Privacy Policy

Gluru Limited

Privacy Policy

Ripl Data Solutions Limited (“we” /us” / “our”) is committed to protecting and respecting your privacy.  Accordingly, we have established the following Privacy Policy regarding the protection of personal information of users of our website www.gluru.co  (the “Website”) and our virtual assistant software services (“Services”) (the Website and Services together constitutes “Gluru”), including but not limited to in accordance with the UK Data Protection Act 1998 (the “Act”).

users”, “you” or “your” means customers or anyone else who uses or accesses Gluru.

This Privacy Policy together with our terms of use http://gluru.co/termsofservice and any other agreement between you and us and sets out the basis on which any Personal Data (as defined in the Act) we collect from you, or that you provide to us, will be processed by us.

For the purposes of the Act, we are the data controller and our data controller registration number is ZA081238. If you have any questions about this Privacy Policy, we can be reached by email at info@gluru.co .  Alternatively, you can contact us at:

Attn: Data Protection Officer

Gluru Limited

8 Warner Yard

London

EC1R 5EY

We reserve the right to amend or modify this Privacy Policy at any time and in response to changes in applicable law.  If we change our Privacy Policy we will post the changes on this page, and may place notices on other pages of our Website, so that you are aware of any amendments.

Information we may collect about you

We may collect and process the following data about you:

personal information that you provide by filling in forms on Gluru such as your name, mailing address, telephone number, email address, credit or debit card details and other information that can be used to identify you. This includes information you provide at the time of creating your account or at any subsequent point;

if you contact us, we may keep a record of that correspondence;

we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;

details of any videos, comments, posts, social media information or other  information you post or upload on Gluru;

device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information); and

details of your visits to Gluru, including but not limited to, the Internet protocol address used to connect your computer to the Internet, traffic data, location data, other communication data and the resources that you access.

location information such as GPS signals sent by a mobile device and we may also use various technologies to determine location such as sensor data from your device that may, for example, provide information on nearby WI-FI access points and cell towers.

unique application numbers and information about your installation, for example, the operating system type and application version number may be sent to us when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.

we may collect and store information locally on your device using mechanism such as browser web storage including HTML 5 and application data caches.

we use various technologies to collect and store information when you use Gluru, and this may include sending one or more cookies or anonymous identifiers to your device.

We will hold the above information for as long as is necessary in order to provide you with the service on Gluru, deal with any specific issues that you may raise or otherwise as is required by law or any relevant regulatory body.

Information we may collect about others

We may collect and process the following data about others that you provide us with, including (but not limited to) information that you provide by filling in forms on Gluru.  You represent and warrant to us that you have obtained the express consent from the individuals whose data you provide us with.

For the avoidance of any doubt, any reference in this Privacy Policy to your data shall include data about other individuals that you have provided us with.

IP Addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical information about our users’ browsing actions and patterns, and does not identify any individual.

Cookies

Gluru uses cookies to distinguish you from other users. This helps us provide you with a good experience when you use Gluru and also allows us to improve Gluru. Please note that it is possible to disable cookies being stored on your computer by changing your browser settings. However, Gluru may not perform properly or some features may not be available to you if you disable cookies.

For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policyhttp://gluru.co/termsofservice .

Where we store your personal information

The data we collect from you is stored in the European Union but may be transferred to and stored at a destination outside of the European Economic Area (“EEA”).  Any Personal Data you provide may be used by a group company, partner entities, and vendors and service agencies that we may engage to assist us.  However, we will not otherwise provide your Personal Data to a third party without obtaining your prior consent, except in case providing it to (a) successors in title to our business; or (b) a third party pursuant to laws or regulations; or (c) in order to enforce or apply the Website Terms of Use  (see link to the Terms of Use); or (d) to protect the rights, property or safety of others; or (e) as outlined in this Privacy Policy.

By submitting your Personal Data, you agree to this transfer, storing or processing.  We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.

The transfer, storage or processing of Personal Data outside the EEA does not diminish your rights and we will take all reasonable steps necessary to ensure that any information that is transferred, stored or processed outside the EEA will be treated securely, in accordance with this Privacy Policy and with the same level of protection required by the Act.  Please note that by visiting and using Gluru, and giving us your Personal Data, you consent to your Personal Data being collected, used, processed, disclosed and stored by us, only as described in the Terms of Use and this Privacy Policy.

