This GLACER® privacy notice (“Privacy Notice”) describes how the GLACER LLC (“GLACER”, “we” or “us”) collects, uses, shares, and retains personal information that you provide to us, or that we collect, when you use the GLACER website located at www.glacer.org and other websites owned or controlled by GLACER (the “Sites”) or related mobile applications, use GLACER products and services and complete related forms, participate in GLACER events, or communicate with one of our customer service representatives (“Personal Data”). This Privacy Notice does not cover the privacy practices of local GLACER chapters, which are separate legal entities that – depending on where they are located, may be subject to different laws and requirements than those of GLACER (to understand how chapters use personal information, please contact them directly). Please note that if you disagree with anything in this Privacy Notice, you must not use the Sites or mobile applications, or provide personal information to us in connection with GLACER’s products or services.

1. Overview

This policy applies to all information that we collect about you when you use GLACER websites. It does not cover the privacy practices of local GLACER chapters or other third-party websites we may link to. If you are in the European Economic Area, United Kingdom and/or Switzerland, refer to Section 10 for polices specific to you. This Privacy Policy applies to all personal information that we collect about you when you do any of the following (collectively “Services”):

• use the GLACER websites located at www.glacer.org and other websites owned or controlled by GLACER or related mobile applications that link to this Privacy Policy (collectively “Sites”); or

• use GLACER products or services and complete related forms, participate in GLACER events, or communicate with one of our customer service representatives.

This Privacy Policy does not cover the privacy practices of local GLACER chapters, which are separate legal entities. You should contact them directly or review the privacy policy located on their websites to understand how they process your information.

Our Sites may contain links to third-party websites. These third-party websites and services are not related to us and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage you to read the privacy policies of all websites you visit.

A “visitor” is an individual who visits the Sites, without having registered. A “registered user” is an individual, such as a member, who has registered with us, and whose identity can be determined directly or indirectly from the information provided. For this Privacy Policy “you” means a visitor or a registered user.

By accessing and using our Services, subject to applicable law, you signify you understand and consent to the terms of this Privacy Policy and consent to our Terms of Use. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy or our Terms of Use, you should immediately discontinue access or use of our Services.

2. Information We Collect

We collect personal information when you interact with our Services.

You provide data to us when you:

• Sign up to become a registered user of our site(s)

• Join as an GLACER member

• Register for virtual, or in-person, events or conferences

• Download certain publications or materials which are offered for free

• Register to take a certificate or certification exam

• Communicate with GLACER staff and provide information to us, such as your email address.

We record your visits and use of our services. We may use automatic data collection technologies to collect certain information about your device, your activities on our site and your location as described in our Cookie Notice.

Third parties such as your employer, our training partners or companies controlled by GLACER, may share your data with us. We may collect data about you when you use our services on social media. You provide us with data when you participate in our professional networking features or post on public areas of the site.

We use third party payment processors who fully comply with PCI requirements. As such, your online payment data is not captured, stored or used by us.

We collect personal information when you interact with our Services.

Personal information is data that can be used to identify you directly or indirectly or to contact you including, but not limited to, your name, mailing address, email address, and telephone number.

This policy does not apply to anonymized information as it cannot be used to identify you. The types of personal information that we may collect about you include, but are not limited to, information you provide to us, information from third parties, and information collected automatically about your use of our Services.

2.A. Information You Directly and Voluntarily Provide to Us

2.A.i Membership.  

If you provide your personal information to GLACER to become a member, or if you sign up to become a registered user of any Site, you will be required to provide certain information as part of the registration process. This information may include your first and last name, email address, and business or home address. We may also request that you voluntarily provide other information, such as your phone number, date of birth, demographic information, educational background, work experience, information about your non-GLACER certifications, courses or areas of study in which you may be interested and information about your company as it relates to our Services and your membership. We use this information to communicate with you, to design content and activities that we believe would be of interest to you, and to ensure that we will not violate any applicable U.S. sanctions in providing you access to our Services. We rely on fulfillment of contract as the lawful basis under Article 6, GDPR for processing members’ personal information.

