Privacy policy:

1. Introduction

This Privacy Policy (the “Policy”) explains how Grande Clip Korea, LLC (“Company”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal information when you visit the glowbeast website at https://glowbeast.co (the “Site”) or subscribe to our email newsletter.

We may provide different or additional notices of our privacy practices for certain services or activities, in which case those notices will supplement or replace the disclosures in this Privacy Policy.

We are committed to protecting your personal information. The Site is intended solely for users who are at least eighteen (18) years of age. We do not knowingly collect personal information from anyone under that age.

By using the Site or subscribing to our newsletter, you acknowledge that you have read this Policy. Where applicable law requires consent, we will rely on the consent you provide when you submit your email address.

This Policy should be read together with our Terms of Service, available at https://glowbeast.co/terms.

2. Personal Information We Collect

We collect only the limited personal information described below. We do not sell goods or services through the Site and we do not require any user account.

2.1 Information you voluntarily provide

We collect information you provide directly to us. The types of personal data we may collect directly from you include:

• Email address — provided by you when you subscribe to our email newsletter through the subscription form on the Site.
• Subscription preferences — any preferences or topics you select at the time of subscription, if applicable.
• Inquiries — if you contact us directly, the content of your message and any contact information you choose to provide.

2.2 Information collected automatically

When you visit the Site, our servers and certain essential technologies automatically collect limited technical information necessary to operate the Site and the newsletter subscription, including:

• Device and usage information, such as your IP address, browser type, device information, operating system, access times and length of stay, information about your activity on a specific page such as mouse movements and keystrokes, the websites you visited before navigating to our websites, specific pages accessed, search terms you used to reach our websites, and links clicked; and
• subscription event metadata (e.g., timestamp of subscription, confirmation status).

We use this information solely to operate, secure, and improve the Site, to confirm your subscription, and to detect or prevent abuse. We do not use it to build advertising profiles.

2.3 Information We Derive or Infer

We may derive information or draw inferences about you based on the information we collect. For example, we may draw inferences about your approximate location based on your IP address.

We use this information solely to operate, secure, and improve the Site, to confirm your subscription, and to detect or prevent abuse. We do not use it to build advertising profiles.

2.4 Cookies

The Site uses strictly necessary cookies only — small text files required for the Site to function (for example, session management, security, and load balancing). We do not currently use analytics, advertising, or tracking cookies. If we add such technologies in the future, we will update this Policy and, where required, obtain your consent through a cookie banner before placing non-essential cookies.

[TO REVIEW — If you decide to add Google Analytics, Meta Pixel, or similar tools, this Section and the Cookies Section must be updated, and you will likely need to deploy a cookie-consent banner for EU/UK and CCPA-compliant opt-outs.]

2.5 Information we do not collect

We do not collect names, postal addresses, telephone numbers, payment information, government-issued IDs, biometric data, precise geolocation, or special categories of personal data (such as health, racial or ethnic origin, religious beliefs, or sexual orientation), unless you voluntarily include such information in correspondence with us.

3. How We Use Personal Information

We use the personal information we collect for the following purposes:

• to send you the email newsletter and related marketing communications about glowbeast, our brand, our products, and promotions;
• to confirm, manage, and process your subscription, preference updates, and unsubscribe requests;
• to operate, secure, and improve the Site, including diagnosing technical problems, preventing fraud or abuse, and protecting our rights and the rights of others;
• to respond to your inquiries and requests; and
• to comply with applicable legal obligations and to exercise or defend legal claims.

We do not use your personal information for automated decision-making that produces legal or similarly significant effects on you.

4. How We Share Personal Information

We do not sell or rent your personal information. We share personal information only as described below.

4.1 Service providers (processors)

We engage trusted third-party service providers to perform services on our behalf, such as email-delivery platforms, hosting providers, and security or anti-abuse tools. These providers process personal information solely on our instructions, are bound by appropriate confidentiality and data-protection obligations, and may not use your information for their own purposes.

[TO REVIEW — Once your email service provider (e.g., Mailchimp, Klaviyo, SendGrid) is selected, list the provider here together with its country of operation and a link to its privacy policy or data-processing terms.]

4.2 Legal disclosures

We may disclose personal information when we believe in good faith that disclosure is required to: (a) comply with applicable law, legal process, or government request; (b) enforce our Terms of Service; (c) protect the rights, property, or safety of the Company, our users, or others; or (d) detect, prevent, or address fraud, security, or technical issues.

4.3 Professional Advisors

We disclose information about you to our professional advisors, including accountants, auditors, lawyers, insurers, and bankers, where necessary to obtain advice or otherwise protect and manage our operations and business interests.

4.4 Business transfers

If we undergo a merger, acquisition, financing, reorganization, bankruptcy, or sale of some or all of our assets, personal information may be transferred as part of that transaction, subject to standard confidentiality protections. We will notify you of any such change in ownership or material change in the handling of your personal information.

