Last updated as of December 3, 2023
Gloat Ltd., its subsidiaries and affiliates, (“Gloat”, “we”, “our” or “us”) provide this Privacy Policy (our “Policy”) to inform how we collect, use and disclose of information, including personal information, we receive, as data controller, when you engage with our various activities described below.
When you engage with our various activities, we may collect personal information that, alone or in combination with other information, could be used to identify you as follows:
(i) “User” meaning you visit or otherwise interact with our website www.gloat.com (the “Website”), online advertisements, emails and content under our control (collectively, “User Activities”);
(ii) “Leads” meaning you contact us via our Website forms (e.g., ‘Talk to an expert’, ‘Learn how’, interaction with the chatbot) or via email; subscribe to our newsletters or our blog; register to our events and webinar; participate to a meeting; request to receive an article posted on LinkedIn or interact in any other way with our social media pages (like LinkedIn); you are the customer account administrator; and therefore you may become a prospective customer (or a representative) for us, which means you will receive our marketing and sales communications (e.g., marketing offers and updates, information about our services and products offerings, service updates, special offers, campaigns, additional promotional materials) (collectively, “Sales and Marketing Activities”);
(iii) “Community Members” meaning you register, visit, complete forms, or otherwise interact with our community portal available at https://www.gloat.community/ (“Gloat Community”), allowing you to ask questions, register for events, share success stories, and download community event content and/or change management content; (collectively, “Community Activities”);
(iv) “Business Contact” meaning you are the contact at our customers, service providers and other business partners; or
(v) “Physical Visitor” meaning you visit our offices and premises.
Please note that this Policy does not cover how Gloat processes personal information on behalf of our customers as a processor. If you are an employee of our customer that uses Gloat technology platform and services, a separate privacy policy applies to our Services and is provided to individuals using our Services as an end-users of our customer’s (including our customer’s employees and contract employees) for our customer’s purposes, prior to processing their personal information.
This Privacy Policy was written in English. If you are reading a translation and it conflicts with the English version, please note that the English version controls.
If you have questions or concerns regarding this Policy, please contact us at: privacy@gloat.com
1. PERSONAL INFORMATION COLLECTION
When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual.
General Provisions
No legal requirement. If you are a User, Leads, Community Member, Business Contact or Physical Visitor, we hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any personal information and the provision of it is solely based on your free will.
Personal information provided by third parties
In the course of using or interacting with activities described above, you may provide us with certain personal information relating to you, including without limitation information related to you through any interface or mechanism, third parties’ sites such as Facebook and LinkedIn, or any other means (“Personal Content”). The Personal Content we receive may include your first name, last name, email address, job title, company, country, company size.
Personal Content we receive from our third parties’ services providers, such as co-sponsors of events attended by us, business contact information data brokers, will be used according to this Policy.
Personal information that Leads, Community Member, Business Contacts and Physical Visitors provide us with
If you are Leads, Community Member, Business Contact or Physical Visitor, we process the following categories of personal information directly from you:
The provision of certain types of personal information may be necessary or optional, depending on your requests. Mandatory information will be marked as such at the moment of collection of your personal information. If you refuse to provide mandatory information, Gloat may not be able to process your request (e.g., your request to talk to an expert or to visit our offices and premises).
Personal information that we collect automatically from you
If you are User, Community Member or Leads, we may automatically collect the following personal information:
2. LINKS TO THIRD PARTY SITES
Our Website, Gloat Community and advertisements may contain links to third party websites and applications. However this Policy applies only to the Website and Gloat Community, online advertisement under our control or any other activities under our control as described above. We do not exercise control over providers of information, or over banners, other advertisements or links, if any, from within the Website, Gloat Community and advertisements. These other sources may place their own cookies or other files on your computer, collect data or solicit personal information from you, and they follow different rules regarding the use or disclosure of the information that you submit. We encourage you to read the privacy policies and other terms of the other sources before using their services.
