Privacy policy
This Privacy Policy is issued by GL Technologies (Hong Kong) Limited and its affiliates (together,
"GL.iNet", "we", "us" and "our") and is addressed to individuals outside our organization with whom we interact,
including customers, visitors to our Sites, users of our Applications, and recipients of any of our other products
or services (together, "you" and "your").
This Privacy Policy applies to all of GL.iNet’s brands and platform, including GL.iNet, GoodCloud,
AstroWarp, Lafaer, SimPoYo, as well as any specific device, website, or application that references or links to
this Privacy Notice.
We may update this Privacy Notice to reflect changes to our information practices. If we make any material
changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a
notice on GL.iNet's Application or Site you used prior to the change becoming effective. All changes shall be
effective from the date of publication unless otherwise provided. We encourage you to periodically review this
page for the latest information on our privacy practices.
If you are a resident of United States, Australia, Japan or South Korean, please pay particular attention
to Section 15, which provides additional information highly relevant to your personal information and specifically
outlines how we comply with local laws and regulations.
List of Contents
1. Collection of Personal Data
1.1 Depending on how you use our Sites, Applications, products or services, we may collect
or obtain Personal Data about you from the following sources:
1.1.1 Data you provide to us: We obtain Personal Data when you provide those data to us
(e.g., when you register an account with us; where you contact us via email, telephone, or by any other means; or
when you provide us with your business card).
1.1.2 Account creation details: We collect or obtain Personal Data when you register or
create an account to use any of our Sites or Applications.
● Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you
(e.g., when we provide a service to you).
● Site or Application data: We collect or obtain Personal Data when you visit or use any of our Sites or
Applications, or use any features or resources available on or through our Sites or Applications.
● Content and advertising information: If you interact with any third-party content or advertising on our
Sites and/ or Applications (including third-party plugins and cookies), we allow the relevant third-party
providers to collect your Personal Data relating to your interaction with that content or advertising, and we
receive some or all of this Personal Data from the relevant third-party provider relating to your interaction with
that content or advertising.
● Data you make public: We may collect the Personal Data content you publish, or otherwise manifestly make
public, including comments you make about us, through our Applications and other platforms, your social media, or
any other publicly available platforms.
● Third party information: We collect or obtain Personal Data from third parties who provide it to us
(e.g., single sign-on providers and other authentication services you use to connect to our services, third-party
providers of integrated services, your employer, other GL.iNet customers, business partners, Processors, and law
enforcement authorities).
● Data automatically collected: We or our third-party partners automatically collect information you
provide to us and information about how you access and use our Sites, Applications, products or other services
when you visit our services, read our emails, or otherwise engage with us. We typically collect this information
through a variety of tracking technologies, including (i) cookies or small data files that are stored on an
individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile
SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we
may use third-party partners or technologies to collect this information. Information we collect automatically
about you may be combined with other personal information we collect directly from you or receive from other
sources.
2. Creation of Personal Data
We also create Personal Data records about you in certain circumstances, such as records of your
interactions with us, details of your past interactions with us. We may also link Personal Data collected from any
of our Sites, Applications, products, or services, including where those data are collected from different
devices.
3. Categories of Personal Data We Collect and Process
3.1 When you first register for a GL account, we may collect the following categories of
Personal Data about you: username and password, email addresses and/or phone numbers. After successfully creating
your GL account, you can use it to log in across GL.iNet’s various Sites and Applications.
3.2 When using our Sites, Applications, products, or services, we may also collect and/or
process the following categories of Personal Data about you:
3.2.1 Contact information: including your first and last name, preferred name, phone
number, email address, mailing address, and communication preferences, all of which you have voluntarily
provided.
3.2.2 Account information: including first and last name, country, language preferences,
email address and/or phone number, and all of which you have voluntarily provided.
3.2.3 Transaction information: including records of purchases and prices, consignee first
and last name, shipping address and contact information, shipment tracking details, details of returns, and
warranty details, when you place orders on our Sites or Applications.
3.2.4 Payment details: such as invoice / payment records, payment amount, payment date,
billing address,and payment method, when you place orders on our Sites or Applications. Please note that we use
third-party payment providers, including Shop Pay, Stripe, Amazon Pay, PayPal, and Google Pay, to process payments
made to us. We do not receive or retain any personally identifiable financial information such as payment card
numbers; rather, all such information is provided directly by you to our third-party payment providers. The
payment provider’s use of your personal data is governed by their privacy policy.
3.2.5 Information collected from third-party authentication services or other third-party
accounts you link to our services: some of our Sites, Applications, products or services may allow you to log in
through a third-party social network or authentication service, such as Google. When you use these single sign-on
services to access our Sites, Applications, products, or services, we do not receive your login credentials for
the relevant third-party service. Instead, we receive tokens from the single sign-on service to help identify you
in our system (such as by your username) and confirm you successfully authenticated with the single sign-on
services. In addition to authenticating your identity, these services will, in most cases, provide you the option
to share certain Personal Data with us, which could include your name, email address, friend list and other
contacts, or other information in your public profile (e.g., profile picture, age range, gender, language,
country). The data we receive is dependent on that third party’s policies and your privacy settings on that
third-party site.
