Updated November 2020

Scope

PLEASE READ THIS PRIVACY STATEMENT AND NOTICE OF PRIVACY PRACTICES CAREFULLY. This Privacy Statement and Notice of Privacy Practices (“Privacy Policy”) sets forth the privacy practices of Torus Sphere, Inc. and/or its subsidiaries and affiliates (collectively “We” “Us” or the “Company”). The Privacy Policy governs your use of this website, your use of any affiliated third party websites that may contain a link to this Privacy Policy, or to any pages, facilities, services, or capabilities accessible on or by any top-level Torus Sphere, Inc., domains owned by us including but not limited to the following; or any subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (each, a “Site” and collectively the “Sites”). This Privacy Policy is intended to be an enterprise wide privacy policy applicable to all data collection by the Company.

This Privacy Policy shall apply strictly to information collected in the United States. This Privacy Policy describes how We treat your use of the Sites and when you use our products (“Products”) and services (“Services”) which we define below in the Description of Products and Services section of this Privacy Policy, including the collection, storage, transfer, sharing and handling of your personally identifiable information (“Personally Identifiable Information” or “PII”) and your non-personally identifiable information ( “Non Personally Identifiable Information” or “NPII”) when you utilize the Sites or obtain our Products or Services.

Changes or Updates to this Privacy Policy

We reserve the right to revise or update this Privacy Policy at any time, and you agree to be bound by those revisions or updates. We will notify you of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its “Last Modified” date on the Sites. Your use of the Sites thereafter constitutes your agreement to and acceptance of the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates. In the event we materially change the way in which we use your Personal Information, we will provide you with at least 30 day notice and ask you to affirmatively accept the changes to a new Privacy Policy. This Privacy Policy is incorporated as part of the Terms and Conditions that apply with respect to your use of the Sites. If you do not agree to the terms and conditions of this Privacy Policy, including having your information used in any of the ways described in this Privacy Policy do not provide us with your information. If you do not agree to any terms of the Privacy Policy, please do not use the Sites.

This Privacy Policy does not apply to information you may choose to provide to us that does not display or link to this Privacy Policy or that does not have this Privacy Policy prominently displayed at the point of the collection of your information. By providing us your information you acknowledge that you have read this Privacy Policy and consent to the privacy practices as described in this Privacy Policy. Your further affirm your consent by submitting content or materials to us through our Sites. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any person. The information you provide to us is also governed by the Terms of Service which you can review by clicking here:

Contact and Electronic Communications Opt Out

By providing your information on our Sites, you agree that we can communicate with you electronically regarding any security, privacy, or administrative issues relating to your use of the Sites or the Products or Services and generally for business purposes, i.e. notifications and important messages related to the use Products and Services. If, at any time after registering your information or electing to sign up for Products or Services, you change your mind about receiving information from us, send us a request specifying your new choice. Simply send your request to support@glew.io. If you have any specific questions about this Privacy Policy, please email us at support@glew.io.

Description of Products and Services

Torus Sphere, Inc. develops and provides a software-as-a-service enterprise management solution to a variety of industries. Our focus is on big data visualization and decision support. We provide Products and Services under a software-as-a-service model that support data integration, data exchange and data management for clients in multiple sectors of the economy including providing client support through the use of our software to enhance workflow operations, create dashboard visualization for our clients and to synthesize data from multiple disparate data sources and generates actionable insights for revenue opportunities.

Information We Collect From You

We collect two types of information from you when you visit our Sites or register to use our Products and Services: (1) “personally identifiable information” (as defined below) and (2) non-personally identifiable information (as defined below).

Personal Identifiable Information (“PII”)

Personally identifiable information includes, but is not limited to, your name, company name, address, email, phone number, financial, billing or payment information, position, or title. We use your PII mainly to provide you with the Products and Services, administer your inquires and complete your transactions.

Non-Personally Identifiable Information (“NPII”)

Non-Personally Identifiable Information can be technical information or it can be demographic information, such as your age, gender, or interests. NPII may also mean aggregated, non-identifiable or anonymized information. NPII does not identify you personally. If you do provide us with non-personally identifiable information, we may use it for the purposes described in this statement or where it is collected, or any other legal purpose.