2.A.ii. Events and Conferences.

We may host events that include in-person and virtual conferences, training, knowledge sharing and webinars. If you register for an event, and you already have an account, we will access the information in your account to provide you with information and services associated with the event. We may also ask for additional demographic information during the registration process. If you register for one of our events and you do not have an account or are not a member, we will collect your first and last name, email address, business or home address, information about the type of business you work for or with, and your role in that business. We use the information provided by event attendees to provide them with event services, including badge printing, tracking your Continuing Professional Education (CPE) or Continuing Professional Development (CPD) credits, tailoring sessions to meet the audience profile and to determine the sessions likely to require the biggest rooms, and related purposes connected with the event. We rely on fulfillment of contract as the lawful basis under Article 6, GDPR for processing your personal information in relation to events and conferences.

If you are a presenter at one of our events, we will collect information about you such as your name, employer, contact information and photograph, and we may also collect information provided by event attendees who evaluated your performance as a presenter. We may also make and store a recording of your voice and likeness in certain instances. We rely on a legitimate interest as the lawful basis under Article 6, GDPR for collecting, storing and processing your personal information in this way.

2.A.iii. Publications.

We offer various publications and materials through our Sites. Some of these publications and materials are publicly accessible, and others require that you be a member, or that you create an account and subscribe to receive these publications and materials.

If you are not a member and you create an account for this purpose, you will be required to provide certain information as part of your account registration, which may include your first and last name, email address, business or home address and professional information.

We rely on our contract with you as the lawful basis under Article 6, GDPR to process your personal information for purposes of fulfilling your request to receive our publications.

2.A.iv. Exams and Certification. 

When you register to take an GLACER exam, we will collect certain personal information such as your first and last name, email address, phone number, business address, home address, demographic information and professional and education history. We may also collect and store information you provide to us about special accommodations that you may request. Only authorized employees within GLACER have access to your exam scores and personal information pertaining to any special accommodations you may request. GLACER will collect your exam results and, in conjunction with maintaining your certification(s), if applicable, your record of participation in continuing professional education. We rely on a contract fulfillment basis to process personal information associated with providing certification services.

2.A.v. Certification Status.

If you hold an GLACER certification, we will only share your certification status with a third party to the extent we have received your prior consent to share such information, or to the extent you have provided the third party with the necessary information to access your certification status on our site.

2.A.vi. Communications.

If you communicate or correspond with us by email, through postal mail, via telephone or through other forms of communication, including our customer service center, we may collect the information you provide as part of those communications.  For example, if you correspond with us through email, we may collect and store the email address you use to send the applicable correspondence and use it to respond to your inquiry; to notify you of GLACER conferences, publications, or other services; or to keep a record of your complaint, accommodation request, and similar purposes. We have a legitimate interest in processing the personal information of those who communicate voluntarily with us so that we can provide our Services.

2.B. Information We Automatically Collect.

As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your device (computer, tablet, smart phone) and your activities, including:

• If you access the Services through a computer, we will automatically collect information such as your browser type and version, computer and connection information, IP address, mobile device advertising identifier, Media Access Control (MAC) address pages you have visited, type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution, Internet service provider or mobile carrier’s name, connection speed and connection type, date stamp, URL of the last webpage visited before visiting our Platform, and URL of the first page visited after leaving our Platform, pages viewed, time spent on a page, click through, clickstream data, queries made, search results selected, comments made, search history, type of service requested, purchases made, and information collected through cookies, pixel tags, and other technologies. For more information on the tracking technology we use, please see our Cookie Notice, which describes the cookies used on our Sites and provides information on how users can control the information they process.

• If you access the Services through a mobile device, we may also be able to identify the location of your mobile device. We use your location information (if shared) to identify the geographic locations from which our content is accessed so that we can better understand what content topics may be most relevant in that region, and to our members generally, and to develop resources around those content topics. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

We rely on our legitimate interest in understanding how our members, visitors and potential customers use our website in processing personal information in this way. Such processing assists us in providing more relevant products and services to our members, and with providing value to our sponsors.

