Privacy Policy

Effective date: 2026-10-29

1. Who we are

Glowapp is provided by a different company depending on where you live:

  • Comersol Soluciones Globales S.L. — European Union
  • Charlesson American Trading LLC — United States
  • Charlesson UK Consulting Group Limited — World

For you (based on your country or, if we do not know it, your language), Glowapp ("we", "us", "our") is operated by Charlesson UK Consulting Group Limited, a private company limited by shares registered in England and Wales, company number 16665273, registered address: Office 13570, 182-184 High Street North, East Ham, London, E6 2JA, United Kingdom, which is the data controller for personal data processed through glowapp.uk and the Glowapp service (the "Service").

For any privacy-related question, contact us at glowapp@charlesson.eu.

2. Scope

This policy explains what personal data we collect, how we use it, the legal bases we rely on, who we share it with, your rights under the UK GDPR and the Data Protection Act 2018 (and, where applicable, the EU GDPR), and how to exercise those rights.

3. Personal data we collect

Depending on how you use the Service we collect:

  • Account data: email address, password (stored as a salted hash), display name, username, language preference, profile photo.
  • Profile and content: bio, links, products, services, appointments, posts, media you upload to your public profile.
  • Payment data: billing email and the data your payment provider needs to process a transaction. We do not store full card numbers; payments are processed through Payment Hub.
  • Wallet and transaction data: balances and transaction history related to sales, subscriptions and tips on the Service.
  • Customer / lead data: data submitted to creators through lead forms, booking forms and checkout (the creator is the controller of that data; we act as processor on their behalf).
  • Communications: emails you send us, support tickets, and messages exchanged through the Service.
  • Usage and device data: IP address, approximate location derived from IP (country/region only), browser and device type, pages viewed, profile views, referrer, timestamps, and similar technical data.
  • Cookies and similar technologies: see section 11.

4. How we use your data and legal bases

We process personal data for the following purposes:

  • To provide the Service (create your account, host your profile, deliver messages, process payments) — legal basis: performance of a contract.
  • To process payments, prevent fraud and meet accounting obligations — legal bases: contract and legal obligation.
  • To secure the Service, prevent abuse and investigate violations of our terms — legal basis: legitimate interests (keeping the Service safe).
  • To send service emails (security alerts, transactional receipts, important account notices) — legal basis: contract / legitimate interests.
  • To send marketing emails about Glowapp features — legal basis: consent (you can withdraw it at any time).
  • To produce aggregated analytics and improve the Service — legal basis: legitimate interests.
  • To comply with legal requests and enforce our rights — legal basis: legal obligation / legitimate interests.

5. Who we share data with (sub-processors)

We share personal data only with the providers we need to run the Service. They act as our processors and are bound by data-processing agreements:

  • Amazon Web Services, Inc. — object storage (user-uploaded media).
  • Hostinger International Ltd — virtual private server hosting and outbound email (SMTP).
  • Payment Hub — payment processing.
  • Email delivery providers used for transactional and marketing email.
  • Hangzhou DeepSeek Artificial Intelligence Co., Ltd. (DeepSeek, People's Republic of China) — the AI model that generates Irene's replies: your messages, your business context and, when you ask for it, the Google data needed for that task.

We may also disclose personal data to law-enforcement authorities, regulators or courts when we are legally required to do so, or to protect our rights, users or the public.

We do not sell your personal data.

6. International data transfers

Some of our providers are located outside the European Economic Area and the United Kingdom. When we transfer personal data outside them, our default basis is the EU Standard Contractual Clauses together with the UK International Data Transfer Agreement (IDTA) or the UK Addendum to those clauses, or another lawful transfer mechanism, and we apply appropriate safeguards to keep your data protected at the level required by the EU and UK GDPR.

DeepSeek processes data in the People's Republic of China, which has no adequacy decision under the EU or UK GDPR.

7. Data retention

We keep personal data for as long as we need it for the purposes set out in this policy:

  • Account and profile data: while your account is active, and for up to 30 days after account deletion (then anonymised or deleted, except where law requires longer retention).
  • Payment and transaction records: up to 6 years after the transaction, to comply with UK tax and accounting law.
  • Usage and behavioural analytics (pages viewed, interactions, navigation patterns, device and session information): kept for up to 14 months and then deleted or anonymised.
  • Server and security logs (error traces, request logs, abuse detection): up to 90 days.
  • Marketing data: until you withdraw consent or for 24 months of inactivity, whichever is sooner.
  • Backups: encrypted backups may persist for up to 35 days after deletion from the live database.

You can ask us to erase your personal data at any time (see section 8), and we will delete the behavioural records associated with you before that period ends, subject to any legal obligation to keep specific records for longer.

8. Your rights

Under UK GDPR you have the right to:

  • Access your personal data and request a copy.
  • Rectify inaccurate or incomplete data.
  • Erase your data ("right to be forgotten") in certain circumstances.
  • Restrict processing in certain circumstances.
  • Object to processing based on legitimate interests or for direct marketing.
  • Receive your data in a portable format and transmit it to another controller.
  • Withdraw consent at any time, where processing is based on consent.
  • Not be subject to decisions based solely on automated processing that produce legal effects.

To exercise any of these rights, email glowapp@charlesson.eu. We will respond within one month.

To delete your account, go to glowapp.uk/legal/delete-account or, in the app, Profile → Delete my account.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk. If you are in the European Economic Area, you may also contact your local supervisory authority.

9. Security

We use technical and organisational measures to protect your personal data, including TLS encryption in transit, encryption at rest for backups, salted password hashing, restricted access controls, audit logging and regular security review. No system is completely secure; if a personal-data breach affects your rights and freedoms we will notify the ICO and, where required, you, in accordance with UK GDPR.

10. Children

The Service is not intended for children under 13. If you are under 13, do not use the Service or submit any personal data to us. If we learn that we have collected personal data from a child under 13 without parental consent, we will delete it. Some features (such as payments and selling) require you to be at least 18.

11. Cookies and similar technologies

We use cookies and similar technologies for: keeping you signed in (session cookies), remembering preferences (language), and measuring aggregate usage. Strictly necessary cookies do not require consent. Non-essential cookies are only set with your consent, which you can withdraw at any time through your browser settings or the cookie controls inside the Service. See our dedicated Cookie Policy at /en/legal/cookies for the full list and durations.

