Privacy Policy

GLOWINT, LLC \u00b7 Effective date: [EFFECTIVE DATE]

1. Introduction and Scope

GLOWINT, LLC ("GLOWINT," "we," "us," or "our") is a global management consulting and manufacturer-representation firm headquartered in Miami, Florida, United States. This Privacy Policy explains what personal information we collect through our website at https://glowint.co (the "Site"), why we collect it, how we use and share it, and what rights you have over it.

This policy covers the public Site only. It is written for a business audience: our Site is directed at companies and the people who work for them, not at consumers, and we do not sell products or process payments here. Our client portal at portal.glowint.co is a separate service governed by its own terms and privacy notice. If you engage GLOWINT under a services agreement, the data-protection terms of that agreement govern the personal data we process on your behalf during the engagement, and those terms prevail over this policy where the two differ.

We operate internationally, through partner agents in Argentina, Brazil, Central America, Chile, Colombia, Mexico and North America, and maintain commercial relationships across roughly 83 countries, including 35 in Europe. We have written this policy to meet the requirements of United States federal and Florida state law, the EU and UK General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), Brazil's Lei Geral de Protecao de Dados ("LGPD"), and comparable regimes elsewhere.

For the purposes of the GDPR and the LGPD, GLOWINT, LLC is the controller of the personal data described in this policy.

2. Information We Collect

Information you give us voluntarily.

The Site has one place where you can submit information about yourself: our contact form. When you complete it, we collect your name, work email address, telephone number, company or organization, your role, your country, and whatever you choose to write in the free-text field describing your interest or need. Please send us only what is necessary. Do not use the contact form to transmit confidential business information, trade secrets, or sensitive personal data, including health, financial account, biometric, or government identifier information. If you email or call us directly using the details at the end of this policy, we collect what you provide in that correspondence.

Information collected automatically.

When you visit the Site, we and our analytics providers automatically collect technical and usage information: your IP address, browser type and version, operating system and device type, screen size, approximate location derived from IP address, referring URL, the pages you view, the time and duration of your visit, and how you interact with pages, including scrolling, mouse movement, clicks, and taps. This is described in more detail in Section 5.

We do not knowingly collect special categories of personal data under Article 9 of the GDPR or "sensitive personal information" as defined by the CCPA/CPRA, and we do not ask for it.

3. How We Use Information

We use the information described above to: respond to your inquiry and communicate with you about it; evaluate whether GLOWINT and your organization are a fit, and prepare proposals, scopes of work, and engagement documents; create and maintain a record of your inquiry in our customer relationship management system, so our team has continuity of context; send business communications about our services where you have asked for them or where we are otherwise permitted to do so, with an unsubscribe route in every marketing message; understand how the Site is used, diagnose problems, and improve its content, structure, performance, and accessibility; protect the Site and our business against fraud, abuse, and security incidents; and comply with legal obligations and establish, exercise, or defend legal claims.

We do not use your information for automated decision-making that produces legal or similarly significant effects, and we do not build advertising profiles about you.

4. Legal Bases for Processing Under the GDPR

Legitimate interests (Article 6(1)(f)).

We process contact-form submissions and business correspondence to respond to inquiries, pursue and manage commercial relationships between businesses, and secure and improve the Site. We have assessed that these interests are not overridden by your rights, in part because the data involved is limited, business-context information you chose to give us. You may object at any time, see Section 9.

Consent (Article 6(1)(a)).

We rely on consent for non-essential cookies and analytics, including the session recording described in Section 5, and for marketing emails where consent is required. You may withdraw consent at any time; withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Performance of a contract or steps taken at your request before entering a contract (Article 6(1)(b)).

Where your inquiry concerns a prospective engagement, or where we are performing an existing agreement with you or your organization.

Legal obligation (Article 6(1)(c)).

Where we must retain or disclose information to comply with applicable law.

Under the LGPD, the corresponding bases are consent (Art. 7, I), compliance with a legal obligation (Art. 7, II), performance of or preliminary steps toward a contract (Art. 7, V), exercise of rights in proceedings (Art. 7, VI), and legitimate interests (Art. 7, IX).

5. Cookies and Analytics

The Site uses cookies and similar technologies. Strictly necessary cookies make the Site work, they support security, load balancing, and remembering your cookie preferences, and cannot be switched off. Analytics cookies and scripts are optional and are only loaded where you have consented, in jurisdictions that require consent.

We use two analytics tools, and we name them plainly:

Google Analytics 4 (GA4), provided by Google LLC. GA4 tells us how many people visit the Site, which pages they view, how they arrived, roughly where in the world they are, and what device they use. We have configured IP anonymization where available. GA4 does not tell us your name.

Microsoft Clarity, provided by Microsoft Corporation. Clarity does something more than page counting, and you should know exactly what it does. Clarity records your session and builds heatmaps. It captures a replay of your visit, the pages you moved through, where you scrolled, where your cursor or finger travelled, what you clicked, and how long you paused, and aggregates that behaviour across visitors into heatmaps showing where attention concentrates on a page. We use these recordings to find friction: broken layouts, confusing navigation, forms that people abandon.

Clarity is configured to mask text input by default, so that what you type into form fields is not captured in the replay. Session recording is loaded only where you have consented in jurisdictions requiring consent, and you can decline it through our cookie banner or withdraw consent later without losing access to any part of the Site.

Both providers process this data as our service providers and in accordance with their own privacy notices. You can opt out of Google Analytics across all websites using Google's browser add-on. Most browsers also let you block or delete cookies through their settings, and we honor Global Privacy Control signals where the law requires it. Blocking strictly necessary cookies may prevent parts of the Site from working.

6. How We Share Information

Service providers.