3.2.6 Product-specific information: Upon installation of and/or binding IoT products to
our Applications, we will collect certain data to maintain and protect our services, monitor, manage and optimize
performance, and provide customer support and warranty services. Additionally, we may ask you to provide some
other information or obtain information from third parties if relevant to the functionality of the products. The
specific data collected will depend on the products you choose to install and/or use with our Applications. For
details about the product-specific information we collect, please refer to the following:
GL.iNet & Goodcloud: When you use our GL.iNet routers and Goodcloud service, we will collect information
related to the use of our products and devices and statistics about the performance of your GL.iNet devices
through automated technologies. This information includes：
● Inter GL.iNet speed, storage information, error rates, and other performance information.
● Basic information. For the purpose of adapting to user terminal devices, optimizing interface display
effects and compatibility analysis, we may collect your browser information, operating system, device type
(mobile, PC), screen resolution.
● Network environment. We may collect your network status (downlink speed, latency, compatibility),
language and time zone to determine performance bottlenecks, optimize loading speed, and do regional/language
adaptation.
● User behavior data. We may collect your login time, user active time, PV (page visits, including
non-login pages), UV (unique visitors, only logged-in users, not deduplicated yet), page access path to analyze
user usage habits, optimize product structure and interaction paths, and evaluate user stickiness.
● Function usage. We may collect your statistics on specific function usage to evaluate the popularity of
functions and provide a basis for function optimization and iteration.
● Error collection. We may collect the interface error (such as API call failure), backend error (server
error), front-end interface error (JavaScript error, etc.) to monitor system stability, assist in quickly locating
and fixing bugs, and improve user experience.
GLKVM: When you use GLKVM devices and GLKVM Cloud Platform, we will collect the following information from
you:
1) your login account information:
● Login account information: gl account, nickname, avatar information;
● When you use GLKVM Cloud Platform, the network egress IP of the PC you are currently using will be
collected.
2) We may collect the list and version of your connected IOT devices to provide you with the upgraded
functionality of your IOT devices to ensure that you can use the latest version of the service (including the
firmware version).
3) Information we collect through automated means
When you use GLKVM Cloud Platform, we collect data about the device you use to access GLKVM Cloud Platform,
such as: device name; relevant operating system type; host name; IP address; encryption public key; language
setting; date and time of access to the cloud platform; logs describing the connection, and statistics about data
sent from other devices ("inter-node traffic logs"); however, please note that GLKVM Cloud Platform does not
process or access the content of user traffic data transmitted through the cloud platform, which is fully
end-to-end encrypted.
You may choose to use certain features and functions through GLKVM Cloud Platform, which may generate
additional logs and other data that will be sent to GLKVM Cloud Platform for processing and storage on behalf of
our customers ("customer log data").
When you use GLKVM Cloud Platform, we also collect aggregated usage statistics and user behavior data (such
as your login time, login activity, user active time, PV (page views, including non-login pages), UV (unique
visitors, limited to logged-in users, not yet deduplicated), page access path, feature usage, KVM device
information, and KVM device usage duration) to analyze user usage habits, optimize product structure and
interaction paths, assess user stickiness, and improve product functionality. We will use
de-identification/anonymization techniques to process the above data, ensuring that it cannot identify your
specific personal identity, either alone or in combination with other information.
4) When you use the "Screen Wall" feature, for your convenience, we will remember your device password
with your consent and store it securely in the cloud after encryption. If you choose not to agree, we will not
record your device password. After your consent, you can also click the key icon on the editing page at any time
to cancel saving, and we will immediately clear the password storage record.
AstroWarp: When you use our AstroWarp services, we will collect the following information from you:
1) Login Account Data
● Login account information: GL account, nickname, profile picture.
● Information collected during the use of the router: Router MAC address, IP address, device name, device
model, and firmware version.
● Resource sharing data from connected routers: IP, MAC, and default names of connected devices.
● Cloud gateway purchases: When users purchase a cloud gateway, we will collect the network exit IP of the
PC.
2) Application Data
To ensure you continue to enjoy the latest AstroWarp services, we collect version information of your
AstroWarp application and mobile device model during firmware upgrades. We may also collect a list of connected
smart devices and their version numbers to provide upgrade functionality, ensuring you can access the latest
services (including firmware versions).
3) Information collected automatically:
● Device name,operating system, hostname, IP address, encryption public key, language settings, access date
and time, connection logs, and inter-node traffic statistics.
● Aggregated usage statistics, such as the amount of data transmitted.
Note:
● AstroWarp does not process or have access to the content of user traffic data transmitted through
AstroWarp, as it is fully end-to-end encrypted.
