Glowise | Privacy Policy (20260515)
Glowise-GLP-1 & Calorie Tracker | Privacy Policy
Effective as of 15 May 2026
Thank you for using our mobile application Glowise-GLP-1 & Calorie Tracker ("Glowise"), visiting our website at https://glowise.app/ and/or communicating with us via email or text or our social media accounts, if any (collectively, the “Services”).
For the purposes of data protection and privacy laws, Tiya Pte Ltd and Vocalbeats.AI Pte Ltd ("we" or "us") are joint controllers for the processing of your personal information. We are committed to protecting your privacy through our data practices described in this Privacy Policy.
This Privacy Policy describes:
• The ways we collect personal information about you and why we do so;
• How we or our Authorised Partners use your personal information;
• The choices you have about your personal information; and
• How we protect your personal information.
For the purposes of this Privacy Policy, the terms “personal information” and “personal data” are used synonymously. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Services (unless otherwise stated below or at the time of collection).
Residents of certain U.S. states have privacy rights detailed in our Privacy Notice to US Residents. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice to US Residents, the latter will control.
BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY. We reserve the right to change and may periodically update this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy on our website or within the Application. Where required, we endeavour to notify you of material changes to this Privacy Policy by posting a notice on Glowise or via in-app notificaiton. Your continued use of our Services following the posting of changes to the Privacy Policy or any notification to you shall mean you accept those changes. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
The designated joint controller representative is Vocalbeats.AI Pte Ltd, which is entitled to act on behalf of Tiya Pte Ltd and is responsible for processing and responding to data requests made by you or any government authority. If you have questions about how we collect, use, process or protect your personal information, or if you have any requests in respect of your personal information, our contact information is as follows:
￮ Name of Joint Controller Representative: Vocalbeats.AI Pte Ltd
￮ Address: 108 Robinson Road, #09-01, Singapore 068900
￮ Attn: Data Protection Officer
￮ Email: [email protected]
We will respond to your requests in accordance with applicable laws and may take additional steps to verify your identity before fulfilling your request. These steps may include verifying your account details. You may also designate an authorized agent to act on your behalf but we reserve the right to verify the agent's identity and authority, and may deny any requests in appropriate circumstances.
We endeavour to respond to all requests in a timely manner. For more complex requests, we may charge a fee for processing your request. We will inform you of such fees before proceeding with your request. If you have any unresolved concerns about your privacy rights or personal data protection that we could not address adequately, you may contact your local privacy and personal data protection authority for further assistance.
2. Collection of Personal Information
(I) Information you provide when you create, update your profile or use our Services
Category | Description |
User Data | You do not need to provide any personal identifiers (such as name or phone number) to start using Glowise. You may provide an alias or username. When you use Glowise, we will collect information such as your country, timezone, device language settings and subscription status in order to enable you to use the features. We collect some of this data from your device. For more information about how we collect and use this data, see ‘Your general (non-precise) location’ in the Usage Data category. When you send us feedback or request, we may collect your real name and email address etc as well as the contents of those feedback or requests. |
User Content | All username (pseudonym), information, text, audio/sounds or any other materials whatsoever, whether input, entered, uploaded, transmitted or used by you in conjunction with Glowise (collectively “Submitted Content”) are collected by us. Do note that your Submitted Content may include fitness and wellness data (see below). The Output generated using your Submitted Content are also collected by us. The Output will include recipes created based on your Submitted Content as well as a list of recipes that you choose to save for future reference within the app. We may process your Submitted Content and Output for purposes of enabling you to use the mobile app, monitoring for and preventing abusive or harmful use of our Services, conducting technical analysis to improve the quality of our Services (such as ASR accuracy) on a de-identified basis, or for analytics purposes. |
Fitness & Wellness Data | We collect and process Fitness and Wellness Data in order for you to better track your calorie intake and fully utilise the features of Glowise. They may include: • Height and weight • Health indicators such as BMI • Gender • Year of birth • Lifestyle • Fitness / wellness objectives and activities • Nutritional intake (including food items scanned via barcode) • Dietary preferences, habits and restrictions • Data relating to your physiological condition and wellness medication schedules (such as GLP-1 injection or oral intake logs) Some of these Fitness & Wellness Data that you provide to us may be considered sensitive data or classified under special category of data. When you voluntarily take steps to submit such data to us via the mobile app, you may be asked to provide your explicit consent before you can use the features of Glowise. By you choosing and taking steps to use our Services and providing information to us, you also consent to the (continued) collection, use and processing of your Fitness & Wellness Data and, unless otherwise stated in this Privacy Policy, we use this consent as one of the legal grounds for the processing of such data. You can withdraw your consent at any time, by not using the Glowise app (and its features) or sending us a request to delete your data or simply contacting us for assistance. You may refer to paragraph 6(C) below for more information. We do not process such data to render (and we do not render) any professional medical advice or process the data for any diagnostics purposes. |
Optional data you may choose to share with us | |
Category | Description |
Survey and User Research Data | When you respond to a survey or take part in user research, we collect and use the personal data you provide. |