We use vendors to run the Site and our business, website and infrastructure hosting, our CRM platform, email and productivity services, and the analytics providers named above. They may access personal information only to perform services for us, under contract, and are prohibited from using it for their own purposes.

Partner agents.

Where an inquiry concerns a market covered by one of our partner agents, we may share your inquiry with that agent so they can respond, under confidentiality obligations.

Professional advisers.

Lawyers, accountants, auditors, and insurers, where necessary and under duties of confidentiality.

Legal and safety.

Where required by law, subpoena, court order, or government request; to enforce our agreements; or to protect the rights, property, or safety of GLOWINT, our clients, or others.

Business transfers.

In connection with a merger, acquisition, financing, or sale of assets, subject to this policy continuing to apply to the transferred information.

GLOWINT does not sell personal information, and we do not share personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA. We have not sold or shared personal information in the preceding twelve months. We do not sell personal information belonging to anyone, including minors under 16.

7. International Data Transfers

GLOWINT is based in the United States, and the information we collect is processed and stored in the United States and in other countries where our service providers operate. If you are in the European Economic Area, the United Kingdom, Switzerland, Brazil, or another jurisdiction with data-transfer restrictions, your personal data will be transferred outside your country to a jurisdiction that may not provide the same level of protection as your home law.

Where we transfer personal data out of the EEA, the UK, or Switzerland, we rely on the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum where applicable, supported by additional technical and organizational measures where warranted. For transfers from Brazil, we rely on the mechanisms permitted under Articles 33 and following of the LGPD. You may request a copy of the relevant transfer safeguards by writing to us at the address in Section 13.

8. Data Retention

Contact-form submissions and related correspondence are retained in our CRM for the duration of the commercial conversation and for a period afterward that reflects the ordinary rhythm of B2B business development, as a general rule, up to thirty-six months from the last meaningful contact, after which records are deleted or anonymized unless a longer period is required. If your inquiry becomes an engagement, records are retained for the life of the engagement and for the period required by our professional, contractual, tax, and legal obligations. Marketing contact records are retained until you unsubscribe or ask us to delete them.

Analytics data is retained according to each provider's configured retention window. Microsoft Clarity session recordings are retained for a limited period consistent with the provider's standard retention setting and are then deleted.

9. Your Rights

If you are in the European Economic Area, the United Kingdom, or Switzerland, you have the right to: access the personal data we hold about you and receive a copy; rectify inaccurate or incomplete data; erase your data where the conditions for erasure apply; restrict processing in certain circumstances; data portability; object to processing based on our legitimate interests, and an absolute right to object to direct marketing at any time; withdraw consent at any time where processing is based on consent; and lodge a complaint with a supervisory authority. We would appreciate the chance to address your concern first, but that does not limit your right to complain.

If you are a California resident, you have the right to: know what personal information we have collected, the categories of sources, the business purposes, and the categories of third parties to whom we disclose it; delete personal information collected from you, subject to exceptions; correct inaccurate personal information; opt out of the sale or sharing, noting that we do not sell or share, so there is nothing to opt out of; limit the use of sensitive personal information, noting that we do not collect it; and non-discrimination. You may use an authorized agent with proof of authorization.

If you are in Brazil, under the LGPD you have the right to confirmation of processing; access; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data; portability; deletion of data processed with consent; information about entities with which we have shared your data; information about refusing consent and its consequences; revocation of consent; and the right to petition the Autoridade Nacional de Protecao de Dados.

If you are elsewhere, other regimes, including Colombia's Ley 1581 de 2012, Mexico's LFPDPPP, Argentina's Ley 25.326, and comparable laws in Chile, Canada and other markets where we operate, grant rights that broadly parallel those above. Where such a law applies to you, we will honor the rights it gives you. Rather than list every regime here, we take the practical approach: tell us where you are and what you want, and we will apply the law that governs you.

10. How to Exercise Your Rights

Write to us at info@glowint.co with the subject line "Privacy Request," or call +1 (833) 456-9468. Tell us what right you want to exercise, and give us enough information to find your record.

We will verify your identity before acting, using information already in our possession. We will not create new accounts or collect additional identifiers just to verify you.

We respond to GDPR and LGPD requests within one month, extendable by two further months for complex or numerous requests, with notice to you. We respond to CCPA/CPRA requests within 45 days, extendable once by a further 45 days with notice. Exercising your rights is free. We may charge a reasonable fee or decline to act only where a request is manifestly unfounded or excessive, and we will explain our reasoning if that happens.

11. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against loss, misuse, unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit using TLS, access controls limiting internal access to those with a business need, vendor due diligence and contractual data-protection commitments, and periodic review of our practices.

We will be straight with you: no method of transmission over the internet and no method of electronic storage is completely secure. We cannot guarantee absolute security. If a breach occurs that affects your personal data, we will notify you and the relevant authorities as required by applicable law.

12. Children's Privacy

The Site is a business-to-business property intended for professionals acting in a business capacity. It is not directed to children, and we do not knowingly collect personal information from anyone under 18, or under 16 where the GDPR sets that threshold, or under 13 for purposes of the Children's Online Privacy Protection Act. If you believe a child has provided us with personal information, contact us and we will delete it.

13. Changes to This Policy

We may update this policy to reflect changes in our practices, our technology, or the law. When we do, we will revise the effective date at the top of the page. If the changes are material, we will provide more prominent notice.

14. Contact Us

GLOWINT, LLC. Miami, Florida, United States. Email info@glowint.co. Telephone +1 (833) 456-9468. Web https://glowint.co

Data protection matters. For privacy questions, data subject requests, or complaints, including matters arising under the GDPR, CCPA/CPRA, or LGPD, write to info@glowint.co with the subject line "Data Protection".