Privacy Policy

This Privacy Policy (“Policy”) explains how Discountopia doing business as Glasy (“Glasy”, “we”, “us”, “our”, etc.) collects, uses and discloses Personal Data (as defined below) of customers and merchants on our mobile application, website located at: www.joinglasy.com, or the various associated websites, platforms or applications (collectively and each individually, the “Glasy Platform”).

At Glasy we are committed to protecting the privacy of everyone in our community and who makes use of our services. By visiting and/or using the Glasy Platform, you consent to the collection, use, storage, disclosure and transfer of your Personal Data as set out in this Policy. In some cases, we may ask you to provide explicit consent if we intend to process your Personal Data otherwise than as indicated in this Policy, however sometimes your consent may be implied through your conduct with us.

Restaurants, convenience stores, grocery stores and other businesses that offer products (“Partners”) on the Glasy Platform may offer their products for delivery directly through the Glasy Platform, or may use the Glasy Platform to provide services for orders placed on the Partner’s own website, application or ordering platform. In such circumstances, we will process data received from such Partners in accordance with this Policy.

If you do not agree with any part of this Policy, you should not conduct any transactions on the Glasy Platform, navigate away from the Glasy Platform immediately, and uninstall our application.

What and why we process personal data

Personal Data (or “your Data”) means any information or set of information from which we are able, directly or indirectly, to personally identify you, in particular by reference to an identifier e.g. name, email address, phone number, etc. Personal Data does not include data where the identity has been removed (anonymous data). Whenever you interact with the Glasy Platform we collect and process your Personal Data. Glasy may process your Personal Data for the following purposes:

1. Customer Accounts

If you interact with the Glasy Platform you are given the opportunity to create an account with us. We use this information to administer your account, enable your access to the Glasy Platform, verify your identity as an authorized user concerning your account, and to implement, carry out and maintain security measures aimed at protecting our customers from identity theft, fraud and unauthorized access to an account. The following Personal Data must be provided by you when you sign up for an account:

• Name
• Contact data
• Password of your selection

You may choose to register for an account with us via a third-party social media network, including Facebook, Apple and Google (“Social Media”). If you do so, you authorize us to access certain Social Media account information consistent with your Social Media privacy settings, including your name. We use this information to administer your account, and to enable your access to the Glasy Platform.

At the time of signing up for an account, we also automatically collect your IP address and device information.

2. Ordering process

We process the Personal Data you provide to us when you place an order. This Personal Data is needed to confirm and execute your order, and to process your payment, and a possible refund (if applicable). We process the following Personal Data in the ordering process:

• Name
• Delivery address data
• Contact data
• Order and transaction data
• Payment data
• Age verification data

At the time of placing an order, we also automatically collect your IP address and device information, to help protect against theft, fraud and unauthorized access to an account.

We collect your order history including the date, time, cost, order type, and, physical address method of purchase, and order details, including specific food items ordered and special order instructions. We use this information to ensure that your order has been completed, to allow you to select previously entered addresses for future deliveries and to improve our service offerings.

Please be aware that if you submit an order for alcohol, you will be asked to provide government-issued identification upon delivery, and Glasy may process age verification data (such as your date of birth), to confirm that you are of legal age.

Payment operations are outsourced to our payment processors and we do not store your credit card information in our systems other than the first four and last four digits of the credit card number.

3. Partner reviews

We may offer you the opportunity to submit a review of Partners on the Glasy Platform. We may process the following Personal Data when you post a review:

• Name
• Contact data
• Review

When your review is published, the review, your first name and the initial of your last name, may be made available to Partners. Partners may be provided with the opportunity to respond to your feedback. You also consent to us using such reviews (but not your name and contact information) in any marketing or advertising materials.

4. Customer services and support

When you contact our customer services support, we will use the Personal Data you provide to answer your question or handle your complaint. We process the following Personal Data for customer service purposes:

• Name
• Address data (if applicable)
• Contact data
• Order and transaction data
• Payment data (if applicable)
• Comments and Communications Data (if applicable)

We may process Personal Data via call recordings to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.

We retain the above information to assist you in the future and to improve our customer service and service offerings, and for training and quality purposes.

5. Social media:

We may offer you the opportunity to otherwise engage with Glasy or its content on or through Social Media. When you engage with us through Social Media websites, plug-ins and applications, you may allow us to have access to and disclose certain information associated with your Social Media account (e.g., name, username, email address, profile picture) to deliver content or as part of the operation of the website, plug-in or application.

6. Loyalty programs

Glasy offers loyalty programs to provide you with discounts. When you make use of one of our loyalty programs, we process your Personal Data to provide you with the discounts or offers as set out in the respective loyalty program. Such processing may include but is not limited sharing such Personal Data with the merchants on the Glasy Platform.