12. Creators using Glowapp to collect data from their audience

If you are a creator using Glowapp to receive customer data (lead forms, bookings, sales), you are the data controller of the data you collect from your audience, and Glowapp acts as your data processor for that data under a data-processing agreement incorporated into our Terms of Service. You are responsible for providing your audience with the privacy information required by law.

Contacts from your device. In Irene's chat you can choose up to 20 contacts with your phone's contact picker, or open a contacts file (.vcf or .csv) stored on your device. The file is read in your browser and is not uploaded. The contacts you choose are written into your message as text, so you can review or edit them, and they are only sent if you send that message; they are then processed like the rest of your conversation, including by the AI model providers that act as our processors. Glowapp does not access the rest of your address book. This is not a Google service. For your contacts' personal data, you are the controller and Glowapp processes it on your behalf as your processor: only choose people whose data you are entitled to share.

13. Google services integration and Google API user data

If you choose to link your Google account with Glowapp, our Service can integrate with several optional Google services, each requested and connected independently from your Google connections settings: Calendar, Tasks, Drive/Docs/Sheets/Slides, Contacts, Search Console, Analytics, and Gmail. We only request access to a given service once you choose to connect it, using the specific scopes listed below for that service. New connections can currently choose Google Calendar, Gmail (send), Google Drive, Google Tasks and Google Contacts. Search Console and Google Analytics remain available only to accounts that had already connected them; they are described below for those accounts.

Signing in with Google uses only the basic account identity (openid, email and profile) to find or create your Glowapp account. It does not grant access to Calendar, Gmail, Drive, Tasks or Contacts.

  • Google Calendar (https://www.googleapis.com/auth/calendar.events): when you ask Irene, Glowapp reads events from your primary calendar (date and time, title, location, Google Meet link, guests and who organizes an invitation) to check availability and answer you, and creates, updates, reschedules or deletes the appointments and events you approve. With your approval in the app, Irene can also change or delete an event you organize in that calendar, or answer an invitation (yes, no or maybe); if the event has guests, Google emails them the change, and your answer reaches the person who organizes the invitation. Glowapp does not invite or remove guests. We do not read other calendars.
  • Google Tasks (https://www.googleapis.com/auth/tasks): when you ask, Irene lists, creates, updates, completes and deletes tasks in your Google Tasks. Creating, changing and deleting require your approval in the app.
  • Google Drive, Docs, Sheets and Slides (https://www.googleapis.com/auth/drive.file): Glowapp can create Docs, Sheets and Slides for you, save to your Drive a file you attached in the chat, list them, read the text of a document it created, and permanently delete files it created. You can also choose files from your Drive with Google's file picker (Connect apps › Google Drive) so Irene can read them when you ask (Docs and Slides as text, the first sheet of a spreadsheet as a table, and text or CSV files); she never changes or deletes the files you choose. For the picker, your browser receives a short-lived access token limited to this permission, which is not stored. Creating, saving and deleting require your approval in the app. This permission only covers files Glowapp created or saved for you, or that you chose in the picker — never the rest of your Drive.
  • Google Contacts (https://www.googleapis.com/auth/contacts; accounts that connected it earlier for reading only keep https://www.googleapis.com/auth/contacts.readonly): when you ask, Irene looks up your contacts and, with your approval in the app, creates a contact or changes the name, emails, phone numbers, company, job title or notes of one. It never deletes contacts and writes to nobody. Your contacts' details are sent to the AI model providers in section 5 only when your request needs them, and Glowapp's activity records keep only how many contacts were read and their ids.
  • Google Search Console (https://www.googleapis.com/auth/webmasters.readonly), only for accounts that already connected it: read-only access to the search performance data of sites you own, requested using your own Google account.
  • Google Analytics (https://www.googleapis.com/auth/analytics.readonly), only for accounts that already connected it: read-only access, requested using your own personal Google account — never a Glowapp administrator account or any account shared across the platform.
  • Gmail (https://www.googleapis.com/auth/gmail.send): when you ask Irene, Glowapp can send a new message or a reply, but only after you review and approve the exact text in the app, one message at a time. This permission does not let Glowapp read, search, or modify your mailbox. Glowapp does not mark, label, archive, move or delete email, and does not create drafts. Glowapp does not keep a copy of your mailbox. If you granted an older drafts permission, you can remove it at myaccount.google.com/permissions; Glowapp no longer uses it.
  • Purpose of use: each integration is used strictly to carry out the task you connected it for (syncing your schedule, managing a reminder, creating or editing a file you asked for, sending an email you approved, etc.) — never for any purpose you have not initiated.
  • Storage and protection of credentials: We store OAuth refresh tokens securely and encrypted (AES-256) in our database, one per Google account, covering only the services you have chosen to connect. We never store copies of your private Google data beyond what is needed to carry out the action you requested.
  • Sharing: to answer what you ask, Irene sends only the Google data needed for that request (for example, that day's events, or the text of a message you asked her to send) to the AI model providers listed in section 5, who act as our processors and only use it to generate the answer. Glowapp does not sell your Google user data, does not use it for advertising, retargeting or data brokering, and does not share it with anyone else except where required by law.
  • No AI model training: Data accessed via Google APIs is never used to train, retrain, or fine-tune generalised artificial intelligence or machine learning models.
  • Limited Use compliance: Glowapp's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
  • No Glowapp staff read your Google user data unless you give explicit consent for support, it is needed to investigate security or abuse, or the law requires it.
  • Questions about your Google user data: glowapp@charlesson.eu.
  • Revocation and disconnection: You can connect or disconnect each Google service independently at any time from your Glowapp Google connections settings, or revoke Glowapp's access entirely in your Google Account security settings at myaccount.google.com/permissions. Disconnecting a service stops Glowapp from using it immediately; once no connected service remains, we delete the stored encrypted Google token.