Apple Health (HealthKit) Data | If you choose to connect Apple Health ("HealthKit") with Glowise, we will request your permission to read certain categories of health and fitness data from HealthKit. We will only access the specific data types that you explicitly authorize. These may include (depending on your selection): • Active energy burned • Dietary energy consumed • Height, weight, BMI • Steps, walking/running distance • Heart rate • Other nutrition or fitness metrics that you choose to share We only use HealthKit data for the following purposes: • To enable you to track your calorie intake, activity levels, and wellness progress within the app • To provide insights, analytics, or personalized recommendations based on your selected data • To improve the accuracy and functionality of Glowise features We do not use HealthKit data for marketing, advertising, or profiling, nor do we share it with third parties except as needed to provide core app functionality or comply with legal requirements. We also do not store or transfer HealthKit data to external services for unrelated purposes. You may withdraw your permission at any time in your Apple Health settings. Once access is revoked, Glowise will stop collecting HealthKit data immediately, and you may request deletion of previously collected data at any time. |
Voice Input and Transcriptions | If you choose to use the voice input feature to log your meals, we will request your permission to access your device’s microphone. This feature uses Automated Speech Recognition (ASR) technology to convert your voice into text in real-time. We collect and process the resulting text transcriptions (“ASR Transcriptions”) to automatically identify food items and meal categories for your logs. In order to monitor and improve the accuracy of our ASR technology, we may also collect and upload randomly selected, short and isolated snippets of your original voice audio to our servers for the sole purpose of analyzing discrepancies between the audio and the generated transcriptions. To protect your privacy, such audio snippets are processed in a strictly de-identified format. This means the audio data is automatically decoupled from your User ID, name, or any other personal identifiers at the point of collection before being used for technical analysis and AI training purposes. You may withdraw your permission at any time in your device settings. Once access is revoked, Glowise will stop processing voice inputs and collecting any audio snippets immediately. |
Refund Consumption Information | When you request a refund through the App Store, we may collect and submit consumption-related data to Apple (e.g., usage activity or access to premium features) to help Apple assess the legitimacy of the refund request. This data is collected only with your explicit consent, which you may withdraw at any time from the "About" page. |
(II) Information We Get When You Use Our Services
When you use our Services, we may automatically collect information about you and how you use our Services. We only use pseudonymized or anonymised data that have gone through a privacy-enhancement process to protect and improve the functionalities of the Services.
Category | Description |
Usage Data | These are personal information collected and processed when you’re accessing or using the Services. They include: • account settings • interactions with the Services and their features Your technical data. They include: • online identifiers such as IP addresses • information about the devices you use such as: ￮ device type and IDs ￮ network connection type (e.g. wifi, 4G, LTE, Bluetooth) ￮ provider ￮ Crash logs ￮ network and device performance ￮ language ￮ operating system ￮ Glowise application version
• Load and network balancing • Security services • Enabling you to use the app's features Camera and Sensor Data. When you use the barcode scanning feature to log nutritional information, we request access to your device’s camera. The camera is used solely to identify the barcode; we do not store or upload images from your photo library or camera roll. |
(III) Information We Collect from Third Parties
Categories of Third Parties | Description | Data Categories |
Payment and transaction fulfillment providers | When you pay subscription fees (where applicable) to access the features on Glowise. The Apple App store (where you downloaded Glowise) is responsible for handling any and all payments of In-App purchases. They will collect your payment information such as credit card details and other identification information such as name, billing address, email address. After you provide the requisite information and complete the transaction, a purchasing account will be created and maintained by Apple. Apple will use your personal information to process any purchases, to confirm your orders via email, to make future purchases more convenient for you and to handle, where applicable, refunds. We do not collect or process any personal information save that Apple will provide us with high-level records of non-sensitive transaction information and subscription data (such as order number, time of order, IDFA, user ID, subscription type etc) so that we can activate the paid features for your use or improve the performance of our Glowise app. | Pseudonymised Payment Transaction Information |
Technical Service Partners | We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g. country or region, city, state). This makes it possible for Glowise to provide the Glowise Service, content, and features. We also work with security service providers who help us protect user accounts. | User Data Usage Data |
Wellness & Nutrition Service Providers | We work with third-party service providers to offer features such as food nutrition lookups and barcode identification. When you use these features, certain data (such as a barcode ID or search term) may be sent to the provider to retrieve relevant information. | Product Identifiers (e.g., Barcode IDs) Search Queries |
Marketing partners | When you download Glowise through our marketing partners, they provide information about their channel. | Usage Data |
Law Enforcement Agencies | We may receive information from law enforcement about potential violations of our Terms of Use. | User Data User Content |
3. How Do We Use Your Information
DO NOT SELL. We do not sell your personal information. We also do not transfer, disclose or share your personal information with third parties, except where the information is necessarily transferred, disclosed and shared with our authorised third-party partners who must use and process your information solely to provide you with the Services on our behalf.