2.C. Information from Third Parties.

We may receive personal information about individuals from third parties. This may happen if your employer pays and registers you for training, certification, or membership, however, we will only share information about you with your employer if you consent in advance to our sharing this information. Our third-party training partners may also share your personal information with us when you sign up for training, certification or membership through the applicable training partner. We may also receive personal information about you from companies controlled by or under common control of GLACER. When you interact with our Services on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such personal information that we are permitted to collect by those social media platforms. When you access our Sites through social media channels or when you connect the Site to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.

2.D. Information You Post on the Sites.

If you post information on public areas of the Sites, that information may be collected and used by us, other users of the Sites, and the public generally. If you are a member or registered user and choose to participate in our professional networking features, which are provided by our third-party vendor and volunteer platform provider, Higher Logic, your postings will be associated with the personal information in your public member profile (which includes your name, user name, and other optional information you may choose to include). GLACER may share the following personal information with Higher Logic for this volunteer management platform and other GLACER platforms: your name, state, zip code, country, phone number, bio, email, job title, company, GLACER and non-GLACER certifications, education (university or school and degree), areas of interest, membership level, chapter membership, chapter leader role, chapter ID, work experience, date of birth, photo and staff membership.

If you decide to participate in our platforms and professional networking features, keep in mind that your personal information (for example, your name and online user name), along with any substantive information you disclose in the communication you decide to post, will be publicly accessible and viewable by others who visit that area. In addition, we may highlight certain users’ postings or contributions to other members of the GLACER professional networking features. For example, users who participate actively in our social networking features, like contributing materials and engaging in certain online activities, will be listed as “active members” in a roster that is viewable by all other registered users. It is possible that your posting may result in unsolicited messages from third parties. We strongly recommend that you do not post any information on the public areas of the Sites that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

2.E. Information You Provide to Payment Processors.

All payments made to us are processed by a PCI/DSS-compliant (these are payment card industry security standards) payment processing service. All information collected by these third-party providers for purposes of processing your payments is not available to us, unless you have otherwise provided this information to us in connection with your use of the Sites or our Services.

3) Why We Collect Your Information

We use your data to provide our services to you, respond to you, advise you of other services, and to personalize your experience. We will only use your information as described in this Notice or as disclosed to you prior to such processing taking place.

3.A. To Provide and Maintain our Services.

We will use your personal information to provide information or deliver Services that you request and to allow you to participate in interactive features of our Sites and Services when you choose to do so. For example, we process your personal information to provide membership benefits and other services to you, including order processing, processing of certification or membership applications, registering you for event or training programs, or registering you for reduced hotel price rates. When you sign up for a certification course or seminar, we will use your personal information to facilitate the delivery of such course or seminar. To the extent your organization has paid for your certification course or seminar, we may provide the status of your course or seminar to your organization upon notice to you. In compliance with applicable laws, we may also publish the names, titles, country and business affiliations of officers, committee members and others who have assisted with initiatives or projects to provide recognition of their achievements to the GLACER community.

3.B. To Provide Customer Support or Respond to You.

We collect any information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you.

3.C. To Advise You of Other Services.

From time to time, subject to the applicable law, we may share your personal information with third parties or partners. You may opt out of having your personal information shared with third parties. If you choose to limit the use of your personal information, certain features or Services may not be available to you.

3.D. To Personalize Your Experience.

We may also use your personal information to tailor your experience at our Sites, to compile and display content and information that we think you might be interested in, and to provide you with content according to these preferences. We may also use this information to help us understand your needs and interests, and to better tailor our products and services to meet your needs.

3.E. To Send You Marketing and Promotional Emails.

We may use your personal information we collect from you and third-party sources to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, to deliver targeted and relevant advertising and marketing to you, and to promote our Services. Our marketing will be conducted in accordance with your advertising / marketing preferences and as permitted by applicable law.

3.F. For Research and Development.

