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PRIVACY POLICY

Updated on March 17th, 2020.

Preamble

GLOSE (hereinafter referred to as "GLOSE") manages the GLOSE Website and mobile application.

This Privacy Policy sets out how GLOSE collects and uses the Personal data collected on the Website and the Application, in accordance with the regulations in force in France as set out in the Statute on Computer Technology and Freedoms dated 6 January 1978, known as the "Data Protection Act" and EU Regulation 2016/679 of 27 April 2016 on the protection of personal data (hereinafter the « GRPD").

The purpose of this Privacy Policy is to inform people browsing on the Website or the Application or using the Services that they offer:

• Of how GLOSE collects, uses and shares the Personal data GLOSE gathers in the course of providing these Services (I);

• Of the information, which may include Personal data, that GLOSE collects during your browsing, through the use of Cookies (II).

This Privacy Policy is available:

• In the footer of each page of the Website;

• Via a link under each data collecting form;

• In application downloading stores;

• On the Application’s Menu tab.

Any modification or update of this Privacy Policy will be duly brought to any User’s attention.

I.PROCESSING OF PERSONAL DATA COLLECTED DIRECTLY FROM THE USER IN THE CONTEXT OF PROVIDING SERVICES

1. Definitions

"Friends" refers to every Gloseur who follows you and whom you follow.

"Application" refers to the Glose Application, available on Apple's App Store and Google's Play Store download platforms.

"Terms of Use" refers to our Terms and conditions of use and sale, available here . These Terms of Use govern the use of the Platform Website and the subscription to our Services, and form the contract that binds us to you.

"Personal data" refers to any information relating to a natural person which is identified or identifiable, either directly or indirectly, by reference to an identification number or one or several factors specific to that natural person.

"Gloseur" or "User" refers to anyone registered on the Website and/or the Application.

"Group" refers to a community of Gloseurs gathering around an eBook, an author or any kind of subject.

"Platform" refers to the Application and the Glose Website.

"Profile" efers to the page of the Website/Application allowing every Gloseur to handle his own Personal data, his Friends, his Groups and his privacy settings.

"Services" refers to the Services providing by GLOSE through the Website and the Application as they are defined in the Terms of Use .

"Website" refers to the website accessible at www.glose.com ;

"Special Partner" refers to an independent publishing company who has entered into an agreement with GLOSE whereby the Special Partner’s customers are authorized to read the Special Partner’s eBooks on the Platform while benefitting from the Services. Currently, GLOSE’s Special Partners are :

• HarperCollins: - https://www.harpercollins.com/

• Harlequin: - https://www.harlequin.com/

2. Who is responsible of your Personal data?

2.1. If you registered directly on the Platform:

The data controller is GLOSE S.A.S with a capital of € 14 671.15, recorded in the Commercial and Corporate Register of Nanterre with the No. 798 135 489, whose headquarters are located at 85 rue Jouffroy d'Abbans, 75017 Paris, France, represented by its President, Mr. Nicolas PRINCEN.

Users may contact GLOSE’s Personal data referent M. Christophe SPY for all questions related to the processing of their Personal data and the exercise of their rights as described in article 9 below, at the following address: privacy@glose.com and entitling the email “my Personal data”.

2.2. If you clicked on the “Read on Glose” link from a Special Partner’s order confirmation email:

Our Special Partners allow you to read the eBooks you purchase on their website or apps on the Glose Platform. To do so, once you purchased the eBook, you simply need to click on the “Read on Glose” link provided in their confirmation email. Doing so will automatically register you on the Glose Platform.

In this case, GLOSE and this Special Partner are joint data controllers of your Personal data.

3. What Personal data do we collect?

3.1. Personal data collected

GLOSE believes in the possibility of giving you a taste for reading and improving yourself thanks to the data you provide to us and you generate during your use of our Services, which allow us to qualify your reading level, to determine your reading tastes and preferences, and to recommend books to read or Gloseurs to follow.