● Customers may choose to use certain features and functions of AstroWarp, which may generate additional
logs and data sent to AstroWarp for processing and storage on behalf of our customers (referred to as “customer
log data”).
● When you use our services, we also collect aggregated usage statistics (e.g., the amount of data
transmitted through AstroWarp's cloud gateway over a period). Please note that this aggregated information or
metadata cannot be used to identify you or your device, and we may use and disclose such information at our
discretion as described in the “Aggregated/De-identified Information” section below.
Others
If you learned about Lafaer and SimPoyo's products through our website and would like to learn more about
the data they collect, you can view their privacy policy at the following URL:
1) Lafaer: https://lafaer.co/policies/privacy-policy
2) SimPoYo: https://w.simpoyo.com/privacy-statement/
4. Purposes of Processing
GL.iNet processes Personal Data for the following purposes and based on the following legal grounds:
● For the performance of GL.iNet services. This element covers all technical and commercial processes
required to carry-out user requests.
● Processing is necessary to perform a contract with the User, or in order to conclude one.
● For correct operation of our products and services through internal data analysis.
● For convenient and straightforward use of our products and services.
● To improve the Site, personalize the user experience, and enhance user interactions with the Site.
● Processing is based on GL.iNet's legitimate interest to conduct its business, improve its product and
service offerings, and facilitate communication.
● Promotional communications.
● Processing is based on your consent.
● For linking various user accounts (i.e. the GL account with other social media or email accounts) and
extracting information for specialized requested services.
● To provide customer service and ensure the security of our operations.
● Processing is based on the legal obligation to ensure the confidentiality of processing and GL.iNet's
legitimate interest to secure its operations.
● To offer you optimized advertising and product information.
● To confirm identity and prevent fraud.
● Processing may be requested by some judicial process or governmental agency.
5. Legal bases for Processing
5.1 The legal bases on which we rely for the processing of Personal Data , are as
follows:
5.1.1 Perform our contractual services or prior to entering into a contract with you: If
you order products or services from us or if you contact us to request our products or services, we use your
Personal Data to provide you with these products or services, including for account and contract management, to
facilitate user benefits and services, including customer support and process payment for our products and
services or with information that may be relevant for you to decide on whether you want to order our products and
services;
5.1.2 Justified by our legitimate interests: The usage of your Personal Data may also be
necessary for our own business interests. For example, we may use some of your Personal Data to update and monitor
the services, or diagnose or fix technology problems; help maintain the safety, security and integrity of our
property and services, technology assets and business; enforce our terms, resolve disputes, carry out our
obligations and enforce our rights, and protect our business interests and the interests and rights of third
parties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity.
5.1.3 Consent: In some cases, we may ask you to grant us separate consent to use your
Personal Data. In this case, you can revoke your consent at any time with effect for the future.
5.1.4 Compliance with legal obligations: We are obligated to collect or retain certain
Personal Data because of legal requirements, for example, tax or commercial laws, or we may be required by law
enforcement to provide Personal Data on request.
6. Disclosure of Personal Data
6.1 We may also share, transmit, disclose, grant access to, make available, and provide
Personal Data with and to third parties, as described below.
6.1.1 you and, where appropriate, your appointed representatives.
6.1.2 GL.iNet affiliates: We share Personal Data amongst the legal entities that make up
the GL.iNet, for legitimate business purposes and the operation of our Sites, Applications, products, and services
for you, in accordance with applicable law. These legal entities may use your Personal Data in the manner
described in this Privacy Policy.
6.1.3 As required by law: We may disclose Personal Data to third parties, such as legal
advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if
we reasonably believe in good faith that such action is necessary:
(a) in connection with the establishment, exercise, or defense of legal claims;
(b) to comply with laws or to respond to lawful requests and legal process;
(c) to protect our rights and property and the rights, personal safety and property of others, including to
enforce our agreements and policies;
(d) to detect, suppress, or prevent fraud or other criminal activity; or
(e) as otherwise required by applicable law.
6.1.4 Third-party Processors: We share Personal Data with third party contractors and
service providers subject to reasonable confidentiality terms. such as email service providers;
marketing/advertising service providers; text message service providers; payment services providers; shipping
companies; and postal carriers, subject to the requirements noted below in this Section (6). These Processors
support us in processing the types of Personal Data described above in Sections (1) - (3), and for the purposes
described in Section (4). They only are authorized to process that information as necessary and as directed by
us;
6.1.5 Advertising networks and partners: To efficiently market our products and services
to you, including to deliver advertising and personalize content on our Sites, Applications, products and
services, on other websites and services, and across other devices, we may share Personal Data with advertising
networks and partners. These parties may collect information automatically from your browser or device when you
visit our websites and other services through the use of cookies and similar technologies. This information is
used to provide and inform targeted advertising, as well as to provide advertising-related services such as
reporting, attribution, analytics, and market research.