We may use your information to gather analysis or valuable information so that we can improve our Services and to detect, prevent and address technical issues. We may also use your information to monitor the usage of our Site including without limitation search terms entered, pages visited and documents viewed.

3.G. For Security Reasons.

We may use personal information to help monitor, prevent and detect fraud, enhance security, monitor and verify identity or access, or security risks.

3.H. To Post Testimonials.

We may use personal information to post testimonials on our Sites. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. You can request your testimonial be updated or deleted at any time by sending a request with your name, testimonial location and contact information.

3.I. To Enforce Compliance with Our Terms and Agreements or Policies.

When you access or use our Services, you are bound to our Terms of Use and this Policy. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We also may process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties and business partners; and, as applicable, collect fees based on your use of our Services. We also use your information to ensure that we will not violate any applicable U.S. sanctions in accepting your donation or by providing you access to our Services.

3.J. Other Legitimate Business Purpose.

We may use your personal information when it is necessary for other legitimate purposes such as protecting our confidential and proprietary information.

4. Children

We do not collect data from children. We do not knowingly collect personal information data from persons under the age of 16. If you are a parent of a child under 16, and you believe that your child has provided us with information about him or herself, please contact us via the information in the Contact section below.

5. How We Share Your Information

We share your data only with those who need access or those to whom you have provided consent. Except as set forth in this Privacy Policy or when specifically agreed to by you, we take care to allow your personal information to be accessed only by those who really need access to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. In general, we do not share your information with a third party for their independent use unless:

• you request or authorize it,

• it is required by law, or

• it is in connection with a co-sponsored event.

We may share personal information in the following circumstances:

5.A. Service Providers. 

We may share your information with our suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with advertising, hosting, data analytics, information technology and infrastructure, email delivery, auditing, exam-testing, training providers and other related activities, vendors or third parties who deliver or provide goods and services or otherwise act on our behalf of or at our direction. 

Our service providers are given only the information they need to perform their designated functions and are prohibited from using the information we provide them for their own purposes.

5.B. Business Partners and Sponsors.

From time to time, we may engage in joint sales or product promotions with selected business partners. If you purchase or specifically express interest in a jointly-offered product, promotion or service, we may share relevant personal information with those partners. If you are an event attendee, speaker, or sponsor, certain items of your information may be included in the event roster, which may also be shared with third-party event sponsors and exhibitors and publicly disclosed, subject to the applicable law.

While we do not control our business partners’ use of such information, we do take appropriate steps to ensure that they use appropriate safeguards to protect your personal information. Our partners and sponsors are responsible for managing their own use of the personal information collected in these circumstances, including providing information to you about how they use your personal information.

We recommend you review the privacy policies of the relevant partner to find out more about their handling of your personal information. Where we do share your personal information with third parties, GLACER takes steps to ensure that they use appropriate safeguards to protect your personal information.

5.C. Within Our Corporate Organization and with Our Local Chapters and Volunteers.

We are part of a corporate organization that has many legal entities, business processes, management structures and technical systems. We may share your personal information within this organization and with our subsidiaries and/or affiliates to provide services and support, provide recommendation to optimize services, to provide members and prospective members with information about our Services, and for the purposes otherwise described in this Privacy Policy. We may also share your information with our board members and our volunteers for the purposes of conducting our internal business operations.  We may also share your information with your local GLACER chapter so they may offer membership and associated services to you pursuant to your membership in that Chapter.

Your information, particularly with respect to the goods and/or services your company has purchased from GLACER for your benefit, will be shared with your organization’s program coordinator.

5.D. Compliance with Laws or Regulatory Body.

We may disclose your information to government authorities or third parties if:

• required to do so by law or regulation, or in response to a subpoena or court order or any other enforceable governmental request or order;

• we believe disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or

• to exercise, establish or defend our legal rights.

5.E. Business Transfers.

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, corporate reorganization or similar event. We will inform any buyer that your information shall only be used in accordance with this Privacy Policy.

5.F. Potential Employers.