Thus, when providing its Services, GLOSE collects the following Personal data:

• Identification profile data: name, surname, email address, address, scholarship (formation, degree, jobs), username, login details, IP address, avatar picture, type and version of the browser used, operating system Friends and Gloseurs followed.

• Reading profile data: books read/opened/imported, reading tastes and preferences, reading time, contributions (annotations, quotes, critiques), reading Groups, history of the navigation on the Platform, date and time of visit, time spent on each page.

• Purchase and invoicing data: purchase history, bank details (only the last four digits of the credit card are kept, the rest is stored securely with our payment service provider “Stripe”), order forms.

You undertake to provide updated and valid Personal data and warrant that you will not make any false statement or provide any erroneous information.

3.2. Necessary and optional nature of the Personal data collected

3.2.1. Necessary data

During your subscription and the creation of your profile on our Platform you are required to provide the following information: email address, username, password.

When you purchase an eBook on our Platform, you are invited to give your bank details (name, surname, card number, expiry date, cryptogram).

You need to give us this Personal data insofar as they are strictly necessary for your registration and the use of our Services.

You’ll be notified of the necessity to provide these data upon collect. If you don’t provide them, you won’t be able to access or use the Services.

3.2.2. Optional data

Other Personal data collected are optional. You are therefore free to provide them or not. However, they allow us to personalize the Services we offer and to greatly improve your browsing experience on the Website and/or the Application.

So, the more specific you are, the better your GLOSE experience will be.

4. How are your Personal data collected?

4.1 Forms

GLOSE collects your Personal data when you fill in the following documents:

• The Platform registration form;

• The newsletter subscribing form;

• The eBook order form.

4.2 Facebook, Twitter and Google Connect

You may also access the Platform using your Facebook, Twitter or Google login. For detailed information on the policies of these entities with regard to Personal data, we recommend that you consult their privacy policies, accessible directly on their websites.

4.3 Profile

GLOSE collects the Personal data that you freely enter in your Profile. You may at any time edit your Profile to complete it, modify it, or delete your User account.

4.4 Use of Glose Services and activity on the Website

GLOSE collects Personal data that you generate when you use the GLOSE Services and features, including:

• Playlists you create;

• The eBooks that you read, liked, classified, highlighted, the pages you read, the words and sentences you highlighted, dictionary searches, time spent, date and time of reading;

• The notes and book reviews you create;

• Your contributions (annotations, quotes);

• Your conversations within the Glose social network or your Reading Groups.

4.5 Transfer of a Glose Education User account to the standard Glose Platform

GLOSE may collect Personal Data relating to a user of the Glose Education following such user’s request to have his account transferred onto the general Glose Platform (in the case of a User who graduates and is no longer registered in a school for example). In these circumstances, the Glose Education user may prefer a transfer of his account rather to the Platform than its definitive deletion in order to preserve his rights to his eBooks, contributions and other reading data.

4.6 Automatic registration on the Platform following a purchase on a Special Partner’s website

When you purchase an eBook on a Special Partner’s website (as defined in Article 1 of these Terms of Use ) this Special Partner will offer the possibility, in its order confirmation email, to read this eBook on the Glose Platform.

If you chose to read this eBook on the Platform, some of your Personal data will be automatically transferred from the Special Partner’s website to the Platform in order to create your User account on the Platform.

By clicking on the “Read on Glose” in the Special Partner’s confirmation email, you accept the creation of your User account on GLOSE and the transfer of the necessary Personal data to GLOSE.

4.7 Cookies

GLOSE may collect some of your Personal data thanks to Cookies, according to the conditions described in the II.

5. Privacy settings

By default, a User's Profile is public.

However, you may at any time choose what information you wish to share or not with other Users by setting all or part of your Profile in the following ways:

• Completely private: only your username is accessible to other Users and may appear in search results, but the content of your Profile is not visible to other Users;

• Semi-private: only your Friends can view the content of your Profile that is not accessible to other Users;

• Fully public: all Users can access it.