We use your personal information for the following purposes only when it is necessary to do so for valid reasons (such as with your consent, to comply the law, to provide you with the Services, to protect your rights and interest or to fulfil our legitimate business interests) and in accordance with applicable laws:
Purpose | Legal basis | Personal Information |
To allow you to use the Services and generally manage your account. | They are necessary to provide you the Services. | Account Information: Pseudonymised Device ID & Storage Capacity |
To deliver and facilitate the delivery of the Services and to allow you to use the Glowise features. | They are necessary to provide you the Services. | User Content |
To support wellness tracking, personalized insights, and activity-based features within Glowise. | They are necessary to provide you the Services. You have provided your consent by entering data manually or connecting third-party services such as Apple Health. | Fitness & Wellness Data, Apple Health (HealthKit) Data: weight, steps, calories, heart rate, sleep, and other metrics you choose to provide |
To allow you to subscribe to the paid Services. | They are necessary to provide the paid Services. | Pseudonymised Payment Transaction Information: |
To assist Apple in assessing refund requests by providing consumption information when you request a refund through the App Store. | You have provided your explicit consent. | Consumption information: usage activity, access to premium features |
To provide you certain additional optional features of the Glowise service. We will clearly ask for your consent. | Consent | Consent Data |
To better understand how Glowise users use and interact with the Services. | We have legitimate interests to develop and improve our products and features for our users. | Activity Information: |
We may synthesize user content and analyze de-identified audio snippets and ASR transcriptions to train & improve our AI services, including the accuracy of voice-to-text recognition and food identification. Specifically, we compare randomly selected audio snippets with their resulting transcriptions to identify and correct recognition errors. | We have legitimate interests to develop and improve our products and features for our users. Synthetic Data being artificially generated and not linked to personally identifiable information (PII), does not contain any identifiable or sensitive personal information. | Synthetic Data: De-identified Audio Snippets De-identified ASR Transcriptions |
To detect and prevent fraudulent activities, software and tools within the Services and/or employed by end users. | It is in our legitimate interests to ensure the security of the environment of our Services and safety of our users. | Fraud Detection Information: • Basic device information (eg:brand, model, device system version settings) • Device identification information (eg: IMEI, ICCID, IDFV, OAID, bluetooth, MAC) • Device network information • Installed application information |
To comply with our legal obligations, respond to legal requests, respond to requests from law enforcement authorities (such as police, prisons, courts) as well as exercise, establish or defend our legal rights. | Compliance with legal obligations | User Data Usage Data User Content Survey and User Research Data |
To take appropriate action in respect of intellectual property infringement claims or reports of inappropriate content or activity. | Legitimate interest to protect our legal rights | User Data Usage Data User Content |
To diagnose, troubleshoot and fix issues with the service | They are necessary to provide you the Services. | Crash Reporting Information: |
To provide you with customer and technical support when you have enquiries, provide feedback, when you need troubleshooting, to fix bugs and to assist with any issues you might experience using the Services. | With your consent to resolve your questions. | Customer Support Information: |
When Glowise users respond to a survey or take part in user research, we collect and use the personal information as described in the survey or user research. | You provide consent for processing personal information. | Survey and User Research |
To conduct business planning, reporting, and forecasting. | Legitimate Interest | Aggregated usage data |
To evaluate and develop new features or technologies. | Legitimate interest to improve our products, improve user experience and develop new products for our users. | Synthetic User Content |
4. Who Else Can Use Your Information
We may share your information with other entities in the following situations:
A) Our Related Entities: We might share your personal information with our related entities in the same corporate group to assist us in technical processing operations (such as data hosting, analytics or maintenance), finance, legal, HR or accounting assistance, enhancing security against spam, abuse, fraud, infringement or other wrongdoings, and improving the Services; for corporate audit, analysis, strategic planning, research and development, corporate transactions (for example merger and acquisition, sale of company assets, financing etc); or compliance with applicable law. Each entity within the group may only use your personal information in accordance with this Privacy Policy.