Safeguarding personal data

Your passwords are stored on our servers in encrypted form. We do not disclose your account details, postal or email addresses to anyone except when legally required to do so.   We use a variety of technological, physical and organisational protections and procedures to help protect your Personal Data from unauthorised access, use, or disclosure, such as encryption, passwords and physical security measures.  Whilst we strive to protect your Personal Data, we cannot ensure or warrant that the Personal Data or private communications you transmit to us will always remain private.  The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Sensitive information between your browser and Gluru is transferred in encrypted form using Secure Socket Layer (“SSL”).  When transmitting sensitive information, you should always make sure that your browser can validate Gluru’s certificate.

It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the Internet is not completely secure.  Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to Gluru, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent any unauthorised access.

Safeguarding Personal Data

We are committed to protecting the security of your Personal Data.  We use a variety of technological, physical and organisational protections and procedures to help protect your Personal Data from unauthorised access, use, or disclosure, such as encryption, passwords and physical security measures.  Whilst we strive to protect your Personal Data, we cannot ensure or warrant that the Personal Data or private communications you transmit to us will always remain private.  The transmission of information via the internet is not completely secure.  Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Website and any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.  

How we use your information

We use information held about you (and information about others) in the following ways:

to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;

 to ensure that content from the Website is presented in the most effective manner for you and for your computer;

to conduct, monitor and analyse our business or Website operations.  We may use the information to monitor and improve our level of service, to improve the content of the Website, to respond to your requests and for our own internal purposes;

to prevent fraud and other prohibited or illegal activities;

to protect the rights and safety of our affiliated entities and third parties, as well as our own;

to notify you about changes to our service;

to ensure you receive information relevant to you;

to ensure the content on Gluru is presented in the most effective manner for you and your computer or mobile device; and

to notify you about changes to our service.

Our goal is to be clear about what information we collect about you so that you can make meaningful choice about how it is used.  For instance, you can review, edit and control certain types of information tied to your Personal or Business Account using Gluru settings.

Disclosure of your information

We may disclose your Personal Data to any of our partners and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your Personal Data to third parties and such disclosure may include for the following purposes:

when we entrust a certain sub-contractor and/or partner with the handling of Personal Data in which case we will carefully check and select such subcontractor and partner and will exercise necessary and appropriate supervision and/or review over such sub-contractor and/or partner in order to ensure the security control of the entrusted Personal Data;

in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;

if we are or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets;

if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or

we may share aggregated, non-personally identifiable information publicly with our partners such as publishers, advertisers or connected sites for purposes such as to show trends about the general use of our services.

Links to third party sites

The Website may from time to time provide links to other third party websites whose privacy policy practices may differ from those of ours.  The Privacy Policy described here does not apply to those sites.  If you submit Personal Data to those sites, your information is governed by their privacy policies and we do not accept any responsibility or liability in respect of third party sites.  Please ensure you check the legal and privacy policy sections of any third party sites you may access through the Website before submitting Personal Data to them.

How You Can Access Your Personal Data

The Act gives you the right to access information held about you.  Your right of access can be exercised in accordance with the Act.  Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

When any person who is the subject of our retained Personal Data requests us to disclose, correct, add, delete, discontinue using or erase such Personal Data, we will appropriately respond to such request in accordance with applicable laws and regulations.  We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

You have the right to ask us not to process your Personal Data by contacting us at info@gluru.co.

The Act gives you the right to access information held about you by submitting a request in accordance with the Act and is subject to a £10 administrative fee. All such requests should be sent to info@gluru.co.

Changes to this policy

Please note that this Privacy Policy may be revised at any time so users are encouraged to visit this page every time they visit the Website.  This Privacy Policy was last reviewed on 30 October 2014.

Contact

Any questions, comments, complaints and other enquiries regarding your Personal Data or our Privacy Policy and practices, please email us at info@gluru.co or write to us at the following address:

Attn: Data Protection Officer

Gluru Limited

8 Warner Yard

London

EC1R 5EY