Instagram and Facebook (Meta): if you connect your Facebook Pages and the Instagram professional accounts linked to them, Glowapp asks Meta for these permissions: pages_show_list, pages_read_engagement, instagram_basic, instagram_manage_insights and read_insights (to read your posts and their numbers); pages_manage_posts and instagram_content_publish (to publish a post or a photo); pages_read_user_content, pages_manage_engagement and instagram_manage_comments (to read the comments on your posts and reply to one); and pages_messaging, instagram_manage_messages and pages_manage_metadata (to read your Messenger and Instagram Direct conversations and reply within the 24 hours Meta allows). You can refuse any of them, and Irene then only does what you allowed. Irene publishes or replies only after you review and approve the exact text in the app, one action at a time; she never deletes, hides or edits posts or comments, does not use message tags, and Glowapp does not subscribe to Meta webhooks: it only reads when you ask. Comments and messages are written by other people and contain their personal data (their name or username and what they wrote): when you ask Irene about them, that text is sent to the AI model providers listed in section 5 only to produce the answer. Glowapp does not keep a copy of your comments or messages: what remains is what appears in your conversation with Irene, counts and identifiers (not the text) in the activity log for 30 days, the approval card (which shows the original comment or last message) for up to 30 days, and the posts and replies you approve. For your followers' and customers' data you are the controller (see section 12). A photo you publish is copied to a public address so that Meta can fetch it, and only when you approve the card. Your Meta access token is stored encrypted and is never sent to the AI model. You can disconnect Meta in Connect apps and remove Glowapp's access in Facebook › Settings › Business integrations.

Other apps you can connect (not Google): X (formerly Twitter) and LinkedIn. Nothing is connected until you connect it yourself from Connect apps. Glowapp stores the access each app grants encrypted (AES-256) in our database and uses it only when you ask Irene. What Irene reads to answer a request is sent to the AI model providers listed in section 5 only to produce that answer. X and LinkedIn process what you publish under their own terms and privacy policies, as independent controllers.

  • X (scopes tweet.read, tweet.write, users.read and offline.access): Glowapp reads your account id and username and, when you ask Irene, your latest posts with their likes, reposts and replies (if X's API plan allows it); and publishes the text you approve, one post at a time, only after you see the exact text and the account on a card in the app. It does not upload images or videos, reply, like, follow anyone or read your direct messages.
  • LinkedIn (scopes openid, profile, email and w_member_social): Glowapp reads your member id and name (the email address LinkedIn returns with these permissions is not stored) and publishes on your personal profile the text, and the link if any, that you approve, one post at a time, only after you see it on a card in the app. It does not read your posts or messages and does not post to company pages.
  • Disconnecting X or LinkedIn removes the connection in Glowapp immediately and asks that app to revoke the access; you can also revoke it in that app's own settings.

Microsoft (Outlook): you can also connect a Microsoft account, personal (Outlook.com, Hotmail) or work or school, from Connect apps. Nothing is connected until you connect it yourself. Glowapp stores the access Microsoft grants encrypted (AES-256) in our database, together with the account's id, name and email address, and uses it only when you ask Irene. Microsoft keeps processing your mailbox, calendar and contacts (and, if you turn them on, your OneDrive files, Microsoft To Do tasks and Teams channels) under its own terms and privacy statement.

  • Microsoft permissions for Outlook (scopes openid, email, profile, offline_access, User.Read, Mail.Read, Mail.Send, Calendars.ReadWrite and Contacts.Read), requested together on one consent screen when you connect.
  • What Glowapp reads, only when you ask Irene: your Outlook emails (sender, recipients, date, subject and text; attachments are only listed by name and are never opened), the events of your calendar on the dates you ask about, and the Outlook contacts that match a search.
  • What Glowapp sends, only after you review and approve the exact content on a card in the app, one action at a time: a reply to an email (always to the original sender, or to the reply-to address that email sets, shown on the card), a new email, a new calendar event (if it has guests, Microsoft emails them an invitation) and your answer to an invitation (Microsoft tells the organiser). Glowapp does not mark your email as read, move, flag or delete it, does not create drafts, and does not change or delete your contacts or existing events.
  • Optional parts, each requested only when you turn it on in Connect apps (Microsoft then asks for that permission alone, and what you already granted stays): OneDrive (scope Files.ReadWrite.AppFolder), Microsoft To Do (scope Tasks.ReadWrite) and Microsoft Teams (scopes Team.ReadBasic.All, Channel.ReadBasic.All and ChannelMessage.Send). If you never turn them on, Glowapp never asks for these permissions.
  • OneDrive: Glowapp only reaches the Glowapp folder of your OneDrive (Apps › Glowapp), not the rest of it. When you ask Irene, it lists the names, sizes and dates of the files in that folder (never their content), and it saves to that folder a file you attached in Irene's chat only after you approve a card with its name, size and folder; it never overwrites an existing file.
  • Microsoft To Do: when you ask Irene, Glowapp reads your lists and their tasks, and it creates a task (title, and the due date and note you give) only after you approve a card with the real list name. It does not complete, change or delete tasks. If the list is shared, the people you share it with will see the new task, and the card says so.
  • Microsoft Teams (work or school accounts only): Glowapp reads the names of the teams and channels you belong to so you can choose where to write, and it sends a text message, as you, to the channel you choose only after you approve a card with the team, the channel and the exact text; everyone in that channel sees it. It does not read channel messages or write in private chats. Some organisations require an administrator to approve these permissions.
  • Glowapp does not keep a copy of your mailbox, calendar, contacts, files, tasks or Teams channels: the text Irene reads to answer a request is sent to the AI model providers listed in section 5 only to produce that answer. What remains in Glowapp is what appears in your conversation with Irene (which may quote or summarise it), a short excerpt in the activity log for 30 days (with email addresses and phone numbers hidden; searches and reads keep only counts and ids), and the messages, events, files, tasks and answers you approve. Emails, events, contacts, file names, tasks and Teams names contain personal data of other people: ask Irene only about data you are entitled to process.
  • Disconnecting Microsoft removes the connection in Glowapp immediately. Microsoft does not let Glowapp revoke the access itself, so also remove it in your Microsoft account: account.live.com/consent/Manage (personal accounts) or myapps.microsoft.com (work or school accounts).