If you use GLACER’s Career Center services, the information you include in your profile will be shared with our Career Center site vendor and will be subject to the vendor’s privacy policies.

When you provide information in the Career Center, your information may be accessible to potential employers or recruiters. We will only share information about you with potential employers or recruiters if you consent in advance to our sharing of this information.

Subject to applicable law, we may also make publicly available the names, titles, country and business affiliations of officers, committee members and others who have assisted with initiatives or projects to ensure they receive the appropriate recognition.

6. Information Security

We take reasonable measures to ensure your data is safe. We take reasonable measures to protect any personal information we may hold to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. In some areas of our platforms, we may use encryption technologies to enhance data privacy and help prevent loss, misuse, or alteration of the information under GLACER’s control.

We cannot guarantee, however, that all information will remain secure. The Internet by its nature is a public forum. We encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your login ID and password from third-party access, and for selecting passwords that are secure.

7. Data Retention

We retain your information according to applicable laws and store it securely. We will retain the personal information we collect from you where we have a justifiable business need to do so and/or for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, legal, accounting or other purposes). You can request deletion of your personal information at any time (see "Your Privacy Rights and Choices" section for further information) and we will consider your request in accordance with applicable laws.

When we have no justifiable business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8.  Your Choices and Privacy Rights

You have choices on how we communicate with you. Listed below are choices we provide you in relation to the processing of your personal information. Individuals located in the European Economic Area (“EEA”), the United Kingdom or Switzerland at the time they access our Services, please see section 10, for more information about your choices and rights.

8.A. Marketing Communications.

If you receive commercial electronic communications from us, you can unsubscribe from the receipt of future commercial electronic communications from us by clicking on the “unsubscribe link” provided in such communications, or by going to the Preference Center and submitting an opt-out request.  

Please note that even though you have opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, and you cannot opt out from receiving these messages.

8.B. Subscriptions.

You may manage your subscriptions by subscribing or unsubscribing at any time. Please use the Preference Center to modify or cancel such subscriptions.

8.C. Access and Correction.

You have the right to review and correct personal information that we have collected from you. You may exercise this right by contacting us as indicated in the “How to Contact Us” section, or by going to the Data Subject Access Request form. In your request, please make clear what information you would like to have changed. For your protection, we may need to verify your identity before implementing your request. We will try to implement your request as soon as reasonably practicable. We reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or to charge a fee that considers the administrative costs for providing the information or taking the action requested.

8.D. California Residents. This section applies only to California residents.

• California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, to the extent applicable. To make such a request, please visit our Data Subject Access Request (DSAR) Portal.

• If you are a California resident under the age of 18, and you are registered visitor of a Site, you may request that we remove content or information that you posted on the Site or stored on our servers, by submitting a request in writing as indicated in the “How to Contact Us” section below, and clearly identifying the content or information that you wish to have removed, and providing sufficient information to allow us to locate the content or information to be removed.

• Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, we do not respond to “Do Not Track” (DNT) signals. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

9. International Transfers

We operate in the United States as a global organization. Your personal information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there.

We will take all the steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.

Individuals located in the European Economic Area (“EEA”), the United Kingdom or Switzerland at the time they access our Services, please see section 9, for information on how we transfer your personal information.

10. Notice for Individuals Located in Europe

If you are in the European Economic Area, United Kingdom and/or Switzerland, the policies in this section are specific to you. They describe how we market to you, our legal bases for processing your information and your rights. This section only applies to individuals that access or use our Services while located in the European Economic Area, United Kingdom and/or Switzerland (collectively “Europe”). We may ask you to identify which country you are in when you use some of the Services or we may rely on your IP address to identify which country you are located in.

When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in Europe.

If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in Europe. We are a controller about any personal information collected from individuals accessing or using our Services. A “controller” is an entity that determines the purposes for which and the way any personal information is processed.

10.A. Marketing.