B) Our Authorised Partners: We work with third party vendors to provide the Glowise app ("Authorised Partners" or "Vendors"). We seek to update our list of Authorised Partners below as soon as practicable. These Authorised Partners process your information only at and according to our instructions. They perform tasks such as hosting, user support, analytics and fraud detection and prevention. For more information, please read the privacy policies of our Vendors.
Vendor | Purpose |
Server hosting, Data storage | |
Statistics and analytics | |
Risk Control | |
Statistics and analytics | |
Food database and nutrition information lookup | |
Refund request assessment |
C) AI Service Providers and Data Processing
To provide our core AI-powered nutrition and logging features, we partner with specialized AI providers. Your Submitted Content (such as food images, text, or voice transcriptions) is transmitted via encrypted APIs for real-time processing to provide insights and facilitate seamless meal logging.
Provider | Model/Feature & Purpose |
GPT-4 series & Multimodal models: Used for natural language analysis, nutrition insight generation, and food image recognition. | |
Gemini Pro Vision: Used for advanced food image recognition and structured nutrition data analysis. | |
ASR Model: Used for high-precision automatic speech-to-text (ASR) conversion to facilitate voice-entry meal logging. | |
SambaNova Cloud / Vision Models: Used for high-speed image recognition to enhance photo-processing efficiency. |
Regarding these AI partners, we further disclose:
• Explicit Consent: We only process and transmit your Submitted Content (including voice data for transcription) to these AI partners with your explicit consent, which is obtained when you activate or use the respective features (e.g., using the microphone for voice logging).
• Limited Purpose: Data is used solely for the automated processing required to generate meal logs, nutritional insights, and transcription outputs. Additionally, de-identified audio snippets may be used by us (and/or our ASR partners under strict confidentiality) for the specific purpose of quality control and ASR accuracy assessment.
• No Model Training: We have configured our API integrations to ensure that these AI partners do not retain or use your personal data or Submitted Content to train, improve, or refine their own base models.
• Data Security: All data is transmitted via secure, encrypted channels. While voice inputs for daily logging are processed in real-time, randomly selected and de-identified audio snippets may be temporarily stored on our secure servers solely for the ASR accuracy analysis described in Section 2 and 3 above.
• User Control: You may withdraw consent at any time by disabling microphone or camera access in your device settings.
D) Government Agencies: In order to combat fraud and illegal activity, we may process and disclose information to other organizations or provide information to government agencies in response to any lawful request. If required by any government authority or courts for any purposes such as the enforcement of any laws or to prevent their contravention, we may release your personal information as is legally required or permitted.
5. Data Storage and Cross Border Data Transfers
By default, your personal data is stored on secure cloud infrastructure located in the United States.
In order to provide you with the full range of Services efficiently, your personal information may be accessed by our authorized personnel globally and/or lawfully transferred at our instructions for limited access, use, or processing by our authorized personnel and related entities within the same corporate group around the world.
Because the data protection and privacy laws in the United States and other countries may differ from those of your home country, we ensure that adequate safeguards are in place to protect your personal information. These safeguards include relying on standard contractual clauses, robust data processing agreements, and other lawful mechanisms to ensure a level of protection consistent with this Privacy Policy.
By using our Services and providing information to us, you consent to the storage, transfer, and processing of your information in the United States and other jurisdictions outside your home country. We use this consent and the necessity of performing our contractual obligations to you as the legal grounds for such data transfers.
We will ask for your permission to access your camera or other device functions (where required) so that you may use the features of the app. For example, granting microphone access allows you to use the voice input feature and participate in our ASR quality improvement process. We will also ask for your permission to send you push notifications. You may opt-out at any time by changing the settings on your mobile device.
B) Access the personal information we hold about you
Upon your written request and successful verification of your identity, we will provide you with a copy of your personal information in an electronic format.