6. Why is your Personal data collected and on what legal basis?

Your Personal data is collected and processed for the purposes and under the legal grounds described below.

a. Managing your registration to the Platform and access to our Services

Thanks to the Personal data collected through the registration form, we are able to create your User account on the Platform, verify the validity and the authenticity of your identifiers, and allow you to access our Services as set out in our Terms of Use.

The collection of your Personal data is thereby necessary for the performance of the contract that binds us to you, namely our Terms of Use, which you must read and accept before subscribing to and accessing our Services.

b. Management of your eBook order

Your Personal data is collected and processed for the management of your eBooks purchase, according to our general Terms of Use.

The collect of your Personal data in this operation is necessary to the general Terms of Use you need to accept to subscribe to our Services.

Provided that you express your consent, we may store, via our payment service provider named Stripe, your credit card data in order to facilitate future purchases.

c. Customization of our Services

Your Personal data is collected and processed in order to improve you browsing experience on the Platform and customize our Services.

Collecting your Personal data in this context is necessary to perform the contract that binds us to you, namely the Terms of Use, that you need to accept in order to subscribe to our Services.

d. Data visualization

Data visualization allows you to view numerical data describing your reading habits and your performance as a Gloseur. This information is private and only accessible to you. However, you may decide to share some of this information on your reading feed or on third party social networks.

La Data visualisation vous permet de visualiser des données chiffrées décrivant vos habitudes de lecture et votre performance en tant que Gloseur. Ces informations sont privées et uniquement accessibles par vous. Cependant, vous pouvez décider d’en partager certaines sur votre fil de lecture ou sur des réseaux sociaux tiers.

The collection of your Personal data in this context is based on the execution of the contract that binds us to you, namely our Terms of Use, which you must accept in order to subscribe to our Services.

e. Commercial prospecting - Newsletter

You may register to our newsletter.

The collection of your Personal data in this context is based on your express and specific consent. In addition, you may withdraw your consent at any time, (i) by clicking on the unsubscribe link at the bottom of each email, or (ii) by sending an email to the following address: privacy@glose.com, or (iii) by setting up your Profile.

It is reminded that in order to be able to consent alone to the processing of his or her Personal data, the User must be over 15 years old.

f. Participation in specific operations

When you register on GLOSE upon recommendation of one of our partner publishers, we send to this partner some data related to the books from his catalogue you read or ordered on our Platform.

The transmission of your Personal data in this context is based on the legitimate interest of these partners, in accordance with article 47 of the GDPR.

g. Commercial prospecting - Offer of similar eBooks

When you have ordered or read an eBook on the Platform, GLOSE may send you, by email, offers for similar eBooks that we think may be of interest to you.

In this context, the use of your Personal data is based on the legitimate interest of GLOSE.

h. Sending of push notifications

When you download the Application, you will be asked if you wish to receive push notifications from us. These allow us to notify you in real time of any activity on the Platform that concerns you or that may be of interest to you.

The sending of these push notifications is based on your express consent.

i. Display on the Leaderboard

The Leaderboard is a scoreboard showing the full name, avatar and number of pages read by the five best readers of the Platform. The Leaderboard board is reset every week.

If you Profile is set on Fully Public mode, you may be featured on the Leaderboard. If you do not wish to be shown on the Leaderboard, please set your Profile on “Friends” mode.

7. Who has access to your Personal Data?

7.1. The GLOSE Team

Your Personal data collected by GLOSE are intended for GLOSE members duly authorized to process Personal data within GLOSE, namely, and depending on the nature of the processing and the category of Personal data involved, GLOSE’s representatives and employees in charge of marketing, customer services and IT services.

7.2. GLOSE’s subcontractors

In the course of carrying out its activities and providing the Services, GLOSE uses subcontractors who process Personal data on behalf of GLOSE.

In accordance with the GDPR, GLOSE requires his subcontractors to provide sufficient guarantees for setting up appropriate technical and organizational measures in order to ensure the security and confidentiality of your Personal Data.

