Glowgent - Self-care Enhanced by AI

Effective Date: [Date]
Last Updated: [Date]

1. Introduction and Scope

Glowgent Inc. ("Glowgent," "we," "us," or "our") is committed to protecting your privacy and ensuring transparency in how we handle your personal information. This Privacy Policy explains our data practices for all users of Glowgent's wellness services, whether you're using our consumer app directly or accessing it through a business program.

We follow applicable privacy regulations, including the EU's General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and U.S. health privacy laws like HIPAA where applicable. Our commitment is to give you control over your information while providing you with personalized wellness insights.

Important: By using Glowgent, you agree to the data practices described in this policy. We've written this in plain language so you can easily understand how your information is handled.

2. Key Definitions

"Users" or "you": Individuals who use Glowgent services, either directly or through a business program
"Business Users": Organizations that provide Glowgent to their employees or members
"Personal Data": Any information that identifies you or can be linked to you
"Sensitive Data": Health information, biometric data, and other specially protected categories of personal information
"Services": All Glowgent applications, websites, and related services
"Processing": Any operation performed on your data, including collection, storage, analysis, and sharing

3. Information We Collect

3.1 Information You Provide Directly

Account Information

Name, email address, password, and profile details
Age, gender, and basic demographic information
Organization affiliation (for business program users)

Wellness and Health Data

Sleep patterns, duration, and quality metrics
Physical activity data (steps, workouts, exercise routines)
Nutrition logs and hydration tracking
Weight, body measurements, and fitness goals
Mental health indicators (mood, stress levels, anxiety)
Wellness goals and preferences

Biometric and Image Data

Skin analysis photos (if you use our skin health features)
Voice recordings (if you use voice features)
Other biometric data you choose to share

Communications and Feedback

Messages you send to our support team
Survey responses and product feedback
AI chat interactions and queries

3.2 Information We Collect Automatically

Device and Technical Information

Device type, operating system, and browser information
IP address and general location (city/country level)
App usage patterns and feature interactions
Error logs and crash reports
Session duration and frequency of use

Analytics Data

How you navigate and use our services
Features you access most frequently
Performance metrics and response times

3.3 Information from Third Parties

Health App Integrations (with your permission)

Data from Apple Health, Google Fit, Fitbit, or similar services
Wearable device data you choose to sync

Business Program Data

Information provided by your employer or organization
Eligibility and enrollment status

4. How We Use Your Information

4.1 Core Service Delivery

We use your information to:

Provide personalized wellness insights and recommendations
Power our AI-driven health coaching features
Track your progress toward wellness goals
Customize content and features to your preferences
Maintain and improve our services

4.2 AI-Powered Features and Privacy Protection

Our AI assistant analyzes your data to provide personalized guidance. To protect your privacy, we employ our Adaptive Confidence-Driven Anonymization Engine (ACDAE), which:

Removes or pseudonymizes personal identifiers before AI processing
Uses unique tokens instead of your actual name or identifying information
Separates analysis data from identity data with strict access controls
Ensures AI processing occurs on de-identified data wherever possible

4.3 Service Improvement and Analytics

We analyze aggregated, anonymized data to:

Understand usage patterns and improve features
Develop new wellness insights and recommendations
Conduct research on wellness trends (with anonymized data only)
Ensure service stability and performance

4.4 Communications

We may contact you for:

Essential communications: Security alerts, service updates, policy changes
Service communications: Progress updates, wellness tips, feature announcements
Marketing communications: Newsletters, promotional offers (opt-in only)
Support communications: Responses to your inquiries and assistance requests

4.5 Legal and Safety Purposes

We may process your information to:

Comply with legal obligations and valid legal requests
Protect our rights, property, and safety
Prevent fraud, abuse, or violations of our terms
Enforce our agreements and policies

5. How We Share or Disclose Information

5.1 We DO NOT Sell Your Personal Information

Glowgent does not sell, rent, or trade your personal information to third parties for their marketing purposes or profit.

5.2 Service Providers and Partners

We share limited data with trusted service providers who help us operate Glowgent:

Cloud Infrastructure and Storage

Supabase: Secure database hosting with end-to-end encryption
Cloud storage providers: Encrypted backup and data storage
All providers operate under strict data processing agreements

AI Processing Partners

Google (Gemini AI) and OpenAI: AI model services for personalized recommendations
Data is pseudonymized before processing
Providers cannot use your data for their own purposes
Processing occurs under strict contractual protections

Communication Services

Email delivery services for essential and opted-in communications
Push notification services for app alerts
Customer support tools for assistance requests

Analytics and Performance

Crash reporting and performance monitoring
Usage analytics (with anonymized data only)
Security monitoring and fraud prevention

5.3 Business Program Sharing

For users in organizational programs:

Individual data privacy: Your personal wellness details remain private by default
Aggregate reporting: Organizations may receive anonymized group statistics
Explicit consent: Any individual data sharing requires your clear consent
Professional programs: Licensed healthcare providers may access data with your permission

5.4 Legal Disclosures

We may disclose information when required by law or to:

Respond to valid legal process (subpoenas, court orders)
Protect rights, property, or safety of users or the public
Investigate fraud, security incidents, or policy violations
Comply with regulatory requirements

5.5 Business Transfers

If Glowgent is acquired or merged, your information may be transferred as part of that transaction. You would be notified of any such change and your rights under this policy would continue to apply.