6.1.6 Business and marketing partners: We may also disclose Personal Data with other
business and marketing partners with whom we jointly offer products or services or who are part of our partner
program. We may obtain your consent where required by applicable law;
6.1.7 Individuals you choose, for example through our device-sharing function; we
recommend you share information with only people you trust;
6.1.8 Independent advisors: We may disclose Personal Data to our independent advisors such
as accountants, auditors, consultants, lawyers, and other outside professional advisors to GL.iNet, subject to
binding contractual or statutory obligations or statutory of confidentiality;
6.1.9 Corporate transactions: if GL.iNet is involved in a corporate business transaction,
such as a merger, acquisition, or sale of all or a portion of our company assets, we may disclose Personal Data to
a third party during negotiation of, in connection with or as an asset in such a corporate business transaction.
If GL.iNet completes such a corporate business transaction, you will be notified via email and/or a prominent
notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding
your Personal Data. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership;
and
6.1.10 Other Disclosures We may also disclose your Personal Data to any other third party
or publicly with your prior consent or direction.
6.2 If we engage a third-party Processor to Process your Personal Data, the Processor will
be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior
written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data;
together with any additional requirements under applicable law. Please note that third parties and business
partners may process your Personal Data in accordance with their own privacy policies and terms of service.
7. International Transfer of Personal Data
7.1 Because of the international nature of our business, we transfer Personal Data within
the GL.iNet, and to third parties as noted in Section (6) above, in connection with the purposes set out in this
Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data
protection compliance requirements than those that apply in the country in which you are located, including China,
the EEA, and the US.
7.2 In the event of a transfer by GL.iNet, we ensure that international transfers of your
Personal Data are made pursuant to appropriate safeguards, such as:
7.2.1 Ensuring that the Personal Data is only transferred to countries recognized as
Adequate Jurisdictions.
7.2.2 The transfer is made pursuant to appropriate safeguards;
7.3 If you wish to enquire further about these safeguards, including the specific
contracts entered into, or used, please contact us using the details set out under Section (14) of this Privacy
Notice.
7.4 Please note that when you transfer any Personal Data directly to any GL.iNet entity
established outside the UK, Switzerland, or the EEA (as applicable), this is considered a direct collection, to
which the safeguards mentioned in this Section (7) may not apply. We will nevertheless Process your Personal Data,
from the point at which we receive such data, in accordance with the provisions of this Privacy Notice.
8. Data Retention
8.1 We have implemented processes designed to ensure that your Personal Data are only
processed for the minimum period necessary for the purposes set out in this Privacy Policy. The criteria for
determining the duration for which we will retain your Personal Data are as follows:
8.1.1 we will retain Personal Data in a form that permits identification only for as long
as:
(a) we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are
lawfully included in our mailing list and have not unsubscribed); or
(b) your Personal Data are necessary in connection with the lawful purposes set out in this Privacy Notice,
for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between you and
us, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business
and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal
Data),
8.1.2 the duration of:
(a) any applicable limitation period under applicable law (i.e., either any statutory retention periods as
required by the law of the applicable region (e.g., the European Union or a member state of the EEA), or any
period during which any person could bring a legal claim against us in connection with your Personal Data, or to
which your Personal Data are relevant); and
(b) an additional two (2) month period following the end of such applicable limitation period (so that, if
a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in
which to identify any Personal Data that are relevant to that claim),
8.1.3 in addition, if any relevant legal claims are brought, we continue to Process
Personal Data for such additional periods as are necessary in connection with that claim.
8.2 During the periods noted in 8.1.2 above, we will restrict our Processing of your
Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data
need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in 8.1 above, each to the extent applicable, have concluded, we will either:
(a) permanently delete or destroy the Relevant Personal Data; or
(b) anonymize or deidentify the Relevant Personal Data.
9. Your Privacy Rights
9.1 Subject to applicable law, you may have the following rights regarding the Processing
of your Relevant Personal Data:
(a) the right not to provide your Personal Data to us (however, please note that we may be unable to
provide you with the full benefit of our services, if you do not provide us with your Personal Data – e.g., we
might not be able to process your requests without the necessary details);
(b) the right to request access to, or copies of, your Relevant Personal Data, together with additional
information, such as information regarding the nature, Processing and disclosure of those Relevant Personal
Data;
(c) the right to request rectification of any inaccuracies or incompleteness in your Relevant Personal
Data;
(d) the right to request, on legitimate grounds, restriction of Processing of your Relevant Personal Data
(limiting the purposes for which we Process your Personal Data);
(e) the right to have certain Relevant Personal Data transferred to another Controller, in a structured,
commonly used and machine-readable format, to the extent applicable;
(f) the right to request the deletion or removal of your Relevant Personal Data where there is no other
legal basis for us to keep using it. Please note that we may not be able to immediately remove the information
from the backup system due to applicable laws and regulations or technological limitations. If this is the case,
we will isolate your Relevant Personal Data from any further processing until the backup can be deleted or be
anonymized / deidentified.