GLOSE uses subcontractors located in countries offering an adequate level of protection either because they are subject to the provisions of the GDPR, or, in accordance with article 45 of the GDPR, because they benefit from an adequacy decision by the European Commission (i.e. they have been, like the EU-US Privacy Shield, recognized as providing sufficient guarantees by the European Union).

In cases where GLOSE uses sub-contractors located in countries offering levels of protection non equivalent to the level of Personal data protection in force in the European Union, GLOSE undertakes to regulate the data transfer by entering into standard contractual clauses established by the European Commission with these sub-contractors.

You can get more information about the subcontractors’ guaranties by sending an email to at privacy@glose.com.

7.3. The other GLOSEURS

GLOSE offers you the opportunity to share your Personal data with other GLOSEURS, by setting up your profile:

• Full private: only your name is accessible to the other Users and may appear in search results, but the rest of your Profile is not visible other Users.

• Semi-private: only your Friends can consult your Profile. It is not accessible to others.

• Fully public: every User can access to your profile. If you choose to set your Profile on the Fully public mode, you might be featured in our weekly “Glose 5 Best Readers Leaderboard”.

7.4. GLOSE’s partners

As stated in article 6. f) above, GLOSE can share with SIMON & SCHUSTER (a publishing company ) your Personal data (name, email address and book bought on GLOSE) when you register to GLOSE upon SIMON & SCHUSTER’s recommendation.

8. How long is your Personal data kept?

GLOSE stores your Personal data, in a form that enables your identification, in an active database for the time strictly necessary to achieve the purposes for which they are collected and processed, that is to say:

User Data: This data is kept for the duration of your User account and until it is deleted. A User account that has been inactive for two years will be deleted, after a notice has been sent to the User and has remained unanswered for one week.

Credit card data: Provided you have given your consent, this data is stored at our payment provider named Stripe.

Newsletter data: As regards your consent to receive our newsletter and your email address provided for this purpose, we keep them for 3 years from the date of your registration or the last contact from you (unless you unsubscribe, in which case your email address will be immediately deleted from this database).

Your Personal data may also be archived with supervised, limited and justified access, for the time necessary (i) to comply with GLOSE's legal and regulatory obligations (accounting, taxation: 10 years), and/or (ii) to enable GLOSE to assert a legal claim, before being deleted.

9. How does GLOSE ensure the security and confidentiality of your Personal data?

GLOSE undertakes to treat your Personal data:

• Lawfully,

• Loyally,

• Transparently,

• Proportionately,

• Securely,

• Relevantly,

• Within the strict framework of the aims pursued and announced,

• For the duration necessary for the agreed processing.

GLOSE implements and updates the appropriate technical and organizational measures to ensure the security and confidentiality of your Personal data by preventing them from being distorted, damaged or communicated to unauthorized third parties.

10. What are your rights on your Personal data?

It is possible for you, by simple written request sent to the following address: privacy@glose.com to access the Personal data stored by GLOSE, to request their correction or limitation, their deletion or portability, or to demand that they no longer appear in the GLOSE database.

Under your "Right of access", you are authorized, in accordance with article 15 of the GDPR, to query GLOSE in order to obtain confirmation whether or not your Personal Data is being processed, as well as the communication of information relating to the data processing (in particular its purposes, the categories of Personal data processed and the recipients to whom the Personal data is transferred, the duration of the data's retention or the criteria used to determine this duration, your rights over the Personal data and the right to lodge a complaint with a supervisory authority).

Under your "Right to rectification" as provided for in article 16 of the GDPR, you shall have the right to require GLOSE to rectify, complete or update your Personal data when it is inaccurate, incomplete, ambiguous or out of date.

Under your "Right to erasure" (or « Right to be forgotten"), you can request the deletion of your Personal data, in accordance with article 17 of the GDPR.