Also Pinterest, TikTok and Threads (Meta), under the same rules: nothing is connected until you connect it yourself from Connect apps, the access each app grants is stored encrypted (AES-256) and used only when you ask Irene, and each of them processes what you publish or send under its own terms and privacy policy, as an independent controller. What Irene reads to answer a request (for example, the replies other people leave you on Threads) is sent to the AI model providers listed in section 5 only to produce that answer. When you approve a pin or a Threads post with a photo you attached in Irene's chat, Glowapp copies that photo to a public web address so Pinterest or Threads can fetch it; it is not public before you approve.

  • Pinterest (scopes user_accounts:read, boards:read, pins:read and pins:write): Glowapp reads your account id and username and, when you ask Irene, the names of your boards; and creates on the board you choose a pin with the photo, title, description and link you approve, one pin at a time, only after you see them on a card in the app. It does not delete or change pins, follow anyone or read your messages. While Glowapp's app has Pinterest's trial access, the pins it creates are visible only to you.
  • TikTok (scopes user.info.basic, video.upload and video.list): Glowapp reads your account id and display name and, when you ask Irene, your latest public videos with their views, likes, comments and shares; and can send one MP4, MOV or WebM video of up to 64 MB you attached in the chat to your TikTok inbox, only after you approve it on a card. That video is not published: you finish and post it yourself in TikTok. The video is stored as a chat attachment for up to 30 days and deleted with its conversation. AI model providers receive only its name, type, size and id, not the video or its audio; Irene does not watch or transcribe it. It does not post directly, comment, like or read your messages.
  • Threads (scopes threads_basic, threads_content_publish, threads_read_replies and threads_manage_replies): Glowapp reads your account id and username and, when you ask Irene, your latest posts and the replies other people leave on them (their username, text and date); and publishes the text (and photo) you approve and answers a reply you choose, one at a time, only after you see on a card the exact text and, for an answer, the original reply. It does not delete or hide replies, like, follow anyone or read your messages.
  • Disconnecting TikTok removes the connection in Glowapp immediately and asks TikTok to revoke the access. Pinterest and Threads do not offer that to Glowapp: disconnecting removes the connection and the stored access in Glowapp immediately, and you can revoke the permission in Pinterest's or Threads' own settings.

Slack: you can also connect a Slack workspace from Connect apps, so Irene can post short messages and, if you approve them, automatic alerts in a public channel you choose. Nothing is connected until you connect it yourself. Glowapp stores the access Slack grants (a token for the Glowapp app in that workspace) encrypted (AES-256) in our database, together with the workspace id and name, and uses it only to do what you ask or approve. Slack keeps processing your messages and your workspace under its own terms and privacy policy, as an independent controller.

  • Slack permissions (scopes chat:write and channels:read): when you ask Irene, Glowapp reads the names of the public channels of the workspace, and it posts a text message in a channel, from the Glowapp app (not under your name), only after you approve a card with the channel and the exact text. It does not read any message, does not see private channels or direct messages and does not join channels: you invite the app to a channel yourself.
  • Automatic alerts: if you approve the card that turns them on, each time you get a new lead, a paid order or a booking cancelled by a client, Glowapp posts a short message in the channel you chose, and it posts a test message when you turn them on. The alerts never include names, email addresses or phone numbers of your clients (an order alert includes the title of your product; a cancellation alert, the date and time). You can stop them at any time with another card.
  • Everyone in that channel can see what Glowapp posts there. What Glowapp keeps: the channel's id and name and the events you chose (in our database, not shared with anyone), and the text of the messages you approve, which appears in your conversation with Irene.
  • If the workspace uninstalls the Glowapp app, Slack tells Glowapp and the connection is removed. Disconnecting Slack removes the connection in Glowapp immediately. Slack does not let Glowapp revoke the access itself, so also remove the app in your workspace (Manage apps).

HubSpot: you can also connect your own HubSpot account from Connect apps, so that Irene can send your leads to it as contacts. Nothing is connected until you connect it yourself. Glowapp stores the access HubSpot grants (an access token and a renewal token) encrypted (AES-256) in our database, together with your HubSpot account number, and uses it only to do what you ask or approve. HubSpot processes the contacts it receives in your account under its own terms and privacy policy, as an independent controller; you are the controller of the data of your contacts and Glowapp processes it on your behalf.

  • HubSpot permissions (scopes crm.objects.contacts.write and oauth): Glowapp can only create or update contacts in your HubSpot account. It does not read anything from HubSpot: it does not read your contacts, deals, companies or notes, and nothing you change in HubSpot changes anything in Glowapp.
  • What is sent: for each lead you approve, the lead's email address (HubSpot identifies a contact by it) and, if the lead has them, its name and phone number — nothing else from the form. A lead without an email address is not sent. If your HubSpot already has a contact with that email address, it is updated instead of duplicated.
  • Approval: a single lead is sent only after you approve a card that shows exactly those data. Optionally you can approve, with another card, the automatic sending of every NEW lead: from then on each new lead with an email address is sent by itself to your own HubSpot, and you can stop it at any time with another card. Leads from before are not sent.
  • What Glowapp keeps: for each lead sent, the id of its contact in HubSpot and whether it was sent (in our database; no names, email addresses or phone numbers), and your choice of automatic sending. If a sending fails, Glowapp tries again for up to 7 days and then tells you in Irene's inbox. Disconnecting HubSpot removes the connection in Glowapp immediately. HubSpot does not let Glowapp revoke the access itself, so also remove the app in your HubSpot settings (Connected apps).

Dropbox: you can also connect your own Dropbox account from Connect apps, so that Irene can save to it the files you attach in the chat and find them again by name. Nothing is connected until you connect it yourself. Dropbox gives Glowapp access to a single folder created for the app in your Dropbox (Apps › Glowapp), not to the rest of your Dropbox. Glowapp stores the access Dropbox grants (an access token and a renewal token) encrypted (AES-256) in our database, together with your Dropbox account id and display name, and uses it only to do what you ask or approve. Dropbox stores the files in your account under its own terms and privacy policy, as an independent controller.