We will only contact individuals located in Europe by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are like those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal information in this way or to disclose your personal information to third parties for marketing purposes, please click an unsubscribe link in your emails or go to the Preference Center and submit an opt-out request. You can object to direct marketing at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting products and services.

10.B. Legal Bases for Processing.

Our legal bases for the processing activities identified in this Policy are:

• We rely on our contract with you as our legal basis for processing in relation to the following: to provide and maintain our services, to provide customer support or respond to you, to enforce compliance with our Terms, agreements or policies, and to share your information with service providers.

• Depending on the specific circumstances, we rely on your consent or legitimate interest in relation to the following processing activities: to send you marketing and promotional emails, to advise you of other services, and to share your information with business partners, sponsors, or within our corporate organization.

• We rely on legitimate interest in relation to the following processing activities: to personalize your experience, for research and development, and when we share your information with board members or volunteers or in relation to business transfers or bankruptcy.

• When we share your information to respond to subpoenas, court orders, government requests, or to protect rights and comply with our policies, or in relation to business transfers or bankruptcy, our processing is based on our legal obligations.

10.C. Your Rights.

We provide you with the rights described below when you use our Services. We may limit your individual rights requests in the following ways:

• where denial of access is required or authorized by law;

• when granting access would have a negative impact on other’s privacy;

• to protect our rights and properties; and

• where the request is frivolous or burdensome.

When we fulfill your individual rights requests for correction (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort. If you would like to exercise your rights under applicable law or if you have questions, please contact us at support@glacer.org. We may seek to verify your identity when we receive an individual rights request from you to ensure the security of your personal information. In certain circumstances, you have the following data protection rights:

• Right to withdraw consent. You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.

• Right of access to and rectification of your personal information. You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated with the gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by us that is inaccurate.

• Right to erasure. You have the right to request erasure of your personal information that:

(a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

(b) was collected in relation to processing that you previously consented, but later withdraw such consent; or

(c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

If we have made your personal information public and are obliged to erase the personal information, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other parties that are processing your personal information that you have requested the erasure of any links to, or copy or replication of your personal information. The above is subject to limitations by relevant data protection laws.

• Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless the exercise of this right adversely affects the rights and freedoms of others.

• Right to the restriction of or processing. You have the right to restrict or object to us processing your personal information where one of the following applies:

(i) You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.

(ii) The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.

(iii) We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or in defense of legal claims.

(iv) You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

(v) Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

• Right to object to processing. Where the processing of your personal information is based on consent, contract or legitimate interests, you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims or for any other exceptions permitted by applicable law.

• Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws. We do not engage in this type of automated processing.

10.D. Transfers of European Personal Information to the U.S.

Our headquarters are in the United States, and information we collect from you will be transferred, stored and processed in the United States. We will protect your personal information in accordance with this Privacy Policy wherever it is processed and will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws. These steps include implementing the European Commission's Standard Contractual Clauses for transfers of personal information to our service providers and business partners. To the extent applicable, GLACER may rely on derogations as set forth in Article 49, GDPR for the transfer and onward transfer of personal information collected from individuals in Europe to the United States, and other countries that the EU views as not providing adequate data protection. Specifically, we may transfer such information to another party to perform a contract with you, with your explicit consent or in a manner that does not outweigh your rights and freedoms. If this personal information is not processed and transferred, we will not be able to execute the contract with you or you will not have access to any or all the benefits and features associated with your transaction.

11. Changes to this Notice We may update this policy.

We may need to update this Privacy Policy from time to time to reflect changes in our business practices, data collection practices or organization. If we make a change that we believe materially affects how we process your personal information, we will provide notice of such change on this Site or via email, at the email address we have on file for you. After such notice, your continued use of our Services will be subject to the then-current Privacy Policy. We encourage you to look for updates and changes to this Privacy Policy by checking the “Effective Date” located at the top of the new Privacy Policy.

12. Contact Information

If you have any questions or concerns about this Privacy Policy, please write to us at GLACER, Data Protection Officer, 1846 E. Innovation Park Dr. Suite 100, Oro Valley AZ, 85755, USA.