Here are some examples of the ways in which we may collect and store your non-personally identifiable information through our services, and how we use such information:

Log Information

When you use our services or view content provided by Glew™, we automatically collect and store certain information in our server logs. This type of information includes details of how you used our service, IP address information described below, web pages which have been viewed by a visitor, data and time, domain type, device event information such as crashes, system activity, hardware, settings, browser type or version, browser language, the date and time of your request and referral URL.

Internet Protocol (IP) address

‍Your “IP address” is a number that lets computers attached to the Internet know where to send you data, such as the screens and pages of our services that you view. We use this information to deliver our screens and pages to you upon request, to tailor our services to the interests of you and our other visitors, and to measure traffic to and within our services.

Demographic Information

“Demographic information” may be your gender, age, zip code, and interests. We may collect such information about you through our services and use it to provide you with personalized services and to analyze trends to ensure that our services and the information on them is targeted to meet your needs. Please note that we also consider aggregated information, which is not personally identifiable, to be non-personally identifiable information.

Sharing and Disclosure of PII and NPII

Personally Identifiable Information. Primarily, we may share or disclose your PII in the following instances:

• To fulfill a service to you.

For example, if you email us a question, we may use your email address to process your request and respond to your question.

• To offer you products from our affiliates, strategic partners, agents, or from third-party marketers and other unaffiliated parties that we believe may be of interest to you, or to assist such parties for research, administrative, and/or business purposes.

These parties may contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes.

• To unaffiliated third-party service providers, agents, or independent contractors who help us maintain our services and us with other administrative services (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes, and other promotions).

The Company requires these service-related companies to comply with the principles set out in the Privacy Policy, and requires them to use such information only for the purposes for which it was provided to them.

• To complete your purchase.

If you choose to make a purchase of one of our Products or on or through our Services, we may ask you for your credit card number, billing address, and other information in connection with completing such purchase, and we may use such information to fulfill your purchase. We may also provide such information, or other PII provided by you, to unaffiliated third-parties to complete your purchase (for example, to process your credit card).

• To comply with law, or in the good faith belief that such action is necessary to conform to the requirements of law, or comply with legal process served on us, and to protect and defend our rights or property, including our rights and property and our services, or act in urgent circumstances to protect the personal safety of you and our other visitors.
• To third parties as part of a corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
• To track and analyze NPII, i.e. non-identifying, aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
• To protect against fraud and potential fraud.

We may verify the information you provide to obtain our Products and Services through third parties. In the course of such verification, we may receive additional PII about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address match the information you supplied to us, and that the card has not been reported as lost or stolen.

Non-personally identifiable information

‍We may share and disclose your NPII for the purposes described in this statement or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with PII.

Legal Disclosure. We may disclose information about you and your use of the Services if we believe that such disclosure is reasonably necessary to:

• Comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);
• Protect or defend our rights and/or property or the rights and property of others;
• Enforce our Terms of Use and/or this Privacy Policy;
• Respond to claims that the content(s) of a communication violates the rights of another.

Also, circumstances may arise where, for business reasons, we may decide to reorganize, or divest all or part of our business through sale, assignment, merger or acquisition, or we may acquire a new business. In these circumstances, PII may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business. In such an event, we shall provide notice of any material change to this Privacy Policy, or our Services, in the manner described in this Privacy Policy.

Access and Ability to Correct Your Information

You may modify, correct, change, or request us to delete or update PII that we have collected through the Sites by contacting us via postal mail, e-mail, or telephone, as provided in the Contact and Electronic Communication section of this Privacy Policy.

Cookies and Other Technology

We use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We receive and stores information about how you use our website when you visit the Sites. For example, we receive information that your browser or device sends to our servers whenever you visit the Sites. Your browser or device may tell us your internet protocol (IP) address used to connect your computer to the Internet, computer and connection information such as browser type, version, language and time zone setting, browser plug-in types, operating system, and type of device you are using. When you visit the Sites, your browser may also tell us information such as the actions you take on our Sites, the page that led you to our Sites and, if applicable, the search terms you typed into a search engine that led you to our Sites.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the Sites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Sites or all functionality of the Services.

Third-Party Links and Websites

Our Sites may contain links to third-party services. While we endeavor to work with third parties that share our respect for user privacy, we are not responsible for the websites or privacy practices of such third-parties. You are responsible for knowing when you are leaving our website to visit a third party website, and for reading and understanding the terms of use and privacy policy statements for each such third party.