3. HOW WE USE PERSONAL INFORMATION
Personal information is used for the following primary purposes:
If you a User, Community Member or Leads:
(i) to improve User Activities, Community Activities and Sales and Marketing Activities and your experience (e.g., to facilitate your navigation of the Website, Gloat Community or other User Activities, to personalize your experience on the Website, Gloat Community or other User Activities, to evaluate, analyze and improve User Activities, Community Activities and Sales and Marketing Activities, to create anonymous or aggregate personal information) - the EU/UK legal basis is Gloat’s legitimate interests to improve its User Activities and Community Activities and its user’s experience and to optimize its Sales and Marketing Activities;
(ii) to support and enhancing User Activities, Community Activities and Sales and Marketing Activities data security measures (e.g., monitor and analyze use of the Website, Gloat Community or online advertisement for the technical administration and troubleshooting of the Website, Gloat Community or online advertisement) - the EU/UK legal basis is Gloat’s legitimate interests to secure its User Activities, Community Activities and Sales and Marketing Activities and its user’s experience;
(iii) to create statistics on User Activities, Community Activities and Sales and Marketing Activities (e.g., how many times our ads are clicked, how long our ads are viewed, the length of time Users spend on our Website, the length of time Community Members spend on Gloat Community, number of marketing communications opened, etc. - the EU/UK legal basis is Gloat’s legitimate interest to know who is using and interacting with its activities and websites.
If you are Leads or Community Member:
(iv) to manage your request to communicate with us (e.g., to talk to an expert, to answer your questions, to contact you if necessary, to schedule a meeting) - the EU/UK legal basis is Gloat’s legitimate interest in handling the contact requests sent to it;
(v) to manage your demo request (e.g., to schedule a personalized demonstration with our staff; to potentially purchase our services) - the EU/UK legal basis is steps prior to entering into a contract;
(vi) to manage events (e.g., sign up for events, webinar, training, and attend such events, webinar and training) - the EU/UK legal basis is Gloat’s legitimate interests in handling its events;
(vii) to manage communications, including marketing communications (e.g., to send you articles posted on LinkedIn, marketing and promotional communications, newsletter, research and guides, monthly insights, webinar and events and general or personalized service-related messages and to unsubscribe from the list of people receiving communications if applicable) - the EU/UK legal basis is Gloat’s legitimate interests in suggesting personalized content and offers or your consent (if applicable);
If you are a Business Contact:
(viii) to manage our customer, service provider and other business partners relationship (e.g., to designate the customer and/or service provider’s representative with whom to discuss and deal; to invoice the purchase of our Services.) – the EU/UK legal basis is the performance of the contract concluded between Gloat and the customer or the service provider or other business partner;
If you are a Physical Visitor:
(ix) to manage our physical security measure (e.g., to maintain the security and safety within Gloat’s offices and premises, to support and enhancing the security of our offices and premises) - the EU/UK legal basis is Gloat’s legitimate interests to secure its offices and premises;
If you are a User, Leads, Community Member, Business Contact or Physical Visitor:
(xi) pre-litigation or litigation management (e.g., to take action against any identified security breach; to manage any dispute or litigation) – the EU/UK legal basis is Gloat’s legitimate interests in defending its rights and interests
(xii) compliance with legal and regulatory obligations (e.g., to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities, to process your requests to exercise your rights) – the EU/UK legal basis is Legal and regulatory obligations to which Gloat is subject.
4. PERSONAL INFORMATION SHARING AND DISCLOSURE
We may share your personal information with the following recipients:
(i) Within the Gloat Group Companies. To manage the activities described above.
(ii) Service Providers and Business Partners. We may engage selected third party companies and individuals to perform services complementary to our own (such as data hosting services, data analytics services, business contact data enrichment services/data brokers, user engagement services, e-mail distribution and monitoring marketing services, customer relationship management services providers and chatbot service providers ) (collectively, “Service Providers”). These Service Providers may have access to personal information, which may vary and shall be limited to the information necessary for the performance of the specific roles and purposes in facilitating and improving the purposes of our activities, and shall be subject to privacy and data protection obligations.
(iii) Governmental, Administrative or Judiciary Authorities and Lawyers and Other Advisors for compliance with laws and law enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas, search warrant or court order), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
(iv) Other Third Parties. In connection with a merger, acquisition, reorganization or sale of all or substantially all of our shares or assets, or in the event of our bankruptcy, we may transfer some or all of our assets, including among others any personal information, subject to our Policy as in effect immediately prior to such a transfer (except if we notify you otherwise).
