Last updated: January 22, 2017
When you use Gluwa Services, we collect information sent to us through your computer, mobile phone, or other access device. This information may include your IP address, device information including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website. Gluwa does not intentionally collect information from or about any individual who is under 13 years old.
If you create an account or use Gluwa Services, we, or our affiliates vendors acting on our behalf may collect the following types of information:
If you seek permissions to raise Digital Currency buy and sell limits associated with your Gluwa Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services.
When you use Gluwa Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect information about your computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breach of your Gluwa Account, and to identify any malicious software or other activity that may harm Gluwa or its users.
Finally, we may collect additional information you may disclose to our customer support team.
When you access our website or content or use our application or Gluwa Services, we or companies we work with may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:
We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
We also use Local Shared Objects, commonly referred to as "Flash cookies," to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of Gluwa Services. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies.
We store and process your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, on our computers in the United States and elsewhere in the world where Gluwa facilities or our service providers are located, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Gluwa staff.
We store our customers' personal information securely throughout the life of the customer's Gluwa Account. Gluwa will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or Gluwa Services may not be available to you.
We will never sell or rent your personal information to third parties.
If you use your Gluwa Account to transfer Digital Currency in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to transfer Digital Currency to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
In connection with a Digital Currency transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a Gluwa customer, that Digital Currency transfers are enabled, and/or to notify you that you have received Digital Currency. If you request that we validate your status as a Gluwa customer with a third party, we will do so. You may also choose to send Digital Currency to or request Digital Currency from an email address. In such cases, your user name will be displayed in an email message notifying the user of the designated email address of your action. Please note that merchants you interact with may have their own privacy policies, and Gluwa is not responsible for their operations, including, but not limited to, their information practices.
If you authorize one or more third-party applications to access your Gluwa account, then information you have provided to Gluwa may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using Gluwa services.
We may share your personal information with:
Before Gluwa shares your information with any third party that is not acting as an agent to perform tasks on behalf of and under the instructions of Gluwa, Gluwa will enter into a written agreement requiring that the third party to provide at least the same level of privacy protection as required hereunder.
If you establish a Gluwa account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a Gluwa website) will be shared with the owner of the third party website or application and your information may be subject to their privacy policies.
In general, we will notify you of material changes to this policy by updating the last updated date at the top of this page, and we will provide you with explicit notice of material changes as required by law. We recommend that you visit this page frequently to check for changes.
If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page or by writing to us at Gluwa, Inc., 1390 Market Street, Suite 200, PMB 226, San Francisco, California, 94102, USA.