Children Under 13

The Sites, Product and Services provided by the Company are not directed to persons under 13. We do not knowingly collect PII from children under 13. If you become aware that your child is accessing the Sites, or Services and providing PII without your consent, please contact us by using the information provided in the Contact and Electronic Communications section of this Privacy Policy. We will take steps to remove PII from the Company’s servers and terminate the account should the Company determine that a child under 13 has accessed the Sites or Services.

Social Media and Community Platforms

Any information, communications, or material of any type or nature that you submit to the Sites or through the Services (including, but not limited to any Sites contained on a social media platform or website such as Facebook, Instagram or Twitter) by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at Your own risk and without any expectation of privacy. We cannot control the actions of other users of any social media platform or website and the Company is therefore not responsible for any content or Submissions contained on such sites and platforms. By visiting any of the Sites that are contained on a social media platform or website, you are representing and warranting to us that you have reviewed the applicable Privacy Policy and terms of use of such platform or website and that you will abide by all such provisions contained therein. We may provide public areas on our services, such as forums and chat rooms, where you can post information about yourself and others. Please exercise discretion and use caution with respect to your information, especially in such public areas. We do not control who reads postings on our Sites, or how they may use or disclose such information. If you choose to voluntarily disclose information on public portions of our Sites, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION ABOUT YOURSELF OR OTHERS IN PUBLIC AREAS OF OUR SERVICES. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF SUCH INFORMATION.

Advertisers and Marketing

We may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements about our Products and Services. Such third parties may gather information about your visit to our services or other sites, monitor your access to or market products or services to you, monitor the ads you view, click-on, or interact with, when they were delivered, and the screens and pages that they are on. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by clicking here (unsubscribe button). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

To learn more about these practices, as well as your choices regarding the practices of these third-party advertising companies, you may wish to visit http://www.networkadvertising.org/optout_noNPIIi.asp and/or http://www.aboutads.info/choices/#completed. Both the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) websites provide information regarding their respective members practices and your choices regarding having your information used by these companies, including the opt out procedures. Opting out of one or more NAI or DAA members only means that those NAI or DAA members no longer will be allowed under their own rules to deliver advertisements to you based on your visits to this site and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI or DAA opt out may not, or may no longer, be effective. We are not responsible for effectiveness of or compliance with any third parties’ opt out options or programs.

We do not endorse these parties, their content, or any products and services they offer. You are responsible for knowing when you are leaving our website to visit a third-party website, and for reading and understanding the terms of use and privacy policy statements for each such third party. We are not responsible for, and will not be liable for, their conduct, actions, omissions, or information handling or dissemination practices.

How We Protect Your Information

No data transmissions over the Internet are completely secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us or others over the Internet. You transmit such information at your own risk. Once we receive your transmission, we make reasonable efforts to ensure the security of our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls or secure server software.

Contests, Promotions, and Giveaways

We may conduct giveaways, contests and other promotions on the services in which we may ask you for additional information. We use and treat this information in accordance with the terms of this Policy. Participation in such giveaways and contents is not necessary to use the services, and you may choose whether you wish to participate in any particular giveaway or contest, without affecting your general use of the site.

California Residents’ Rights

(As provided by California Civil Code Section 1798.83)

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy statement) a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.

As stated in our privacy policy statement, we do not share information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure — typically by opting-in to receive information from a third party. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt-in to such use when you provide personal information on our website. Please note that whenever you opt-in to receive future communications from a third party, your information will be subject to the third-party’s privacy policies and practices. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information. You should always review the privacy policies and practices of any party that collects your information to determine how that entity will handle your information. California customers may request further information about our compliance with this law by e-mailing support@glew.io.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.

California Do Not Track Notice

Some browsers have a “Do Not Track” feature that lets you tell websites and online services that you do not want to have your online activities tracked. Such browser features and industry standards are not uniform, so our Sites do not respond to those signals. Our Privacy Policy describes our policies on data collection and tracking.

International Transfer of Information

We may transfer information that we collect about you, including PII, to subsidiary and affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information about you, including PII, to a country and jurisdiction that does not have the same data protection laws as the European Union, and you consent to:

1. The transfer of information about you, including PII, to the U.S.; and
2. The use and disclosure of information about you, including PII, as described in this privacy policy statement.