4.5 Law Enforcement Authorities and Individuals Involved in Legal Proceedings

We disclose personal data in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

4.6 Corporate Affiliates

We disclose personal data to our subsidiaries and corporate affiliates for the purposes described in the How We Use Personal Information section above.

4.7 With Your Consent and at Your Direction

We disclose personal data to third parties when we have your consent or you intentionally direct us to do so.

4.8 Aggregated or de-identified information

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We process, maintain, and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

5. International Data Transfers

The Company is established in the Republic of Korea, and personal information collected through the Site will be transferred to and stored in Korea, where our servers and operations are based.

Personal information may also be processed by our service providers in other jurisdictions, including the United States. This Policy will apply even if we transfer Personal information to other countries. We have taken appropriate safeguards to require that your Personal information will remain protected wherever it is transferred.

6. Data Retention

We retain your email address and related subscription data for as long as you remain subscribed to our newsletter. If you unsubscribe, we will delete your email address and related personal information from our active mailing systems within thirty (30) days of your unsubscribe request.

We may retain a minimal record of your unsubscribe request (such as a hashed identifier or your email address on a suppression list) for a longer period, where necessary to ensure that we do not contact you again, to defend against legal claims, or to comply with applicable law. Technical logs (such as server access logs) are retained for a limited period in accordance with our security and operational needs and then deleted or anonymized.

7. Your Rights

Subject to applicable law and certain exceptions, you have the following rights with respect to your personal information:

• Right of access — to obtain confirmation as to whether we process your personal information and, if so, to receive a copy of that information.
• Right to rectification — to request that inaccurate or incomplete personal information be corrected or updated.
• Right to erasure (“right to be forgotten”) — to request deletion of your personal information in certain circumstances.
• Right to restriction of processing — to request that we limit the processing of your personal information in certain circumstances.
• Right to data portability — to receive certain personal information in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to object — to object to processing based on our legitimate interests, including direct marketing.
• Right to withdraw consent — where processing is based on consent (for example, for marketing emails), you may withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint — with a supervisory authority in the country where you reside, work, or where the alleged infringement occurred.

To exercise any of these rights, please contact us at official@glowbeast.co. We will respond to your request within the period required by applicable law and may need to verify your identity before fulfilling your request. There is generally no fee for exercising these rights, though we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive.

8. Additional Disclosures for California Residents (CCPA/CPRA)

This Section provides additional information for California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA/CPRA”).

8.1 Categories of personal information collected

In the preceding twelve (12) months, we have collected the following categories of personal information from California residents: identifiers (email address, IP address); internet or other electronic network activity information (browser type, pages visited, referring URL); and commercial information limited to your subscription preferences.

8.2 Sources and purposes

We collect this information directly from you when you subscribe to our newsletter and automatically when you visit the Site. We use it for the purposes described in Section 3 of this Policy.

8.3 Sales and sharing of personal information

We do 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 of California residents in the preceding twelve (12) months.

8.4 Sensitive personal information

We do not collect or use sensitive personal information for purposes that require an opt-out right under the CCPA/CPRA.

8.5 California rights

California residents have the right to know what personal information is collected, used, shared, or sold; the right to delete personal information; the right to correct inaccurate personal information; the right to opt out of sale or sharing (not applicable to us); the right to limit the use of sensitive personal information (not applicable to us); and the right not to be discriminated against for exercising these rights. To submit a request, please contact us at official@glowbeast.co. You may also designate an authorized agent to make a request on your behalf, subject to verification.

8.6 “Shine the Light” Law

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

9. Children’s Privacy

The Site is intended only for individuals who are at least eighteen (18) years of age. We do not knowingly collect, use, or disclose personal information from children under the age of eighteen (18). If you believe that we may have collected personal information from a child, please contact us immediately at official@glowbeast.co and we will take appropriate steps to delete it.

10. Security

We implement reasonable and appropriate technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit, access controls, secure development practices, and vendor due diligence. However, no method of transmission over the internet or method of electronic storage is one hundred percent (100%) secure, and we cannot guarantee absolute security.

11. Third-Party Links

The Site may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices or content of any such third party. We recommend that you review the privacy policy of any third-party site you visit.

12. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, applicable law, or for other operational reasons. When we make material changes, we will revise the “Effective Date” at the top of this Policy and, where appropriate, provide additional notice (such as a notice on the Site or, for subscribers, by email). We encourage you to review this Policy periodically.

13. How to Contact Us

If you have any questions, concerns, or complaints about this Policy or our processing of your personal information, please contact us at:

Grande Clip Korea, LLC

14-4, Garosu-gil, Gangnam-gu, Seoul, Korea

Email: official@glowbeast.co