We process the following Personal Data for Glasy Loyalty Rewards:

• Address data
• Order history
• We process the following Personal Data for “Refer a Friend”:
• Your name and contact data
• Name and contact data of the recipient

We do not use the names or contact data submitted in these circumstances for any other purpose without the consent of you or the email recipient to do so. Please ensure that you only submit contact data of individuals with whom you have a personal or family relationship and who would want to receive the message.

7. Customer research

To make sure that our services are aligned with your preferences and to improve our services and platforms, Glasy may approach you to conduct customer research such as but not limited to, surveys, user testing and focus groups. We only send you these types of communications with your prior consent, unless this is not necessary according to the applicable law. Participation in the customer research is completely voluntary. If you do not wish to receive communications about customer research you can unsubscribe from them in the messages itself. Glasy may process the following Personal Data for research purposes:

• Name
• Contact data
• Order and transaction data
• Research input

8. Analytics

Glasy uses your Personal Data to create data in aggregate and/or de-identified format to conduct internal analytics, improve the Glasy Platform including our range of products and services and any other legally permissible purpose.

9. Marketing and other communications

We process your Personal Data to send you (personalized) marketing messages and notifications. Such messages include the latest news, discounts, products and services (including offers of products, services and discounts from select third parties, as described below under “Sharing with others”), updates about new Partners and other communications that may be the subject of direct marketing. We may contact you by telephone, SMS/MMS and email and if you use our mobile application, via push notification.

We will not send you any direct marketing communications unless you have separately consented to receive such communications or such consent has been deemed to have been given under applicable law. If you no longer wish to receive direct marketing communications, you can opt-out using the unsubscribe mechanism in the marketing communication itself (e.g. by clicking the unsubscribe link at the bottom of an email or by replying with the word “STOP” to an SMS/MMS or by following other provided instructions). To manage push notifications, go to the settings page of your phone or tablet and change the push notification permission for the Glasy app. If you switch off in-app push notifications, you will no longer receive updates on your orders via push.

Glasy uses cookies and similar technologies to show you personalized ads targeted to your interests (“Interest-Based Advertising”). To learn more about Interest-Based Advertising, or to opt out of online interest-based advertising from a list of companies participating in the Digital Advertising Alliance of Canada at any time, visit http://youradchoices.ca/choices. To learn more about Interest-Based Advertising in mobile apps and to opt out of this type of advertising by third-party advertising companies that participate in the DAAC’s AppChoices tool, please download the version of AppChoices for your device at https://youradchoices.ca/appchoices/.

On your mobile device, you may choose the “Ask App not to Track” setting (in iOS devices) or a setting to “Opt-out of Interest-Based Ads” (on Android), which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.

As part of our Interest-Based Advertising, we may use services provided by third-party platforms (such as Social Media and other websites) to serve targeted advertisements on such platforms to you, and we may provide a hashed version of your email address or other information to the platform provider for such purposes.

To opt in or out of the use of your information for Interest-Based Advertising you can toggle the Marketing Cookie “on” or “off” in the Cookie Settings in your Glasy account. Please be aware that, even if you opt out of Interest-Based Advertising, you may continue to receive ads from us, but they will not be served using interest-based information about you. Also, to successfully opt out, you must have cookies enabled in your web browser. If your browser is configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser, your opt-out instruction may not, or may no longer, be effective. Your opt-out selections only apply to the web browser you use so you must opt out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt out again.

We may also process your Personal Data to notify you occasionally about important changes or developments to the Glasy Platform, products, services or your account. You cannot opt out of receiving notifications of important changes or developments (e.g., to this Policy or the Terms of Service/Use) unless you discontinue use of the Glasy Platform.

We process the following Personal Data for marketing and communication purposes:

• Name
• Address data
• Contact data
• Order and transaction data
• Review(s) (optional)
• Campaign data (optional)
• DeviceID
• Cookie and Technology data

10. Cookies and App analytics

Glasy and its third-party service providers use cookies or similar technologies for functional, analytical, and marketing purposes. A “cookie” is a tiny element of data that the Glasy Platform can send to your browser, which may then be stored on your web browser or mobile device so we can recognize you when you return. Data processed for cookie purposes defer per purpose (functional, analytical or marketing) and depend on the preferences set by you.

Please see the “Marketing and other communications” section for more information on how Glasy uses cookies for marketing purposes.

Functional Cookies are used to ensure our website remembers your choices and provides better functionality and personalized features. For example, cookies make it possible to remember your delivery address.