5. PERSONAL INFORMATION WHEN APPLYING FOR A POSITION IN GLOAT
Personal Information Collection
Personal information that any User provide us with
If you wish to apply for a position through our online form available on our Website, you will be asked to submit the following categories of personal information:
The provision of certain types of personal information may be necessary or optional, depending on your requests. Mandatory information will be marked as such at the moment of collection of your personal information. If you refuse to provide mandatory information, Gloat may not be able to process your request (e.g., to review your application).
Personal information that Users employed by Gloat provide us with
If you wish to apply for a position through our online link "Employee at Gloat?" available on our Website and if you meet the condition to access it, you may be asked to submit the following personal information (in addition to the personal information above):
Purposes
We may use such personal information to process the application submitted (e.g., to review the application, to schedule an interview with the relevant individual if the application is successful) - the EU legal basis is steps prior to entering into a contract.
General Provisions
For further information, please contact us at privacy@gloat.com.
6. PERSONAL INFORMATION WHEN RECORDING BUSINESS CALLS AND MEETINGS
Personal Information Collection
We might record, track and analyze online meetings, with our sales representatives, customer success and other, which may include your voice, photo and/or video and other personal information, such as full name, email, phone number.
Purposes
We may use such personal information to improve sales internal processes, for analytics, service and business quality control and improvement, and record-keeping purposes. – the EU legal basis is Gloat’s legitimate interest to improve its sales processes and customer support.
General Provisions
Please note that separate information will be provided prior to any recording of the call or online meeting.
7. YOUR RIGHTS REGARDING PERSONAL INFORMATION
General Provisions
You may at any time sending a request to privacy@gloat.com. We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable laws).
When you ask us to exercise any of your rights under this Policy and the applicable laws, we may need to ask you to provide us with certain information to make sure that you are who you claim you are, to avoid disclosure to you of personal information which is related to others that you are not authorized to receive, and to ask you questions to understand better the nature and scope of information that you request.
Israeli Data Subjects Rights
If you are based in Israel, you are entitled to request us to:
(i) review your personal information that we process;
(ii) update, amendment, and delete your personal data which is incomplete or outdated.
EEA/UK Data Subjects Rights
If you are based in the European Economic Area/United Kingdom, you are entitled to request us to:
(i) access your personal information in order to obtain clear, transparent and understandable information on how we process your personal information and on your rights (as provided in this Policy), as well as a copy of your personal information;
(ii) rectify your personal information in case your personal information are obsolete, inaccurate or incomplete;
(iii) object the processing of your personal information when the processing is based on Gloat’s legitimate interest. Gloat will no longer process your personal information unless we demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims;
(iv) in certain circumstances under applicable laws, restrict the processing of some of your personal information during a limited period of time;
(v) withdraw your consent when it has been obtained and processing is based on consent;
(vi) in certain circumstances under applicable laws, request data portability, meaning that you can receive the personal information originally provided by you in a structured and commonly used format or that you can request the transfer of the personal information provided by you to another data controller;
(vii) in certain circumstances under applicable laws, delete your personal information (also known as the right to be forgotten);
(viii) not to be subject to any automated decision making and profiling;
(ix) lodge a complaint with your national data protection authority.
If you have a complaint about how we use your personal information, we would always prefer you to contact us first. However, you may also make a complaint to your local data protection authority in the EEA/UK country where we are based. If you are unsure which data protection authority to contact, please contact us at privacy@gloat.com.
Californian Residents Rights
If you are a Californian resident, you are entitled to request us to:
(i) access your personal information by requesting what personal information we collect about you within the preceding twelve (12) months, including the categories of personal information, the sources from and purposes for which we collect it, and the types of recipients we disclose it, and to request a copy of the specific pieces of personal information that we maintain about you;
(ii) subject to certain exceptions, delete your personal information;
(iii) correct inaccurate personal information;
(iv) opt-out of "sales" or "sharing" of your personal information to third parties;
(v) not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
Virginia, Colorado and Connecticut Residents Rights
If you are a Virginia or Colorado or Connecticut resident, you are entitled to request us to:
(i) access your personal information by requesting what personal information we collect about you;
(ii) obtain a copy of your personal information processed by us, in a portable and to the extent technically feasible, readily usable format that allows you to transit the personal information to another controller without hindrance, where the processing is carried out by automated means;
(iv) subject to certain exceptions, delete your personal information;
(v) correct inaccurate personal information;
(vi) opt-out of "sales" or "targeted advertising" of your personal information to third parties;
(vii) not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out.