  • Dropbox permissions (scopes account_info.read, files.metadata.read and files.content.write): Glowapp can read the display name of your Dropbox account, list and search by file name the files in the Glowapp folder, and save files to that folder. It does not have the permission to read the content of any file, and it does not create share links.
  • What is sent: a file you attached in the chat is sent to your Dropbox only after you approve a card that shows its name, size and folder; the name you type to search is sent to Dropbox to find file names. If a file with the same name already exists, Dropbox saves the new one under another name: nothing is overwritten or deleted.
  • What Glowapp keeps: the connection (the encrypted tokens, your account id and display name) and nothing about the files in your Dropbox: the list of names Irene finds is shown to you in the chat and is not stored. The files you attach in the chat are kept like any other attachment. Disconnecting Dropbox removes the connection in Glowapp immediately. Glowapp does not revoke the access in Dropbox itself, so also remove the app in your Dropbox settings (Security › Connected apps).

Apple iCloud calendar and contacts (this is not a Google service). If you choose to connect iCloud in Connect apps, you give Glowapp your Apple ID email and an app-specific password that you create at account.apple.com — never your Apple ID password. We check them with Apple and keep them encrypted (AES-256-GCM) in our database only so that, when you ask, Irene can read the events of your iCloud calendars (date and time, title, place and which calendar), search your iCloud contacts (name, email addresses and phone numbers; the search runs on our server and what you search for is not sent to Apple) and create in your calendar an event that you approve on a card first (it invites nobody). Glowapp only talks to Apple's iCloud servers. To answer you, only the data needed for that request is sent to the AI model providers listed in section 5, which act as our processors. We do not keep a copy of your calendars or your address book: what remains is what appears in your conversation with Irene and, in the activity log for 30 days, only counts — never event titles or contacts. Your contacts and the people in your events are personal data of other people: you are the controller and Glowapp processes them on your behalf. Disconnecting stops Glowapp from using the password at once (the encrypted record is deleted with your account); remove the password as well at account.apple.com › App-Specific Passwords. If Apple rejects the password, Glowapp stops using it immediately.

Sign in with Apple. If you choose Continue with Apple, Apple confirms who you are and sends us your email address — your real one, or a private relay address (…@privaterelay.appleid.com) if you choose to hide it — and, the first time only, the name you chose to share. We use that email to find your Glowapp account or create a new one, exactly as when you sign in with Google, and the name only as your initial display name. Glowapp never receives your Apple ID password and does not store Apple's tokens: we check them, sign you in and discard them. Apple forwards the emails we send to a private relay address to your real address. Legal basis: performance of a contract (signing you in). You can stop using Sign in with Apple for Glowapp at any time in your Apple ID settings; that does not delete your Glowapp account.

14. Connecting an AI assistant (ChatGPT, Claude and other MCP clients)

Glowapp offers an optional connector, based on the Model Context Protocol (MCP), that lets an AI assistant you choose — such as ChatGPT (OpenAI) or Claude (Anthropic) — work with your Glowapp account on your behalf. Nothing is shared with an assistant until you connect it yourself, either by signing in to Glowapp and approving the authorization screen, or by creating a personal connector token in your account settings. The assistant only ever accesses the account that authorized it.

When the assistant uses a connector tool in response to your request, it can receive:

  • Your bio links, HTML blocks and lead forms, including hidden ones.
  • Your marketplace products, including inactive ones.
  • Your appointments, including your clients' names, phone numbers, email addresses, notes and booking answers.
  • Lead form submissions, including the answers and contact details your visitors entered.
  • Aggregated statistics: profile views, link clicks and recorded earnings from sales, exclusive content and subscriptions.

The assistant can also create or edit links, HTML blocks, lead forms and products, create appointments and change their status, and change the status of leads. Some of these actions publish content on your public profile, synchronise your connected Google Calendar, or send confirmation, reminder or cancellation emails to your clients. The connector cannot make purchases, process payments, transfer money or delete accounts.

What we store for the connection: the assistant's client registration (its name and the addresses it returns to after authorization) and the authorization codes, access tokens and refresh tokens linked to your account, all stored only as SHA-256 hashes. Authorization codes expire after 10 minutes, access tokens after 1 hour and refresh tokens after 30 days (the assistant receives a new one each time it renews access); expired entries are deleted automatically. Our server logs record which connector operation was requested, when and for which account, and are kept for up to 90 days (see section 7). We do not receive your conversations with the assistant — only the tool requests it sends to Glowapp.

Recipients: the provider of the assistant you connect (for example OpenAI for ChatGPT or Anthropic for Claude) receives the information returned by the tools and processes it as an independent controller under its own terms and privacy policy, which may involve transfers outside the United Kingdom. We pass this information on only because you instructed us to by connecting the assistant; we do not sell it and do not share it with that provider for any other purpose.

Legal basis: performance of a contract (providing the connector you asked for). For your clients' and visitors' data you remain the controller (see section 12): make sure you have a legal basis to process it with the assistant you choose and that your own privacy information tells your audience about it.

Your controls: you can stop sharing at any time by disconnecting Glowapp in your assistant's settings or by pausing or deleting your personal connector tokens in your Glowapp account settings; tokens the assistant still holds then expire as described above. Deleting your Glowapp account deletes all its connector tokens. Your rights in section 8 also apply to this data.

15. Irene for Google Chrome (browser extension)

Glowapp offers an optional browser extension, Irene for Google Chrome, that opens Irene (Glowapp's AI assistant) in Chrome's side panel. It only works if you install it yourself, and it uses the Glowapp account you are already signed in to in your browser.