Also, you can ask for a "limited processing" according to the condition of article 18 of the GDPR, allowing the conservation of your Personal data only in order to:

• Verify the accuracy of the Personal data that is being challenged;

• Serve you in the context of the establishment, exercise or defense of your rights in legal proceedings, even though GLOSE no longer has any use for this purpose;

• Verify whether the legitimate reasons pursued by GLOSE prevail over yours should you object to processing based on GLOSE's legitimate interest;

• Satisfy your request to limit the use of your data - rather than have it deleted - in the event that the processing of your data is unlawful.

Under your "Right to data portability" and in accordance with the conditions set out in article 20 of the GDPR, you have the right to receive the Personal data that you shared with GLOSE in a structured, commonly used and machine-readable format, and to transmit such data to another data controller.

Under your "Right to object" provided for in article 21 of the GDPR, you have the right to object to the processing of your Personal data for marketing purposes, which includes profiling to the extent that it is related to such direct marketing.

To exercise your rights of access, rectification, erasure, restriction, portability and object mentioned aforementioned, you simply need to send your request:

• By email to the following address: privacy@glose.com;

• By letter to:
GLOSE
85 rue Jouffroy d'Abbans
75017 Paris
FRANCE

You can also unsubscribe to our Newsletter at any time (i) by clicking on the unsubscribing link in the email footer (ii) by sending an email to : privacy@glose.com, (iii) or by setting up your profile.

GLOSE will provide the User exercising such rights with information on the measures taken, as soon as possible and in any event within one (1) month as of receipt of the request. This period may be extended by two (2) further months where necessary, depending on the complexity and number of the requests received.

If GLOSE does not follow up on the request, it will inform the User, as soon as possible and at the latest within one (1) month from receipt of the User’s request, of the reasons for its inaction and the possibility of lodging a complaint with a supervisory authority and of lodging a judicial appeal.

The exercise of the aforementioned rights is free of charge. However, should a request be manifestly unfounded or excessive, in particular in view of its repetitive nature, GLOSE may either (i) charge a reasonable fee taking into account the administrative costs, or (ii) refuse to act on the request.

11. What happens in case of a Personal data breach?

In case of a Personal data breach, GLOSE shall notify the violation to the CNIL as soon as possible, and if possible seventy-two (72) hours at the latest after becoming aware of it, unless the breach in question is not likely to create a risk for the rights and freedoms of Users.

When the Personal data breach is likely to result in a high risk to the rights and freedoms of Users, GLOSE shall notify it to them, in clear and plain language, without undue delay, subject to the exceptions provided for in the article 34 of the GDPR.

Without prejudice to any other administrative or judicial remedy, the User who considers that the processing of his Personal data infringes the legislation in force shall have the right to lodge a complaint with a supervisory authority, such as the CNIL.

12. Special categories of Personal data

12.1. It is reminded that in order to be able to consent alone to the processing of his Personal data, the User must be over 15 years old.

Si l’Utilisateur a moins de 15 ans, les consentements conjoints de l’Utilisateur et du titulaire de l’autorité parentale à l’égard de l’Utilisateur sont expressément requis.

12.2. GLOSE is not intended to collect so-called sensitive information such as racial or ethnic origin, sexual orientation, medical condition, political opinions, religious or philosophical beliefs or trade union membership, or genetic or biometric data.

Consequently, Users shall refrain from sharing on the Platform any Sensitive Data concerning themselves or third parties. Any sharing by a User of Sensitive Data is done without the knowledge of GLOSE, which undertakes, as soon as it is informed, to delete the personal data or to make access to them impossible.

13. Who to ask your questions to?

For any question concerning the processing of their Personal data and the exercise of their rights, Users may contact our Personal Data Referent, Mr. Christophe SPY at the following email address: privacy@glose.com.

II/ PROCESSING OF PERSONAL DATA COLLECTED THROUGH COOKIES

1. What are the “Cookies”?

Cookies are small text files, often encrypted, generated by the Websites you visit, and processed and stored by the browser of your computer or of your mobile phone.

These Cookies allow the Websites you visit to access information such as connection data, browsing activity, parameters used (language and territory) and actions undertaken.

The aim of the Cookies is to improve your browsing experience on our Platform.

