Privacy Policy

1. Introduction

Welcome to Glena. This Privacy Policy explains how Nayra Tecnologies SAC ("we," "us," or "our") collects, uses, discloses, and protects your personal information when you use our AI CRM and customer conversation workspace, Glena ("Service").

We are committed to protecting your privacy and ensuring the security of your personal data. By using Glena, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, company name, and billing information when you register for an account.
• Profile Information: Additional information you choose to provide in your user profile.
• Communications: Messages, feedback, and other communications you send to us or through our platform.
• Customer Data: Information you upload or transmit through the Service, including customer conversations, contact information, and related metadata.

2.2 Information Collected Automatically

• Usage Data: Information about how you access and use the Service, including features used, pages visited, and time spent on the platform.
• Device Information: IP address, browser type, operating system, device identifiers, and mobile network information.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities.
• Log Data: Server logs that include information such as your IP address, browser type, referring/exit pages, and date/time stamps.

2.3 Information from Third Parties

• Integration Partners: Information from third-party services you connect to Glena (e.g., WhatsApp, Instagram, TikTok, and other messaging or business tools).
• Payment Processors: Payment information processed by our third-party payment providers.

3. How We Use Your Information

We use the collected information for the following purposes:

• Service Provision: To provide, maintain, and improve the Glena platform and its features.
• Account Management: To create and manage your account, authenticate users, and provide customer support.
• AI Processing: To power and improve our AI answer engine and agent-assisted reply suggestions, using data you choose to provide (such as product and knowledge content).
• Analytics: To analyze usage patterns, generate insights, and create reports for you and for our internal business purposes.
• Communications: To send you service-related notifications, updates, security alerts, and marketing communications (with your consent).
• Security: To detect, prevent, and address technical issues, fraud, and security vulnerabilities.
• Legal Compliance: To comply with legal obligations, enforce our terms, and protect our rights and those of our users.
• Personalization: To customize your experience and provide relevant content and recommendations.

4. Data Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party vendors, consultants, and service providers who perform services on our behalf, including:

• Cloud hosting and infrastructure providers
• Payment processors
• Customer support tools
• Analytics and monitoring services
• Email and communication platforms

4.2 Business Transfers

In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business, your information may be transferred to the acquiring entity.

4.3 Legal Requirements

We may disclose your information if required by law, court order, or governmental regulation, or if we believe disclosure is necessary to:

• Comply with legal obligations
• Protect our rights, property, or safety
• Prevent fraud or security issues
• Respond to lawful requests from public authorities

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

5. Data Security

We implement industry-standard security measures to protect your personal information, including:

• Encryption of data in transit and at rest using SSL/TLS protocols
• Regular security audits and vulnerability assessments
• Access controls and authentication mechanisms
• Employee training on data protection and privacy
• Compliance with SOC 2, ISO 27001, and GDPR standards

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining retention periods, we consider:

• The nature and sensitivity of the information
• The purposes for which we process the information
• Legal and regulatory requirements
• Our legitimate business interests

Upon account termination, we will delete or anonymize your personal information within 90 days, unless retention is required for legal, accounting, or security purposes.

7. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request access to the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information (subject to legal obligations).
• Portability: Request a copy of your data in a structured, machine-readable format.
• Objection: Object to processing of your information for certain purposes.
• Restriction: Request restriction of processing in certain circumstances.
• Withdraw Consent: Withdraw consent for processing based on consent at any time.
• Opt-out: Opt-out of marketing communications by following unsubscribe instructions in our emails.

To exercise these rights, please contact us at [email protected].

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable laws.

9. Children's Privacy

Glena is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete such information.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience. You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of the Service.

Types of cookies we use:

• Essential Cookies: Required for the Service to function properly
• Analytics Cookies: Help us understand how users interact with the Service
• Preference Cookies: Remember your settings and preferences
• Marketing Cookies: Used to deliver relevant advertisements

11. Third-Party Links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page and updating the "Last Updated" date. Your continued use of the Service after changes become effective constitutes acceptance of the revised policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

14. Data Protection Officer

For matters related to data protection and privacy compliance, you may contact our Data Protection Officer at [email protected].

15. Regulatory Compliance

We comply with applicable data protection regulations, including:

• General Data Protection Regulation (GDPR) for EU users
• California Consumer Privacy Act (CCPA) for California residents
• Peruvian Data Protection Law (Law No. 29733)
• Other applicable local and international privacy laws