What the extension handles:

  • Your Glowapp session: the extension makes its requests to glowapp.uk with the session already open in your browser. It never asks for, reads or stores your password or PIN. It reads one cookie of glowapp.uk, the anti-forgery token (glow.csrf), to send it back with your requests.
  • Your messages and Irene's replies: this is the same Irene chat you have on glowapp.uk, with the same history, AI credits and approval cards. How the assistant processes and stores your messages is described in the other sections of this policy.
  • Files you attach: only when you choose, drag or paste a file (PDF, Word, Excel, CSV, text or photo), the extension uploads it to Glowapp with your session, just like the paperclip on glowapp.uk: up to 5 files per message and 10 MB each. Photos are reduced in your browser before upload. Glowapp keeps it for 30 days like any other Irene attachment, and the text extracted from it is sent, with your message, to the AI model provider (section 5). If you remove it from the tray before sending, it is deleted. The extension reads no file that you do not choose yourself.
  • The page you ask Irene to read: only when you press "Analyze this page", the extension reads the tab you are on and sends to Glowapp the page's title and address (without the query or the fragment), its description, any text you have selected and, on each press, up to about 6,000 characters of its main content: headings, lists, tables, the names of form fields (never what you have typed in them) and the text of links with their address without the query. If the page is long, each further press sends the next part. Nothing is read in the background and no page is read until you press that button. Chrome may ask you to allow access to websites the first time; if you refuse, Irene reads nothing. That text becomes part of your message to Irene: it is processed by the assistant (which relies on third-party AI model providers acting as our processors) and saved in your chat history like any other message, so do not use the button on pages that show other people's private data or your own sensitive information. You can delete the conversation from Glowapp.
  • Glowapp data for a form (optional): if you press "Glowapp data", the extension shows you the data of your business (name, email, city, short description and the address of your page) or of a recent contact (name, email and phone) and you choose which ones to use. Only the ones you choose are sent, once, with the first message of the task, to the AI model provider (section 5), and stay in the conversation like any other message. Irene cannot ask for them on her own. The extension does not keep them: they are forgotten when the task ends or is stopped, or after 15 minutes.
  • Talking to Irene (optional, extension 1.9.0): if you press the panel's microphone, Chrome asks you for permission to use it. It records until you press again, 60 seconds at most. We turn the audio into text with our own service and discard it: we do not keep your voice. The text is sent to Irene as if you had typed it. No card can be approved by voice, and Stop cuts the recording and discards it.
  • Settings: the extension keeps in your browser (Chrome storage) which Glowapp server it connects to, how Irene acts in a task (with the approved plan or asking before every action), whether you have turned on the several-tabs and notifications options, and the schedules of your shortcuts (name, text, time and repetition).
  • A PDF you ask Irene to analyze (extension 1.8.0): if the tab is a PDF, pressing "Analyze this page" downloads it with your browser session and attaches it to the message box, as if you had chosen it with the paperclip (up to 10 MB). Nothing is sent until you press send; it is then handled like any file you attach for Irene.
  • Shortcuts: if you save a shortcut, Glowapp keeps in your account the name and text you wrote (up to 800 characters, 30 shortcuts at most) so you can use it from any browser with the extension; it is deleted when you delete it or when your account is deleted. Choosing a shortcut only types its text into the box: you decide whether to send it. If you save a finished task as a shortcut, the objective and the list of steps are saved as text (the type of action and the name of the control), never what was typed on a page nor an image. If you schedule a shortcut, Chrome asks you for permission to set alarms and show notifications; the time and repetition are kept only in your browser. At that time, and only while Chrome is open, Chrome notifies you and you decide whether to send it. If you tick "Do it on her own", at that moment you approve the site you have in front of you and a limit of 12 steps: at the set time the extension opens that site, asks for the plan and approves it for you only if it fits what you approved; screenshots and steps are handled as described in "Actions on the page". Anything that needs your approval (paying, sending, deleting or leaving that site) keeps waiting for you and Chrome notifies you. You can remove the schedule at any time.
  • Notifications (optional): if you tick "Notify me when Irene finishes or needs something", Chrome asks you for permission to show notifications. The notification only says that Irene finished or needs your approval, and only when the panel is not in front; it never includes the objective, addresses or what was typed. When you untick it, the extension gives the permission back to Chrome.

What the extension does not do: it does not track your browsing and it does not keep a history of the pages you visit. When you ask it to look at the tab or to run a task, it does send and store the origin and path of that tab and of the tabs in that task's "Irene" group (not the query and not the fragment), not the full address and not the other pages you open. It does not read pages you do not ask it to read, does not include advertising or analytics, does not load or run code from outside the extension, and does not sell or share your data with anyone other than as described in this policy.

Actions: Irene may propose changes in Glowapp from the side panel (for example to your bio or your links). They only happen if you press "Approve" on the card.

Screen capture: when you press "Look now", Chrome asks for access to the sites you visit. If you refuse, no image is taken. If you accept, the extension takes one image of the tab in front (it does not switch tabs) and sends it to Irene as an ephemeral attachment. Glowapp receives that page's origin and path, without the query or the fragment. The image is not kept: it is deleted when you press Stop or when the session expires (15 minutes at most). What is kept, for 24 hours, is a short sentence that Irene writes about each screen she looks at (what was visible, with the site and the path of the page without the query) so she can compare them within a task. Before saving it, Glowapp masks emails, phone numbers, long numbers, codes and keys. You can see and delete them, one by one or all of them, in the panel settings, and they are deleted when your account is deleted. Those sentences are sent, as part of the context of your messages, to the AI model provider (section 5). No person reads that image except where this policy already allows access to your account. It is not used for advertising. The AI model provider processes it as our processor, the same as other images you send to Irene. Nothing is captured in the background. Nothing is captured on banks, payment gateways, crypto sites, webmail, password managers, government sites (including tax offices), the Chrome Web Store, browser-internal pages, local files, or private-network addresses. If a password field or a card field is visible, including inside a same-site frame, nothing is captured. A frame from another site that the browser will not let us read is not inspected: you are warned, and Irene will not type on that page. Fields inside a closed shadow tree are not reviewed.