Analytical Cookies are used to improve our website and our visitors’ experience by analyzing the behaviors and usage patterns of visitors to the Glasy Platform. Glasy uses Google Analytics to collect, process, store and analyze information when you visit the Glasy Platform, including IP address, your location when the Glasy mobile application is used, device identifiers, browser characteristics, operating system details, language preferences, referring URLs, length of visits, pages viewed and other related information. You can obtain additional information on Google Analytics’ collection and processing of data and data privacy and security, including how to learn more about opting out of Google Analytics’ data collection by visiting the Google Analytics website.

You may set your web browser or smartphone to notify you when you receive a cookie or to not accept certain cookies. It is also possible to delete already placed cookies. By disabling cookies, it is possible that parts of our website will no longer work. By clicking on one of the links below you will find how you can change your settings per browser and possibly delete your cookies:

• Chrome
• Firefox
• Internet Explorer
• Edge
• Safari (iOS)

Cookies that are needed for our website and its features to function (Necessary Cookies) cannot be deactivated.

11. Campaigns

From time to time, Glasy may launch contests, sweepstakes or promotions (“Campaigns”) in connection to its services. Joining Glasy campaigns or contests is always on a voluntary basis. Glasy processes the following Personal Data for the purposes of administering your participation in the Campaign:

• Name
• Contact data
• Order and transaction data (optional)
• Campaign data (optional)

12. Fraud prevention/detection and network security

We process Personal Data to implement, carry out and maintain security measures aimed at protecting ourselves and our customers from identity theft, fraud and unauthorized access to an account, and to prevent and/or detect fraud and other forms of misuse on the Glasy Platform. Personal Data processed for fraud prevention and detection and network security purposes are:

• Name
• Order and transaction data
• Payment data
• Browser information
• IP Address
• Device information
• Communications Data

13. Use of Glasy Loyalty Rewards

We process Personal Data if you use your Glasy Loyalty Rewards allowance to pay for an order you placed on the Glasy Platform and to provide you with the digital allowance.

The following Personal Data may be processed in connection with Glasy Loyalty Rewards:

• Name
• Contact data
• Allowance data
• Order and transaction data
• Payment data

Other data related to your usage of Glasy Loyalty Rewards, to operate Glasy Loyalty Rewards and to provide you the Glasy Loyalty Rewards service.

14. Gift cards

When you purchase a gift card for use on the Glasy Platform, your payment card information (including payment card number, security code, expiration date, cardholder name and billing address) is transmitted using the secure services of our payment processors for the purposes of processing your payment. We collect the gift card sender’s email address and recipient’s name and email address. We use this information to deliver and manage the gift card.

Additional purposes

We will only use your Personal Data for the purposes described above. If we want to use the data for a different purpose, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Where required by applicable data protection law, we will obtain your consent.

Age

This Glasy Platform is not intended for persons defined as underage by applicable local laws, nor do we intend to collect Personal Data of website visitors who are under the defined legal age. However, we are unable to verify visitors’ ages. We therefore advise parents and/or legal guardians to monitor their children’s online activities, to prevent their Personal Data being collected without parental consent. If you feel that we have collected Personal Data of a minor without consent, please email or write to us at the contact information set out below.

Automated decision-making

In the performance of our contract with you and to improve our platform, Glasy and its service providers uses Personal Data to render decisions based exclusively on automated processing for the following purposes:

• Provide our services to you (for example, Glasy uses your address data and/or location data to show you available Partners in your local area);
• Customer service purposes (for example, using chatbots);
• Network security and fraud detection/prevention purposes.

Please see below for information on how you can submit your observations regarding the automated decision making which affects you or when such automated decision-making and/or profiling leads to a negative decision about you, and you do not agree with it.

How long we store Personal Data for

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting, or reporting requirements. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personal information, or if required or permitted by law. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and applicable legal and contractual requirements.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Sharing with Partners on the Glasy Platform

Glasy will share your Personal Data (order, name, and telephone number) with the Partner you selected, so that the Partner can process and prepare your order.

Sharing data for Glasy Loyalty Rewards

If you use your Glasy Loyalty Rewards allowance to pay for an order you placed via the Glasy Platform, Glasy shares your Personal Data with the person that grants you the allowance (which might be your employer, business partner, etc.). The person that grants you the allowance has their own responsibility and obligation with respect to the processing of your Personal Data. The person that grants you the allowance also shares your Personal Data with us to allow us to provide Glasy Loyalty Rewards services to you.

Sharing with others

Glasy may work with other third parties and service providers in order to carry out the processing described above and/or to comply with legal obligations.

These group of companies and service providers will process your Personal Data on behalf of us and have access to your Personal Data for the purposes described in this privacy notice, including processing credit card payments and providing services or products to us.