(g) where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that
consent at any time (noting that such withdrawal does not affect the lawfulness of any Processing performed prior
to the date on which we receive notice of such withdrawal).
9.2 Under the GDPR , you may also have the following additional rights regarding the
Processing of your Relevant Personal Data:
(a) the right to object, on grounds relating to your particular situation, to the Processing of your
Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public
interest) or 6(1)(f) (legitimate interests) of the GDPR;
(b) the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct
marketing purposes.
(c) the right to lodge complaints regarding the Processing of your Relevant Personal Data with a competent
Data Protection Authority. However, we encourage you to first contact us so that we can together solve any
concerns you may have.
9.3 This does not affect your statutory rights.
9.4 To exercise one or more of these rights, or to ask a question about these rights or
any other provision of this Privacy Notice, or about our Processing of your Personal Data, please use the contact
details provided in Section (14) below. Please note that:
9.4.1 in some cases it will be necessary to provide evidence of your identity before we
can give effect to these rights; and
9.4.2 where your request requires the establishment of additional facts (e.g., a
determination of whether any Processing is non-compliant with applicable law) we will investigate your request
reasonably promptly, before deciding what action to take.
10. Direct Marketing
10.1 We Process Personal Data to contact you via email, telephone, SMS, EMS, direct mail,
or other communication formats to provide you with information regarding Sites, Applications, products, and
services that may be of interest to you. If we provide Sites, Applications, products, or services to you, we may
send or display information to you regarding our Sites, Applications, products, or services, upcoming promotions
and other information that may be of interest to you, including by using the contact details that you have
provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the
extent required under applicable law. Please note that we may track your opening and clicking behavior.
10.2 You may unsubscribe from specific promotional email campaigns at any time by simply
clicking on the unsubscribe link included in every promotional electronic communication we send.After you
unsubscribe, we will not send you further promotional emails in connection with the email campaigns you have
unsubscribed from, but in some circumstances we will continue to contact you to the extent necessary for the
purposes of providing any Sites, Applications, products, or services you have requested or in connection with any
email campaigns to which you remain subscribed.
10.3 You may unsubscribe from specific promotional text campaigns at any time by replying
STOP via text message to any of the promotional text communications we send in relation to the specific campaign
you would like to opt out from. After you unsubscribe, we will not send you further promotional text messages in
connection with the text campaigns you have unsubscribed from, but in some circumstances, we will continue to
contact you to the extent necessary for the purposes of providing any Sites, Applications, products, or services
you have requested or in connection with any text campaigns to which you remain subscribed.
11. Details of Controllers
11.1 Your Personal Data is controlled by the GL.iNet company located in your region. The
following entities are responsible for processing your data:
Controller entity: GL Technologies (Hong Kong) Limited
Contact details: Unit 601, Building 5W,Hong Kong Science Park, Shatin, N.T., Hong Kong
Controller entity: GL Intelligence, Inc.
Contact details: 10400 Eaton Place, Suite 215, Fairfax, VA 22030
With respect to the processing of Personal Data through our Site and Applications, these entities may both
access your Personal Data and determine the means and purposes of the processing. Therefore, they are jointly
responsible for such processing. If there is no GL.iNet entity established in your region, your Personal Data will
be controlled by GL Technologies (Hong Kong) Limited, which processes your data on behalf of GL.iNet.
11.2 To provide our products and services, the Data Controllers listed above may engage
other GL.iNet entities to process your Personal Data strictly on their behalf and under their documented
instructions. These internal service providers, acting as Data Processors, include our entities headquartered in
China that provide global services such as product research, data operations, and customer support. This
relationship is governed by a robust internal Data Processing Agreement designed to ensure that your Personal Data
is protected in accordance with applicable laws and to the highest standards.
11.3 For general enquiries, or to exercise any of the rights set out in this Privacy
Policy, please contact support@gl-inet.com. Requests relating to data protection will be coordinated by the
appropriate GL.iNet entity based on your location.
12. Business Information and Links to Other Websites
12.1 Business information: In the course of using our Sites, Applications, products, and
services, we may ask you to provide business information related to the company where you work. Business
information may include information about your company’s practices, policies, processes, and supporting
documentation. This business information is stored on GL.iNet systems, and we use it to provide the solutions you
have contracted us to provide and in accordance with the terms and conditions set forth in agreements between
GL.iNet and your company,
12.2 Links to other websites: This Privacy Policy applies only to GL.iNet practices,
technologies, and services. Our online properties may include links to websites and online services that are
operated by other companies not under the control or direction of GL.iNet. If you provide or submit Personal Data
to those websites or online services, the privacy policies on those websites or online services apply to your
Personal Data. We encourage you to carefully read the privacy policies of any website you visit.