8. SECURITY
We employ a variety of measures designed to protect your personal information from potential personal data breach, destruction, loss, modification, unauthorized access and disclosure. However, we do not promise or guarantee that any personal information or private communications will be absolutely protected from unauthorized disclosure or use.
We restrict (and require our Service Providers to restrict) access to personal information to personnel who need to know that personal information to facilitate the operation of the Website and the Gloat Community and the respective activities and services. For further information about our data security please visit https://gloat.com/security-and-compliance/
9. CROSS-BORDER INFORMATION TRANSFER
General Provisions
Your personal Information may be transferred outside of your state or country.
Personal information transfer outside of Israel
When we transfer personal information from Israel to a third country outside Israel, the transfer takes place on the basis of any of the following:
(i) a country declared as offering equivalent level of protection by the Israeli Privacy Protection Authority; or
(ii) another approved transfer mechanism under the Israeli regulations; or
(iii) your consent to transfer your personal information to other jurisdictions, understanding that in some countries the level of protection may be lower than the level under Israeli law.
Personal Information transfers outside of EEA/ the UK
When we transfer personal information from within the EEA/UK to a third country outside the EEA/UK, the transfer takes place on the basis of:
(i) an adequacy decision by the European Commission or the Information Commissioner’s Office, as applicable; or
(ii) in the absence of an adequacy decision other legally permitted safeguards such as standard contractual clauses (“SCCs”) or the UK Addendum, as applicable, for the transfer of personal information to third countries.
10. PERSONAL INFORMATION STORAGE
We store personal information for various reasons and periods of time, as required by applicable laws or for the performance by contracts we are bound to and/or to fulfill our legitimate interests; and/or as permitted by applicable laws.
Subject to your right in accordance with Section 7 above, and in accordance with our Data Retention Policy (which can be provided upon contacting privacy@gloat.com), the length of time we store your personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
11. ADDITIONNAL INFORMATION FOR CONSUMERS IN THE UNITED STATES
Categories of personal information collected
We collect the personal information detailed in Section 1 above. This information includes the following categories of personal information as defined under Californian law:
Categories of personal information disclosed for business purposes
We may disclose the categories of personal information described above for the business purposes outlined in Section 4 above. The recipients to whom we may disclose your personal information (and that may have received such personal information during the last 12-months) for business purposes include: hosting, data security services, fraud detection and prevention services, product analytics, session or activity recording services, remote access services, content transcription and analysis services, performance analytics, content and business contact information / data enrichment providers, insurers.
Categories of personal information shared with third parties
While Gloat does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits as defined by Cal. Civ. Code 1798.140(ad)(2). We have shared in the preceding twelve (12) months personal information as necessary for specific “business purposes,” as defined by Cal. Civ. Code 1798.140(e) and specified in the Section 4 above. You have a right to direct Gloat not to sell or share your personal information. Gloat does not sell or share the personal information of consumers who are under 16 years of age.
12. OUR POLICY TOWARD CHILDREN
Our activities are not meant to be used by persons under 18, as such, we do not knowingly collect personal information from minors aged 13 or younger. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at privacy@gloat.com.
13. CHANGES
We may change the terms of this Policy from time to time by posting an updated version on this page, and/or posting a notice on the Website, with a five (5) day advance notice. Your continued use or interaction of the activities described above following posting the update version or such notice, if applicable, shall constitute your consent to any changes made. If you do not agree to the new or different terms, you should not use or interact and are free to discontinue using such activities.
14. CONTACTING US
If you have any concerns or questions about this Policy, please contact us at privacy@gloat.com.
Copyright © 2023, Gloat Ltd. All rights reserved.