We may share your Personal Data with select third parties, including Partners, advertising and marketing companies and promotional partners, so that we or they may contact you about our or their products or services that may be of interest to you (subject to compliance with Canada’s anti-spam legislation). Such third parties may contact you by mail, telephone, mobile messaging (e.g. SMS, MMS, etc.) or email. If you change your mind about being contacted by these parties in the future, please let us know by using the contact details set out at the end of this Policy or by following other provided instructions.

From time to time we use your information (e.g. specific contact data or aggregated order data) to help us and our third parties understand users of the Glasy Platform, the effectiveness of the order and delivery services and to enhance our and our partner’s product and service offerings.

By submitting your Personal Data, you agree to the transfer, storing or processing as described above. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

Additionally, we may use the Personal Data that you provide to us if we are under a duty to disclose or share your Data in order to comply with (and/or where we believe we are under a duty to comply with) any applicable legal obligation; or in order to enforce the Terms of Service/Use and any other agreement we have with you. This includes exchanging Personal Data with other companies and other organizations for the purposes of fraud protection and prevention. We and our service providers may use or disclose your Personal Data in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable law or legal process. Your Personal Data may also be used or disclosed where necessary or desirable for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your Personal Data may be disclosed or transferred to the target company, our new business partners or owners or their advisors provided that the information disclosed continues to be used for the purposes permitted by this Policy by the entity acquiring the information.

Your Personal Data may be shared with the following parties:

• Software providers
• Advertising and marketing companies, and promotional partners
• Implementation partners
• Hosting partners
• Payment and card service providers
• User testing, survey and research partners
• Professional advisors
• Law enforcement, regulatory bodies and/or government agencies
• Prospective buyers
• Any other third party provided that you have given your consent to the disclosure
• Third-party websites

Our website and mobile application may include links to third-party websites. When you click on such a link, you will leave our service and go to another site. When accessing such third-party websites, bear in mind that each of these websites has its own privacy statement and Glasy is not responsible for the collection, use or disclosure of Personal Data by such third party websites. Although Glasy takes great care in selecting websites to link to, we cannot take responsibility for the way in which they handle your Personal Data.

Where your data gets sent

The Personal Data you provide to us will be held on our servers which may be in Canada or Germany. In addition, your Personal Data may be accessed by or provided to our staff working outside of Canada (and outside of Quebec) and/or to service providers and/or to third parties and act for us for the purposes set out in this Policy or for other purposes notified to you.

While your Personal Data is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. Certain countries outside Canada and the European Economic Area do not always have equivalent strong data protection laws irrespective of the safeguards we have put in place for the protection of your information in accordance with this Policy.

When we transfer Personal Data outside of Canada (and outside of Quebec) we will take into account any applicable statutory obligations relevant to Personal Data transfers and rely on appropriate safeguards.

Personal Data Rights and questions or complaints

You can exercise the rights provided for by applicable data protection laws, which may include: the right to request access to and/or rectification of your Personal Data, the right to cease dissemination (in Quebec), the right to submit observations of automated decision making (in Quebec) and the right to withdraw your consent (subject to legal and contractual restrictions and provided that reasonable notice is given to us), as well as to lodge a complaint with a regulatory authority directly (collectively, “Personal Data Rights”). Your Personal Data Rights are subject to certain exceptions and restrictions prescribed by law.

To exercise your Personal Data Rights or submit a question (including any questions you might have about Glasy’s governance policies and practices regarding Personal Data) or complaint, please email or write to us at the contact information set out below. We may request certain information from you for the purposes of verifying the identity of the individual seeking access to their Personal Data records and may restrict access to certain Personal Data as required or permitted by applicable law or legal process.

If you withdraw your consent to receive information regarding certain products, publications, services or events being offered by Glasy, you will no longer receive those types of communications.

Security

Glasy takes Personal Data protection very seriously and we therefore take appropriate administrative, technical and physical measures to protect your Personal Data against misuse, loss, unauthorised access, unwanted disclosure, and unauthorised alteration. The transmission of information via the internet is not completely secure. Although we will take steps to protect your Personal Data, we cannot guarantee the security of your Personal Data or other data transmitted to the Glasy Platform; any transmission is at your own risk.

How to contact us

If you have any questions or concerns about this Policy and/or our privacy practices, or if you would like to exercise your Personal Data Rights or submit a concern or complaint, please contact us at:

• [email protected]

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. Your continued use of the Glasy Platform after any change of our Policy will constitute your acceptance of the revised terms of this Policy.

We encourage you to periodically review this Policy for the latest information on our privacy practices. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Where required by applicable data protection law, we will obtain your consent to any material changes to this Policy.

This Privacy Policy was last updated on September 20, 2023.