13. Cookies, Analytics and Tailored Advertising
13.1 GL.iNet and its third-party partners use cookies and similar technologies to
automatically collect certain Personal Data when you visit or interact with our Sites and services to enhance
navigation, analyze trends, administer the Sites, track users’ movements around the Sites, gather demographic
information about our user base as a whole, and assist with our marketing efforts and customer service. You can
control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit
your use of certain features or functions on our Sites and services.
13.2 Our Sites provide you the ability to adjust your preferences regarding our use of
cookies and similar technologies by clicking the "Cookie Settings” link in the footer of our Sites. These cookie
preference manager tools are website, device, and browser specific, so you will need to change your preferences on
each device and browser you use when interacting with the specific Site you are visiting. You can also stop all
collection of information via our web services by not using our Sites and services.
13.3 You may also be able to utilize third-party tools and features to further restrict our use of cookies and similar technologies. For example, cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. In addition, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser. You may also exercise choice regarding the use of cookies from Google Analytics by going to https://support.google.com/analytics/answer/181881?hl=en to download the Google Analytics Opt-out Browser Add-on. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: https://policies.google.com/technologies/partner-sites.
14. Contact Us
If you have questions or concerns with respect to our Privacy Policy, you may contact us at
support@gl-inet.com or write to us at: GL Technologies (HK) Limited, Unit 601, Building 5W, Hong Kong Science
Park, Shatin, N.T., Hong Kong.
15. Supplemental Terms – Jurisdiction-Specific
15.1 UNITED STATES
15.1.1 These following disclosures supplement the information contained in the main body
of our Privacy Notice by providing additional information about our Personal Data processing practices relating to
individual residents of certain states in the United States, including the states of California, Nevada, Colorado,
Connecticut, Montana, Oregon, Texas, Utah, or Virginia in the United States. For a detailed description of how we
collect, use, disclose, and otherwise process Personal Data, please read the main body of our Privacy
Notice.
15.1.2 Collection and Use of Personal Data
(1) Personal Data.
(A) As described in more detail in Section (3) above, we collect, and have collected in the preceding 12
months, the following categories of Personal Data:
(a) Identifiers, such as first and last name, preferred name, phone number, email address, user ID, and
online identifiers.
(b) Customer records, such as contact information, and account information.
(c) Commercial information, such as records of purchases and prices, shipping address and contact
information, and details of returns, and consumer histories and tendencies.
(d) Internet / network information, such as the device type, manufacturer, and model, operating system, IP
address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your
network.
(e) Other Personal Data, such as your communication preferences, country, language preferences, and any
other Personal Data you choose to share in custom messages sent through the forms, email addresses, or other
contact information we make available to customers.
(f) Inferences, including consumer preferences, predispositions, and characteristics.
(B) As described in Section (1) above, we collect this Personal Data directly from you, automatically when
you interact with our Sites, Applications, products, or other services, from third parties, and from public
third-party platforms such as social media websites.
(C) We collect Personal Data from and about you for a variety of purposes. For example, we use Personal
Data to communicate with you; to facilitate, process, and fulfill orders you place with us or the services you
request; to analyze and improve the use of our Sites and Applications; to deliver marketing communications and
personalized and non-personalized advertising; and to facilitate our customer services. For more information about
our use of Personal Data, please refer to Section (4) above.
(2) Deidentified Information: We may at times receive, or process Personal Data to create, deidentified
information that can no longer reasonably be used to infer information about, or otherwise be linked to, a
particular individual or household. Where we maintain deidentified information, we will maintain and use the
information in deidentified form and not attempt to reidentify the information except as required or permitted by
law.
15.1.3 Keep Your Information Safe and Secure
(1) All GL.iNet products are built with strong security features that continuously protect your
information. The insights we gain from maintaining our services help us detect and automatically block security
threats from ever reaching you. And if we do detect something risky that we think you should know about, we’ll
notify you and help guide you through steps to stay better protected.
(2) We work hard to protect you and GL.iNet from unauthorized access, alteration, disclosure, or
destruction of information we hold, including:
(A) We use encryption to keep your data private while in transit.
(B) We review our information collection, storage, and processing practices, including physical security
measures, to prevent unauthorized access to our systems.
(C) We restrict access to personal information to GL.iNet employees, contractors, and agents who need that
information in order to process it. Anyone with this access is subject to strict contractual confidentiality
obligations.
15.1.4 Personal Data Disclosures, Sales, and Targeted Advertising
We may disclose the categories of Personal Data above to the following categories of third parties: the
entities that make up the GL.iNet, Processors, third-party providers with services integrating with our services,
individuals you choose to share Personal Data with, and certain third parties where you have provided consent or
where otherwise required or permitted by law. Please see Section (6) for more detail. Please be aware that we will
not transfer your Personal Data to any third parties, including advertising platforms, data brokers, or
information resellers, for purposes other than providing or improving the use case or features of our Sites,
Applications, products, or services, without your consent.
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be
able to limit or opt-out of the sale of Personal Data or the processing of Personal Data for purposes of targeted
advertising (as described in the Your Additional U.S. Privacy Choices section below).
