity to object to the processing of the PII by GLX, which you may exercise at any time by submitting a request to us at: GLX, Inc., 340 Royal Poinciana Way, Suite 317-335, Palm Beach, Florida 33480 or at privacy@glx.com and using the heading EUROPEAN RIGHT OF ACCESS REQUEST.

Opting Out

You may opt out of features of the Website or cancel your access by logging into your user account and updating your preferences. If you would rather us not share your PII with any third party for marketing purposes, please either (1) do not submit PII to GLX through the Website or (2) indicate your desire for us not to share your PII with third parties for marketing purposes by submitting such a request in writing (an “Opt-Out Request”) to us at: GLX, Inc., 340 Royal Poinciana Way, Suite 317-335, Palm Beach, Florida 33480 or privacy@glx.com.

Please note that it may take time for us to comply with your Opt-Out Request and, in the interim, we may continue to use your PII as described in this Privacy Policy. In addition, please note that after receiving your Opt-Out Request, we may continue to maintain your name and other PII to help us ensure we can honor such requests to communicate to you about your account, and for other purposes not related to direct marketing. If we receive your Opt-Out Request after having shared your PII with a third party, GLX may not be able to control use of such PII by such third party (or any other party to whom such third party may have transferred your PII). In such an event you agree that GLX shall not be responsible or liable, directly or indirectly, for damages or loss caused or alleged to be caused in connection with the use of such PII by any such third party or resulting from any such transfer or disposition. If you are concerned about GLX sharing your PII with third parties or otherwise transferring or disposing your PII, you should not provide your PII to GLX.

Links to Other Websites

We may provide links to other websites or resources of possible interest to you. Because we have no control over unaffiliated websites to which we provide links, the collection and use of your PII and other information by such websites shall be subject to the policies and procedures of such websites and not this Privacy Policy.

User Generated Website Content

PII, confidential issues and information shared between users of the Website are not to be discussed with or revealed to any other person or organization without the prior permission of all involved parties.

What are our policies regarding children?

If you are a US citizen, you must be thirteen (13) years of age or older in order to use the Website. GLX does not knowingly collect PII from anyone under thirteen (13) years of age. Users should not invite anyone under thirteen (13) years of age.

If you are a European citizen or a citizen of any other nation, you must be sixteen (16) years of age or older in order to use the Website. GLX does not knowingly collect PII from anyone under sixteen (16) years of age. Users should not invite anyone under sixteen (16) years of age.

California Privacy Rights

California Civil Code Section 1798.83 allows users who are California residents to request information about the disclosure of their personal information to third parties for direct marketing purposes. To make such a request, please contact us by emailing privacy@glx.com or GLX, Inc., 340 Royal Poinciana Way, Suite 317-335, Palm Beach, Florida 33480 and using the heading CALIFORNIA PRIVACY DISCLOSURE REQUEST.

What other information does GLX collect?

We also may collect anonymous and aggregate information from you about your preferences in navigating the Website by using cookies, action tags and other methods. Cookies are small text files that identify your computer. We may use cookies to, among other things, monitor Website usage, customize Website features, identify your computer’s operating system and browser, and complete transactions. An action tag is a small, graphic image on a webpage that is designed to allow the website owner or a third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time that such webpage was viewed. Tags may be associated with cookie information. We may also use such non-PII for promotional purposes. If you do not want us to track such information about you, you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to their presence. You can also adjust the settings in your browser to refuse all cookies.

Do we have a mechanism to address complaints about the handling of information that we collect?

If you have questions or concerns about any of our information collection or handling practices, please contact us by e-mail at privacy@glx.com or write to us at: GLX, Inc., 340 Royal Poinciana Way, Suite 317-335, Palm Beach, Florida 33480.