Actions on the page: you can describe a task (“fill in this form”) and approve once the plan: the objective, the sites she may act on, and a step limit (at most 12 steps and 8 minutes). Inside those sites and the task's tabs, Irene continues on her own (look, decide, act, look again) and the panel lists each step. Several tabs: when you press "Start task", Chrome asks you for permission to open and group tabs and to access websites. If you accept, Irene can open tabs and switch between them inside a Chrome group called "Irene" (up to 8), only on the sites of the plan; any other site asks for a card. At each step the extension sends Glowapp the site and path of each tab in the group, without the query, the fragment or the title. Tabs opened by the task are not closed automatically. If you do not grant the permission, or you turn off "Several tabs" in the settings, the task stays on the tab in front. During the task Irene can also search the web and read public pages from Glowapp's servers, as on glowapp.uk; what she reads is third-party information, not instructions. Stop discards proposals that have not run yet and deletes the frames. It does not undo a click or typed text already sent to the page, and a wait that has already started finishes its timer (between 0.2 and 3 seconds). Submitting or publishing a form, buying or paying, deleting, changing permissions or account settings, sending a message or an email, downloading, uploading a file, or opening a site that was not in the plan asks for a card again. So does any click that is not clearly for reading. Reading means a tab or an accordion that is not a submit or reset button, is not inside a form, is not an input, has no click handler, and points with aria-controls at a panel that exists on the page. An in-page link (#) also asks for a card: the extension cannot see the handlers that the page adds with JavaScript. A button that says “Confirm order” or a control that says “Publish” asks for a card even with type=button or role=tab. Before she acts, the extension sends the real control (its type, role, whether it sits in a form, a short visible label, aria-label, and the link as origin and path only) and the server recalculates from those same facts: it does not see the page. If the two answers differ, or the control’s label, type, role, accessible name, text, form, link, aria-expanded, handler or panel changed before the click, she asks for a card. That card shows what the server validated (the kind of action, the text to type or the address, and the element: role and accessible name), not free text written by the model. It runs only if you approve, and only if the tab, the origin and the element are still the same. The card expires after two minutes, can be used once, and its id is not predictable. She does not type into a password or card field, including inside a same-site frame, and she never types a password, a card security code, a card number, an IBAN or text that looks like one; a frame from another site that cannot be read blocks typing. She does not act on Glowapp’s own admin, dashboard, payment, settings, account-deletion or credential screens (/admin, /superadmin, /dashboard, /app, /checkout, /v2-checkout, /billing, /donate, /facturacion, /factura, /pedido/…/reembolso, /account, /settings, /ajustes, /configuracion, /auth, /login, /password, /credentials, /reset-pin, /forgot-pin, /unsubscribe, /legal/delete-account, /citas/cancelar, /citas/reprogramar, /citas/recordatorio/baja), including when a language prefix comes first (/en/admin). The rest of glowapp.uk can be a task site. She does not download, install or change browser permissions on her own. Page text and anything read from the image are information, not instructions. At least 2 usable AI credits are required (from a Pro or Pro+ plan, or bought). A balance of 1 credit is not enough. Without credits, the server does not call the model. The card and the panel state the cap in credits, never in euros: each look reserves at least 2 credits (at most 24 across those steps, plus the turn that prepared the plan). While she is reading that tab she only has the tools for that tab. The chat trace of a screen step stores the origin, the kind of action and a short result. It does not store what was typed, the full address, the page title, or the selector the model chose. When the task finishes or you press Stop, a text summary is saved in the Irene conversation that was open (what you asked, the kind of each step that actually ran, on which sites, and what is left), without the image, without what was typed, and without the full address. If that conversation cannot be confirmed as yours, the summary is not written. Uploading a file: if you approve an "upload a file" card, the extension downloads from Glowapp, with your session, a file you attached (up to 10 MB; never a screenshot or a keys or credentials file) and places it in the file field of the page you are viewing. The page that receives it handles it under its own policy, not Glowapp's. It does not submit the form: submitting it asks for another card. Typing into a difficult field (optional, extension 1.9.0): if a website does not let her type or choose an option in a field the normal way, the panel offers you "Allow and retry". With that click Chrome asks you for a debugging permission and the extension types into that field the text of an already approved step as if it were typed on the keyboard, only on the task's tab and never on banking, email, sign-in or settings pages. With that permission it does not read the page. While it is active, Chrome shows its debugging notice; it is released when you stop or finish the task.

Use of the information: what the extension obtains from the pages you choose is used only to answer your request and to show you the result. Glowapp does not use it for advertising, to build profiles, or to train AI models, and does not transfer it except to the processors described in this policy that make the assistant work.

Legal basis: performance of a contract (the assistant you asked for) and, for the text of a page, your own action of pressing the button. Your controls: uninstall the extension in Chrome, close the panel, revoke its access to websites in chrome://extensions, and delete the conversation in Glowapp. Your rights in section 8 also apply.

15.1 Irene's browser on Glowapp's servers (this is not the extension). Besides the extension, Irene can open and use public web pages in a browser that runs on Glowapp's servers. That browser does not use your Chrome, your cookies or your accounts: each session starts empty and nothing is kept when it closes. Irene reads at most 20,000 characters of each page and takes at most 40 actions per session; anything that sends something (a form, a purchase, a booking, a message) asks for your approval on a card first. Banking, payment, crypto and password-manager websites are blocked.

When a page asks for a password, a payment, a verification code, a captcha or a file, Irene stops and shows you «Take control»: you see the page live and type yourself. What you type travels through Glowapp's servers to that page and Glowapp does not store it. What you type into a password, payment or verification-code field is never sent to the AI model; text you type into other fields (for example your email address) stays on the page, and Irene can see it when you give control back. The live image of the page is not stored. A session closes after 5 minutes without activity and after 30 minutes at most, and it is deleted when it closes. If you prefer not to type payment details there, do it directly on the provider's website.

16. Irene helps you with your phone (screenshots, screen sharing and sharing from other apps)

Glowapp offers optional features that let you show Irene (Glowapp's AI assistant) what is on your phone's screen so she can explain what to do. Nothing is shared unless you start it yourself, and you can stop it at any time.