Please note we do not sell the Personal Data of individuals we know to be less than 16 years of age or
share such information for targeted advertising purposes. In addition, we do not sell Personal Data, and we do not
process or otherwise share Personal Data for the purpose of targeted advertising.
15.1.5 Automated Decision-Making and Profiling
We do not conduct automated processing of Personal Data for the purposes of evaluating, analyzing, or
predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly
significant effects. As a result, we do not provide a right to exercise control over such forms of automated
decision-making and profiling.
15.1.6 Your Additional U.S. Privacy Choices
(1) Depending on your state of residency and subject to certain legal limitations and exceptions, you may
be able to exercise some or all of the following rights:
(A) Right to Know: the right to confirm whether we are processing Personal Data about you and, under
California and Oregon law only, to obtain certain personalized details about the Personal Data we have collected
about you, including:
(a) The categories of Personal Data collected;
(b) The categories of sources of the Personal Data
(c) The purposes for which the Personal Data were collected;
(d) The categories of Personal Data disclosed to third parties (if any), and the categories of recipients
to whom this Personal Data were disclosed (or, for Oregon residents only, a list of the specific third parties to
whom personal data have been disclosed);
(e) The categories of Personal Data shared for targeted advertising purposes (if any), and the categories
of recipients to whom the Personal Data were disclosed for these purposes; and
(f) The categories of Personal Data sold (if any) and the categories of third parties to whom the Personal
Data were sold.
(B) Right to Access & Portability: the right to obtain access to the Personal Data we have collected about
you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent
technically feasible, readily usable format that allows you to transmit the data to another entity without
hindrance.
(C) Right to Correction: the right to correct inaccuracies in your Personal Data, taking into account the
nature of the Personal Data and the purposes of the processing of the Personal Data.
(D) Right to Control Over Sensitive Personal Data.: the right to exercise control over our collection and
processing of certain Sensitive Personal Data.
(E) Right to Opt-Out of Targeted Advertising: the right to direct us not to use or share Personal Data for
certain targeted advertising purposes.
(F) Right to Opt-Out of Sales: the right to direct us not to sell Personal Data to third parties.
(G) Right to Deletion: the right to have us delete Personal Data we maintain about you (subject to certain
exceptions).
(2) Depending on your state of residency, you may also have the right to not receive retaliatory or
discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the
rights described above may result in a different price, rate or quality level of product or service where that
difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by
law.
(3) Submitting Privacy Rights Requests
Please submit a request specifying the right you wish to exercise by sending us an email at the following
address: support@gl-inet.com.
To exercise your right to opt-out as it relates to the use of cookies and similar technologies that involve
the sale of Personal Data or the use of Personal Data for targeted advertising purposes, please click the “Cookie
Settings” link in the footer of the website and adjust your preferences accordingly. If you are visiting our Sites
with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising
should already be turned off automatically in our cookie preference manager. Please note this opt-out tool is
website, device and browser specific, so you will need to change your preferences on each device and browser you
use to interact with the specific website you are visiting. In addition, you can also opt-out of cookie-based
sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting
https://www.privacyrights.info/. Lastly, you may follow the other steps set forth in Section (13) above to further
exercise control over cookies and similar technologies.
Before processing your request to exercise certain rights (including the Right to Know, Access &
Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a
state that offers the requested right(s). In order to verify your identity, we will generally either require the
successful authentication of your account, or the matching of sufficient information you provide us to the
information we maintain about you in our systems. As a result, we require requests submitted through our email
address to include the requester’s name and email address, their relationship with GL.iNet, the brands relevant to
the request, and the data subject’s email address, state/ country/ zip and any comments relating to the
request.
In certain circumstances, we may decline or limit your request, particularly where we are unable to verify
your identity or locate your information in our systems, or where you are not a resident of one of the eligible
states.
(4) Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf
through the designated methods set forth above where we can verify the authorized agent’s authority to act on your
behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid
power of attorney or (ii) a signed letter containing your name and contact information, the name and contact
information of the authorized agent, and a statement of authorization for the request. Depending on the evidence
provided and your state of residency, we may still need to separately reach out to you to confirm the authorized
agent has permission to act on your behalf and to verify your identity in connection with the request.
(5) Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with
your privacy rights request. All appeal requests should be submitted by replying to the communication resolving
your original request.
15.2 AUSTRALIA
The following disclosures supplement the information applicable to residents of Australia. We strictly
comply with relevant Australian laws and regulations to ensure transparency in the collection, use, and sharing of
your information. These laws include the Privacy Act 1988, the Spam Act 2003, and other applicable privacy and
data protection legislation.
15.2.1 How We Protect Your Personal Information
(1) All personal information we hold will be processed and stored in compliance with obligations under the
Privacy Act 1988. We take reasonable steps to:
(A) Implement practices, procedures, and systems to ensure legal compliance and address compliance-related
inquiries/complaints.
