Privacy Policy

Last updated: August 16, 2024

Welcome to GlowUp. This Privacy Policy applies to GlowUp services (the “App”), which include GlowUp apps, websites, software, and related services accessed via any platform or device that link to this Privacy Policy. The App is provided and controlled by GlowUp, with its registered address at The Meydan Hotel, Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E. (“GlowUp”, “we” or “us”).

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users, and other individuals in connection with our App. If you do not agree with this policy, you should not use the App.

What information we collect

We may collect the following information about you:

Information You Provide

• Your profile information: You give us information when you register on the App, including your username, password, date of birth (where applicable), email address, and/or telephone number, and information you disclose in your user profile.
• User content: We process the content you generate on the App, including photographs, audios, and videos you upload or create, comments, hashtags, feedback, and reviews, and the associated metadata, such as when, where, and by whom the content was created (“User Content”). This includes both the original content you upload and any generated content created by the App. Even if you are not a user, information about you may appear in User Content created or published by users on the App. We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content, to provide personalized recommendations. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect.
• Information in correspondence you send to us, including when you contact us for support or feedback.
• Information through surveys, research, promotion, contests, marketing campaigns, challenges, competitions, or events conducted or sponsored by us, in which you participate.

Automatically Collected Information

• Usage Information: We collect information regarding your use of the App, e.g., how you engage with the App, including how you interact with content we show to you, videos you watch, problems encountered, browsing and search history, the content you like, the content you save to ‘My Favorites’, the users you follow, and how you engage with mutual followers.
• Inferred Information: We also infer your attributes, including your interests, gender, and age range, for the purpose of personalizing content.
• Technical Information we collect about you: We collect certain information about the device you use to access the App, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types. Where you log in from multiple devices, we will be able to use your profile information to identify your activity across devices. We also collect face data through uploaded photos, and once using the camera, which is used to improve the images we create.
• Image Information: We may collect information about the images that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes. We may collect this information to enable special image effects, for content moderation, for demographic classification, for content recommendations, and for other non-personally-identifying operations.
• Tracking Technologies: We and our service providers and business partners use tracking technologies (e.g., mobile analytics, device identifiers, and other similar technologies) to automatically collect information, measure and analyze how you use the App, enhance your experience using the App, improve the App, and measure the effectiveness of advertisements and other content. These technologies enable the App to provide certain features and functionality. We may also use the information collected for advertisements through our partners.

Information From Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

• If you choose to register or use the App using a third-party social network account details (e.g., Facebook, Twitter, Instagram, Google) or login service, you will provide us or allow your social network to provide us with your username, public profile, and other possible information related to such account. We will likewise share certain information with your social network such as your app ID, access token, and the referring URL. If you link your GlowUp account to another service, we may receive information about your use of that service.
• Advertisers, measurement, and other partners share information with us about you and the actions you have taken outside of the App, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses, and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the App with your GlowUp account.
• We may receive information about you from others, including where you are included or mentioned in User Content, direct messages, in a complaint, appeal, request, or feedback submitted to us, or if your contact information is provided to us. We may collect information about you from other publicly available sources.

How we use your information

As explained below, we use your information to improve, support, and administer the App, to allow you to use its functionalities, and to fulfill and enforce our Terms of Service. We may also use your information to, among other things, personalize content you see on the App, promote the App, and customize your ad experience. We generally use the information we collect in the following ways:

• To fulfill requests for products, services, App functionality, support, and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes, and to solicit your feedback.
• To personalize the content you see when you use the App. For example, we may provide you with services based on the country settings you have chosen or show you content that is similar to content that you have liked or interacted with.
• To send promotional materials, including by instant messaging or email, from us or on behalf of our affiliates and trusted third parties.
• To improve and develop our App and conduct product development.
• To measure and understand the effectiveness of the advertisements and other content we serve to you and others, and to deliver advertising, including targeted advertising, to you on the App.
• To support the social functions of the App, including to permit you and others to connect with each other (for example, through our Find Friends function) and to share whether you are active on the App (and other information which you choose to share) with your friends, to provide our messaging service if you choose to use this function, to suggest accounts to you and others, and for you and others to share, download, and otherwise interact with User Content posted through the App.
• To allow you to participate in interactive features of the App, such as enabling your content to be used in other users’ creations.
• To use User Content as part of our advertising and marketing campaigns to promote the App, to invite you to participate in an event, and to promote popular topics, hashtags, and campaigns on the App.
• To understand how you use the App, including across your devices.
• To infer additional information about you, such as your age range, gender, and interests.
• To help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the App.
• To ensure content is presented in the most effective manner for you and your device.
• To promote the safety and security of the App, including by scanning, analyzing, and reviewing User Content, messages, and associated metadata for violations of our Terms of Service, Community Guidelines, or other conditions and policies.
• To facilitate research conducted by independent researchers that meets certain criteria.
• To verify your identity or age.
• To communicate with you, including to notify you about changes in our services.
• To announce you as a winner of our contests or promotions if permitted by the promotion rule, and to send you any applicable prizes.
• To enforce our Terms of Service, Community Guidelines, and other conditions and policies.
• Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content.
• To train and improve our technology, such as our machine learning models and algorithms.
• To facilitate and fulfill sales, promotion, and purchases of goods and services and to provide user support.

How we share your information

All information we collect is never shared unless otherwise specified below:

• Business Partners: If you choose to register to use the App using your social network account details (e.g., Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your phone number, email address, username, and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token, and the referring URL. If you link your GlowUp account to another service, we may receive information about your use of that service. Where you opt to share content on social media platforms, the image, username, and accompanying text will be shared on that platform, or, in the case of sharing via instant messaging platforms such as WhatsApp, a link to the content will be shared.
• Service Providers: We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the App is a safe and enjoyable place, and service providers that assist us in marketing the App.
  • Payment processors and transaction fulfillment providers: If you choose to conduct transactions, we will share data with the relevant payment provider to facilitate this transaction. For these transactions, we share a transaction ID to enable us to identify you and credit your account with the correct value once you have made the payment.
  • Analytics providers: We use analytics providers to help us in the optimization and improvement of the App. Our third-party analytics providers also help us serve targeted advertisements.
• Advertisers, Advertising Networks, and Measurement Partners: We share information with advertisers and third-party measurement companies to show how many and which users of the App have viewed or clicked on an advertisement. This includes advertisements outside the App, such as on social media platforms.
• Independent Researchers: We share your information with independent researchers to facilitate research that meets certain criteria.
• For Legal Reasons: We will share your information with law enforcement agencies, public authorities, or other organizations if legally required to do so, or if such use is reasonably necessary to:
  • comply with legal obligation, process, or request;
  • enforce our Terms of Service and other agreements, policies, and standards, including the investigation of any potential violation thereof;
  • detect, prevent, or otherwise address security, fraud, or technical issues; or
  • protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).
• Sale, Merger, or Other Business Transactions: We may also disclose your information to third parties:
  • in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy, or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
  • if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

Where we store your information

Your information may be stored on servers located outside the country where you live. We maintain major servers around the world to bring you our services globally and continuously. This applies to all collected information stated in this document, unless otherwise specified.

Your rights and choices

You have rights and choices when it comes to your information. You may be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. You may submit a request to exercise your rights under applicable laws by contacting us at contact@glowup.com. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

The security of your information

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will use reasonable measures to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the App; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

How long we keep your information

We retain information for as long as necessary to provide the App and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the App, and enhancing its safety, security, and stability), and for the exercise or defense of legal claims.

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your profile information to provide you with the App, we keep this information for as long as you have an account. If you violate our Terms of Service, Community Guidelines, or other conditions or policies, we may remove your profile and User Content from public view immediately, but may keep other information about you to process the violation.

Information relating to children and teens

GlowUp is not directed at children under the age of 13. In certain cases, this age may be higher due to local regulatory requirements, please see your local supplemental terms for more information. If you believe that there is a user who is below this minimum age, please contact us at contact@glowup.com.

Privacy Policy update

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy or providing any other notice required by applicable law. Your continued access to or use of the App after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the App.

Contact

If you have questions, comments, complaints, or requests regarding this Privacy Policy, please contact us at: contact@glowup.com.

We will endeavor to deal with your request as soon as possible. This is without prejudice to your right to make a complaint with a relevant data protection authority, where applicable.