C) Personal information rights
You may, at any time, withdraw your consent for us to collect, use, disclose or transfer your personal information to third parties. You also have the right to rectify or delete your personal information, or limit the porcessing of your personal information. Upon receipt of your written request, we require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences regarding the same. In general, we shall seek to process your request within thirty (30) calendar days of receiving it. Depending on the nature and scope of your request, you may not be able to access some or all features on Glowise, and we may have to terminate the End-User License Agreement we have with you. We will notify you before completing the processing of your request. Should you decide to cancel your request, please inform us immediately.
Please note that:
a. If you choose not to provide us with all the personal information as required to (i) register a user account, (ii) use the Services, (iii) process your personal information requests or (iv) assist you on other feedback, queries or requests, we may (x) be unable to, or refuse to, process your personal information for any of the purposes stated herein, (y) be unable to (or continue to) perform our contractual obligations owed to you (if any), and/or (z) have to terminate the End User Licensing Agreement, without any liability on our part.
b. You may withdraw your consent to using or disclosing your personal information at any time by adjusting the relevant settings on the App or by contacting us, but withdrawing does not affect the lawfulness of the processing before the withdrawal nor our rights to collect such information where (i) such use or disclosure is required by law, (ii) the personal data in question was collected from publicly available sources or (iii) such use or disclosure is necessary in an emergency where the life or health of a person is at risk.
c. You may, by providing us with a notice in writing, limit the processing of your personal information (including to request us to cease or not begin processing your personal information for purposes of direct marketing). If you limit the processing of your personal information, we may not be in a position to continue to administer any arrangement or contractual relationship in place, which in turn may result in: (i) us being unable to (or continue to) process your personal information for any of the purposes stipulated in this Privacy Policy; (ii) unable to (or continue to) perform our contractual obligations owed to you (if any); and/or (iii) the termination of any arrangements/agreements/contracts you have with us, without any liability on our part.
d. The short audio snippets collected for ASR accuracy analysis are processed in a strictly de-identified format and are retained only for the period necessary to complete the technical optimization. Once the accuracy analysis and relevant functionality improvements are finalized, these snippets are permanently deleted from our servers. Due to their de-identified nature, we may be unable to retrieve or delete specific snippets upon individual request during their brief retention period; however, no further collection will occur if you withdraw your consent or delete your account.
e. Even if you ask us to delete all or some of your personal information, we may still retain some of your data to the extent necessary to serve our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. Where required under applicable laws or if you reside in Japan, we will explain to you in greater detail about why we cannot delete your personal data when we receive such requests.
Under applicable laws, you may have the right to obtain a transferable version of your personal information to transfer to another provider.
To exercise your personal information rights, please contact us according to Section 1 "Contact Us" above. You will not be subject to discriminatory treatment for exercising your rights.
D) Cancelling your subscription plan (if any)
You may cancel your paid subscription plan (when it becomes available) any time. If you decide to cancel your paid subscription, you will enjoy the paid features as per the full billing cycle. If you decide to delete the Glowise app from your mobile device before the paid subscription expires, you may lose your subscription status, your personal information or other related information associated with the account. You will be informed and required to acknowledge the consequences of deleting your account. However, we may retain some information to the extent necessary to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.
E) Requests to Access or Delete Consumption Information
For personal data related to consumption information that we submit to Apple when you request a refund, please note that we do not control or store this data. If you wish to access or delete such information, you may submit your request directly to Apple at: https://privacy.apple.com.
You may delete your Glowise account at any time by logging to your account settings on the app. If you decide to delete your Glowise account, we will delete or deactivate your account and your personal wellness information (including your history of nutritional and medication logs) from our active databases. You may lose your personal information or other related information associated with the account. You will be informed and required to acknowledge the consequences of deleting your account. However, we may retain some information to the extent necessary to serve our legitimate business interests such as to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.
7. How Do We Protect Your Personal Information
In order to help ensure a secure environment for the Services and safe experience for our users, we are continuously developing and implementing reasonable administrative, technical and physical security measures to protect your personal information from unauthorized use or access and against loss, misuse or alteration. We utilize industry-standard security protocols, including encryption for data in transit and at rest, to safeguard your wellness and medication information.
While we try our best, we cannot warrant the security of any information transmitted to us through or in connection with the Services, that we store on our or our authorised partners' systems.