(B) Maintain the accuracy, completeness, and currency of collected personal information.
(C) Secure information against misuse, interference, loss, or unauthorized access through physical and
technological safeguards.
(D) Destroy or permanently de-identify information when no longer needed for legal/business
purposes.
(2) If you identify any security vulnerabilities, please notify us immediately. We adhere to all mandatory
data breach notification requirements outlined in the Privacy Act.
15.2.2 Complaints
To lodge a complaint about our handling of personal information, please submit written details via post or
email using the contact information in this policy. We will respond to formal complaints within 30 days.
If unsatisfied with our resolution, you may escalate the matter to office of the Australian Information
Commissioner (OAIC). For additional details about OAIC, you may:
Visit the Office of the Australian Information Commissioner (OAIC) website: www.oaic.gov.au
15.3 JAPAN
The following disclosures supplement the information applicable to residents of Japan. We handle personal information in accordance with the Act on the Protection of Personal Information (Act No. 57 of 2003, as amended; the "APPI") and the relevant cabinet orders, ordinances, and guidelines issued thereunder.
15.3.1 Purpose of Use and Third-Party Provision
(1) We use personal information for the following purposes:
(A) To process orders, deliver products, provide after-sales support, and administer warranty and return services;
(B) To respond to customer inquiries and communicate with customers regarding our products and services;
(C) To improve our products, services, and website, and to provide information about our products and services;
(D) To comply with applicable laws and regulations, and to establish, exercise, or defend legal claims.
(2) Except as set out below, we do not provide personal information to any third party without the prior consent of the customer:
(A) When required by laws or regulations;
(B) When necessary to protect a person's life, body, or property and it is difficult to obtain the customer's consent;
(C) When necessary to cooperate with a national or local government authority in executing affairs prescribed by laws and obtaining consent may impede such execution;
(D) When the customer has been informed in advance of the matters prescribed by Article 27, paragraph 2 of the APPI (opt-out).
(3) We may provide personal information to third parties located in foreign countries (including Hong Kong SAR and mainland China) for the purposes stated in (1). When doing so, we comply with Article 28 of the APPI by disclosing the recipient country, the personal-information protection system of that country, and the measures taken by the recipient to protect the personal information.
15.3.2 Disclosure, Correction, and Complaints
(1) Customers may request disclosure, correction, addition, deletion, suspension of use, or cessation of third-party provision of their personal information held by us. Such requests should be submitted using the contact information in this policy. We may charge a reasonable fee for disclosure requests as permitted by the APPI.
(2) To lodge a complaint about our handling of personal information, please submit written details via post or email using the contact information in this policy. We will respond to complaints in good faith and without undue delay.
(3) If you are not satisfied with our response, you may contact or file a complaint with the Personal Information Protection Commission of Japan (PPC). For more information, please visit the PPC website: www.ppc.go.jp.
The following disclosures supplement the information applicable to residents of Japan. We handle personal information in accordance with the Act on the Protection of Personal Information (Act No. 57 of 2003, as amended; the "APPI") and the relevant cabinet orders, ordinances, and guidelines issued thereunder.
15.3.1 Purpose of Use and Third-Party Provision
(1) We use personal information for the following purposes:
(A) To process orders, deliver products, provide after-sales support, and administer warranty and return services;
(B) To respond to customer inquiries and communicate with customers regarding our products and services;
(C) To improve our products, services, and website, and to provide information about our products and services;
(D) To comply with applicable laws and regulations, and to establish, exercise, or defend legal claims.
(2) Except as set out below, we do not provide personal information to any third party without the prior consent of the customer:
(A) When required by laws or regulations;
(B) When necessary to protect a person's life, body, or property and it is difficult to obtain the customer's consent;
(C) When necessary to cooperate with a national or local government authority in executing affairs prescribed by laws and obtaining consent may impede such execution;
(D) When the customer has been informed in advance of the matters prescribed by Article 27, paragraph 2 of the APPI (opt-out).
(3) We may provide personal information to third parties located in foreign countries (including Hong Kong SAR and mainland China) for the purposes stated in (1). When doing so, we comply with Article 28 of the APPI by disclosing the recipient country, the personal-information protection system of that country, and the measures taken by the recipient to protect the personal information.
15.3.2 Disclosure, Correction, and Complaints
(1) Customers may request disclosure, correction, addition, deletion, suspension of use, or cessation of third-party provision of their personal information held by us. Such requests should be submitted using the contact information in this policy. We may charge a reasonable fee for disclosure requests as permitted by the APPI.
(2) To lodge a complaint about our handling of personal information, please submit written details via post or email using the contact information in this policy. We will respond to complaints in good faith and without undue delay.
(3) If you are not satisfied with our response, you may contact or file a complaint with the Personal Information Protection Commission of Japan (PPC). For more information, please visit the PPC website: www.ppc.go.jp.