2. What are the Cookies used by GLOSE?

2.1. Analytical Cookies/audience measurement

These Cookies allow us to obtain information about the use of our Website and Application and to analyze traffic data. These traffic statistics allow us to detect navigation problems and thus optimize your navigation and reading experience.

GLOSE may use the following Analytical Cookies:

TYPE OF COOKIES	FUNCTION(S)	HOW TO REMOVE THEM
ANALYTICAL	Google Analytics: audience measurement tools, to understand the behavior of our Gloseurs across all our Services.	https://tools.google.com/dlpage/gaoptout
ANALYTICAL	Amplitude : Analysis of User sessions and the use of our product by our Users and accounting of visits.	https://amplitude.com/privacy

2.2. Tracking Cookies

Such Cookies allow us to follow and track your behavior and your browsing. In particular, they are deposited and read during navigation on the Website or the Application, but also when reading an email, installing or using software or a mobile application, regardless of the type of device used, such as a computer or a smartphone.

GLOSE may use the following Tracking Cookies:

TYPE OF COOKIES	FUNCTION(S)	HOW TO REMOVE THEM
TRACKING	Social networks: to share pages and content on different social platforms. These Cookies also allow to target the advertising offer on social networks.	You can view the privacy policies of the relevant third party social networks. https://twitter.com/personalization https://www.facebook.com/ads/preferences/
TRACKING	NP6 Tag: to track your activity and send you relevant messages (email or via the mobile application)	https://www.np6.fr/consumer-choice/
TRACKING	Hubspot: to manage our contact forms, request a demonor else to receive a white paper.	Opt-out Link: https://developers.hubspot.com/docs/methods/tracking_code_api/remove_cookies

2.3. Technical Cookies

These Cookies allow us to provide you with Services that are tailored to your browsing experience, such as the ability to log in through your Facebook, Twitter or Google account. These Cookies allow us to improve your experience as a Gloseur.

GLOSE may use the following Technical Cookies:

TYPE OF COOKIES	FUNCTION(S)
TECHNICAL	STRIPE: secure the payments you may have to realize. https://stripe.com/privacy
TECHNICAL	Facebook: to manage your connection using your Facebook account and share content on Facebook
TECHNICAL	Twitter: to manage your connection using your Twitter account and share content on Twitter.
TECHNICAL	Google: to manage your login using your Google Account.

3. How long are Cookies used?

The use of Cookies may be limited to the duration of your browsing on the Website with automatic deletion when you leave the Website and may not, in any event, exceed a period of use of thirteen (13) months.

4. How to accept and disable Cookies?

Your prior consent is required before installing certain Cookies.

Thus, during your first visit to the Platform, a "Cookie banner" will appear on the access page.

The deposit of Cookies by GLOSE on your device is subject to your acceptance of one or more families of Cookies, as they appear on the Banner and whose functions are detailed herein.

You will be free to modify your choices at any time, through the choices offered to you by your browser software or by clicking here.

Cookies will be deposited only if they have been expressly accepted by the User.

It is also possible to reject by default the deposit of Cookies by changing your browser settings. Indeed, your browser can be set to automatically accept or refuse Cookies. You also have the possibility to deactivate the storage of Cookies, to be alerted when a Cookie is issued and to see its content and duration of validity.

Uninstalling a Cookie or objecting to the installation of Cookies on your devices may alter your browsing experience and prevent you from benefiting from certain Services on the Platform.

Cookie instructions for the most commonly used browsers are available at the following links

Mozilla Firefox :

https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

Google Chrome :

https://support.google.com/chrome/answer/95647?hl=en

https://policies.google.com/technologies/managing?hl=en

Safari :

https://support.apple.com/en-us/HT201265

Microsoft Edge :

https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

Opera :

https://help.opera.com/en/latest/web-preferences

If you would like more information on Cookie control tools, please visit the following link: https://ico.org.uk/global/cookies/

We remind you that it is not necessary to obtain your prior consent to the installation of technical Cookies, i.e. Cookies that are strictly necessary for the delivery of the Services.