  • Screenshots ("Help me with a screenshot"): the image you choose or take is sent with your message to Irene and used only to answer you. It is not saved to your files: it is kept in short-term memory for up to 15 minutes and removed when the message is saved. Your chat history keeps only the text "Screenshot from HH:MM".
  • Screen sharing ("Show my screen", Glowapp Android app): you start it, Android shows its own consent screen and a notification with a "Stop" button for as long as it lasts. Glowapp takes one still image only when you press "Look now" (in the chat, or in the notification when you are in another app) or when you speak during the call (one image per sentence, see below); never a video, at most one every 3 seconds and 120 per session, and the session ends by itself after 15 minutes. Screens that Android protects (such as banking or password screens) come out black and are not sent. Pressing "Stop" or closing the chat ends it and deletes that session's images.
  • Talking to Irene like a phone call (Android app, optional): if you grant the microphone when you start sharing, the session is a call. While it lasts, the app listens and, each time you finish speaking, sends what you said to Glowapp together with an image of your screen at that moment. It does not listen to you while Irene is speaking, except to know whether you want to interrupt her: if Glowapp is open in front, the microphone is opened only to measure the volume and silence Irene if you speak over her; that is not recorded or sent anywhere. You can tap "Mute" or "Hang up" in the notification at any time, and it mutes itself after 3 minutes without you speaking. We turn the audio into text with our own service and discard it: we do not store your voice. The text goes with the image to Irene as one more message in your conversation, and her answer is read out loud with our own voice (today Irene's voice exists only in Spanish; in other languages the answer is shown in writing). If you do not grant the microphone, you can still share your screen and use "Look now". Do not show screens with passwords, codes, card details or other people's private data, and keep in mind that during the call what is said near the phone may reach Irene.
  • Irene's answer in the notification (Glowapp Android app; optional, on by default, and you can turn it off in the screen-sharing banner): if you press "Look now" in the notification while you are in another app, Glowapp sends that one image to Irene with the question "What do I do now?" and shows her answer in the same notification as plain text (at most 400 characters, without links). The question and the answer stay in your Irene conversation like any other message. Cards that need your approval are never shown or approved from the notification: you see them in Glowapp. If the answer does not arrive, the notification asks you to open Glowapp.
  • Sharing with Irene (Glowapp Android app): when you choose Glowapp in Android's "Share" menu, the app receives only what you chose to share (text or a link, photos, PDF, CSV or a contact card), with the permission Android gives for that share; it does not ask for access to your files. It keeps it only in the phone's memory (at most 5 files of up to 10 MB each, for 10 minutes at most) and puts it in Irene's message box: the text in the message, and the files as attachments that are uploaded and kept like any other attachment you add to the chat. Nothing reaches Irene until you press Send, and you can remove anything first.
  • What Irene can and cannot do: she can look at the image, explain and point at a place on it. She cannot tap, type or open anything on your phone. The only thing she can propose is opening Glowapp's own notification or app settings screen, and only if you approve a card.
  • What we keep: a short record of each session without images (when it started and ended, how many images, how it ended and which settings screen was opened, if any), for up to 90 days to protect your account; it is deleted if you delete your account.
  • Who receives the images: the AI model providers listed in section 5, only to answer you. Glowapp does not sell them, does not use them for advertising or profiling, and does not use them to train AI models.

Do not show screens with passwords, verification codes, bank or card details or other people's private data. You can stop at any time with "Stop", from the Android notification or by revoking screen capture in Android. Legal basis: your consent when you start the feature, and providing the service you asked for.

17. Phone number and "Contacts on Glowapp"

You can add your phone number in Account › My profile. It is optional, is not shown to anyone and is not verified; we keep it while your account exists and you can delete it at any time. It lets people who have your number in their address book know you use Glowapp and message you.

If you use "Contacts on Glowapp", you choose where your address book is read from (Google Contacts, a file, or your phone's contacts). We send our servers only the emails and phone numbers of those contacts, solely to check which ones have an account; we neither store nor log them. The only thing we keep is the result: which of your contacts use Glowapp (each one's account; never their emails or phone numbers, nor the name under which you saved them). We keep it so we can show them to you when you open "New chat" without you having to search again; only you can see it, it is kept while your account exists, and you can delete it at any time from that same screen. For people who already use Glowapp we show their username, name and profile photo.

If someone else has your email or phone number in their address book, they can find you this way. If they find you, you will be in their saved list of contacts until they delete it or either account is deleted. We do not notify anyone that you appeared in their list. We do not receive the names under which you saved your contacts.

18. US State Privacy Rights

DRAFT pending legal review.

Charlesson American Trading LLC, a Delaware limited liability company ("we"), operates Glowapp for users in the United States. We do not sell your personal information, we do not share it for cross-context behavioral advertising, and we do not use or disclose sensitive personal information for purposes other than those permitted by law.

Depending on your state of residence (for example, California, Delaware or Texas), you may have the right to:

  • know and access the personal information we hold about you;
  • correct inaccurate information;
  • delete your information;
  • obtain a portable copy;
  • opt out of targeted advertising, sale or sharing, and certain profiling;
  • not be discriminated against for exercising these rights.

How to exercise your rights: email glowapp@charlesson.eu or use the contact page at glowapp.uk/legal/contact. We will respond within 45 days (extendable once by 45 days where permitted). We may need to verify your identity. You may use an authorized agent. If we deny your request, you may appeal by replying to our decision; if the appeal is denied, you may contact your state attorney general.

Opt-out signals: we honor Global Privacy Control. If your browser sends it and you have not made a choice in our cookie notice, we load no analytics or advertising tool and do not ask again.

Children: Glowapp is not directed to children under 13 and we do not knowingly collect their personal information. Contact us to request deletion.

Retention: we keep analytics data for up to 14 months and account data while your account is active, unless the law requires otherwise.

Service providers: we use providers to host the Service, process payments, send emails and provide AI features; section 5 lists them.

19. Irene, the homepage assistant

If you chat with Irene on our website before creating an account, we keep your messages and her replies, a short automatic summary of the conversation and the page you wrote from, for 90 days, to improve the service and understand what visitors ask. Before saving your messages we automatically mask email addresses, IBANs and long numbers (phone numbers, cards).

We do not store your name or your IP address with the conversation, and the conversation is not linked to any account, even if you sign up afterwards.

Irene is an AI: her replies are generated by an external AI provider that receives the text you type (sections 5 and 6 list our AI providers and the international transfers). Please do not share passwords or card numbers with her.

You can write to us at glowapp@charlesson.eu about your data; section 8 explains your rights.

20. Changes to this policy

We may update this policy from time to time. The effective date at the top of this page indicates when it was last updated. If we make material changes, we will notify you by email or through the Service.

21. Contact

Charlesson UK Consulting Group Limited

Registered address: Office 13570, 182-184 High Street North, East Ham, London, E6 2JA, United Kingdom

Privacy: glowapp@charlesson.eu

Support: glowapp@charlesson.eu

Charlesson UK Consulting Group Limited · Company No. 16665273 · Office 13570, 182-184 High Street North, East Ham, London, E6 2JA, United Kingdom