6. Data Security and Storage

6.1 Security Measures

We protect your information using industry-standard security practices:

Encryption

All data encrypted in transit (TLS/HTTPS)
Data encrypted at rest (AES-256 encryption)
Encrypted backups and database storage

Access Controls

Role-based access with principle of least privilege
Multi-factor authentication for all team members
Regular access reviews and monitoring
Audit logs for all data access

Infrastructure Security

Secure cloud hosting with certified providers
Regular security audits and penetration testing
Automated threat detection and monitoring
Incident response procedures

6.2 HIPAA-Aligned Practices

For health-related data, we implement HIPAA-grade safeguards:

Administrative, physical, and technical safeguards
Business associate agreements with relevant partners
Breach notification procedures
Regular risk assessments

6.3 Data Minimization and Pseudonymization

We limit data collection and processing by:

Collecting only necessary information
Using pseudonymization techniques where possible
Regular data purging of unnecessary information
Separating identifiable data from analysis datasets

7. International Data Transfers

Your data may be transferred to and processed in countries other than your own. When we transfer data internationally, we ensure adequate protection through:

Standard Contractual Clauses (SCCs) for EU data transfers
Adequacy decisions where available
Additional safeguards as required by applicable law
Data localization options for sensitive jurisdictions

We maintain the same level of protection regardless of where your data is processed.

8. Data Retention

8.1 Active Accounts

We retain your data while your account is active to provide continuous service and maintain your wellness history.

8.2 Account Deletion

When you delete your account:

Active data is deleted within 30 days
Backups are purged within 90 days
Some data may be retained for legal compliance (with notice to you)

8.3 Inactive Accounts

Accounts inactive for 2+ years may be flagged for deletion
We'll notify you before any action is taken
You can reactivate to prevent deletion

8.4 Specific Retention Periods

Wellness logs: Retained while account is active, deleted upon account closure
AI interactions: Retained for service improvement, anonymized after 1 year
Support communications: Retained for 3 years for quality assurance
Security logs: Retained for 1 year for security purposes
Aggregated analytics: Retained indefinitely (anonymized data only)

9. Your Rights and Choices

9.1 Universal Rights

Regardless of your location, you have the right to:

Access: Request a copy of your personal data
Correction: Update incorrect or incomplete information
Deletion: Request removal of your personal data
Portability: Receive your data in a portable format
Restriction: Limit how we process your data
Objection: Object to certain types of processing

9.2 How to Exercise Your Rights

In-app controls: Use privacy settings within the app
Account settings: Manage preferences and data directly
Contact us: Email hello@glowgent.com for assistance
Automated tools: Use self-service data export/deletion features

Response time: We respond to requests within 30 days (or as required by local law)
Identity verification: We may need to verify your identity for security
No charge: Rights requests are free (reasonable limits apply)

9.3 Communication Preferences

You can control:

Marketing emails: Unsubscribe links in every email
Push notifications: Manage in app settings
AI interactions: Clear chat history or limit AI features
Data sharing: Opt out of research or analytics participation

9.4 Special Choices for Sensitive Data

Health data: Choose what health metrics to track
Biometric data: Control image and voice data collection
AI processing: Opt out of AI analysis while keeping other features
Third-party sharing: Control integrations with other health apps

10. Children's Privacy

Glowgent is not intended for children under 13 (or under 16 in the EU). We do not knowingly collect personal information from children under these ages. If we discover we have collected information from a child under the applicable age:

We will delete the information immediately
We will not use the information for any purpose
We will implement additional safeguards to prevent future collection

Parents who believe their child has provided information to us should contact us immediately.

11. Compliance with Regional Privacy Laws

11.1 European Union (GDPR)

For EU/EEA users, we ensure:

Lawful basis for all processing activities
Data protection by design and default
Impact assessments for high-risk processing
Appointment of Data Protection Officer (when required)
Right to lodge complaints with supervisory authorities

11.2 United States

HIPAA Compliance: When applicable, we act as a business associate and comply with all HIPAA requirements
State Privacy Laws: We comply with CCPA, CPRA, and other state privacy laws
FTC Compliance: We follow FTC guidelines for health apps and data security

11.3 Other Jurisdictions

We monitor and comply with privacy laws in all jurisdictions where we operate, including:

Canada (PIPEDA)
Brazil (LGPD)
Australia (Privacy Act)
Other applicable regional laws

12. Changes to This Policy

We may update this Privacy Policy to reflect:

Changes in our services or business practices
New legal requirements or regulatory guidance
Improvements to our privacy practices

12.1 How We Notify You of Changes

Significant changes: Email notification and prominent app notice
Minor updates: Notice in app and on website
Continued use: Indicates acceptance of updated policy
Right to object: You may close your account if you disagree with changes

We encourage you to review this policy regularly to stay informed about our privacy practices.

13. Contact Us

13.1 Privacy Team

Email: hello@glowgent.com
Response time: Within 5 business days for most inquiries

13.2 General Support

Email: hello@glowgent.com
Response time: Within 24-48 hours

13.4 Data Protection Officer (EU Users)

For EU-specific privacy matters:
Email: hello@glowgent.com

13.5 Rights and Complaints

If you believe we haven't addressed your privacy concerns adequately:

Contact our Privacy Team first
EU users: File complaints with your local supervisory authority
US users: Contact relevant state attorney general or FTC
Other jurisdictions: Contact your local privacy authority

Privacy Policy

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