Any improper collection or misuse of personal information is a violation of this Privacy Policy and our Terms of Use and should be reported to [email protected]
B) Pseudonymisation, anonymisation and aggregation techniques
These privacy-enhancing techniques involve modifying or removing certain identifying information from your personal data and information to make it more difficult to link the data or information to you. We only use information that has gone through this privacy-enhancement process if we are using them to improve functionalities of the Services.
C) Personal information retention
Generally, we will store your personal information only for the time period necessary:
1. to fulfil the purposes for which such personal information was collected;
2. for as long as you have an active subscription or active account or as needed to provide you the Services; or
3. as required or permitted by applicable laws (such as tax, accounting, or other legal requirements).
Once we determine that the retention of your personal information is no longer necessary for the above purposes, or that retention is no longer necessary for any legal or business purpose, we will cease to retain your personal information, or anonymise the personal information so that it can no longer be used to identify any particular individual.
8. Protecting Children's Privacy
We take our responsibilities to the Glowise community very seriously. We also believe in protecting children's privacy online. The Glowise app is not meant for use by persons under the age of 18 years old. If you are under the age of 18, please do not use our Glowise app in any manner. If you are a minor, you may only access and use the Glowise app with the consent and under supervision of your parent or legal guardian. Please note that you must be of legal age according to the laws of your home country to make any In-App purchases on Glowise.
We do not knowingly collect personal information and data from anyone under the age of 18 and the Glowise app is not directed at anyone under the age of 18. Any person who provides their personal information to us through our Services explicitly represents that they are 18 years of age or older. If we become aware that someone under 18 years of age provided us with their personal information, we will close the account of that person and promptly delete their information or remove their information to the extent required by law, save when we are under a legal obligation to keep certain information.
If you are a parent or legal guardian of a minor, and wish to review any personal data that may have been unknowingly collected by us about your child or ward, or request that their Glowise account or personal information be deleted, you may contact us at [email protected]. We will respond to your requests after verifying the identities of the relevant users and their parents or legal guardians, and obtaining consent (if required under the laws) from the relevant users.
9. Cookies and Tracking Technologies
We use third-party services such as Google Firebase and AppsFlyer to help us understand how Glowise is used and to improve performance and user experience. These services may collect and analyze certain device and usage data, including mobile identifiers, app usage statistics, and crash reports.
These technologies may function similarly to cookies and may involve the collection of personally referable information under applicable laws. This data may be shared with or accessed by the respective service providers to perform analytics, attribution, or to optimize Glowise’s performance.
We will ask for your prior consent before enabling such tracking technologies, except where they are strictly necessary for the operation or security of Glowise. You may withdraw your consent any time by adjusting your device settings.
Residents of certain U.S. states have privacy rights detailed in our Privacy Notice to US Residents. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice to US Residents, the latter will control.
11. Notice to EU or UK Residents
Pursuant to the General Data Protection Regulation (GDPR) and the UK Data Protection Act, we now explain the valid legal bases we rely on in order to process your personal information.
a. Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
b. Performance of a contract. It is necessary for us to process your information in order to allow you to register a Glowise account and grant you a license to access, use or navigate our Services (or continue to do so at your choice).
c. Compliance with Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
d. Legitimate Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
12. Notice to Canadian Residents
We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
a. If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
b. For investigations and fraud detection and prevention.
c. For business transactions provided certain conditions are met.
d. If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
e. For identifying injured, ill, or deceased persons and communicating with next of kin.
f. If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
g. If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
h. If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
i. If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
j. If the collection is solely for journalistic, artistic, or literary purposes.
k. If the information is publicly available and is specified by the regulations.
13. Notice to Malaysian Residents
This section applies to you if you reside in Malaysia. In this section, the term “processing” shall have the same meaning as prescribed in the Malaysian Personal Data Protection Act 2010 (“MY PDPA”).
Personal Information of Minors – In respect of personal information relating to a minor (i.e. individuals under the age of 18), you confirm that you are the parent or legal guardian or person who has the parental responsibility for the said minor to consent on his/her behalf to the processing of his/her personal information in accordance with this Privacy Policy.
Obligatory Personal Information – It is obligatory that you supply us your details for fields marked as compulsory (where applicable) when you register an account or use our Services (collectively, “Compulsory Personal Information”). If you fail to supply us with any of the Compulsory Personal Information, we may refuse to, or may be unable to, process your personal information for any of the purposes specified in this Privacy Policy.
Language – In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail over the Bahasa Malaysia version.