Gladly

Gladly states it uses aggregated and anonymized data for service improvement, but the ToS grants a broad, perpetual license to use User Content for developing and improving services. The Privacy Policy does not explicitly prohibit training on user data, only mentions aggregation/anonymization for 'internal and external business purposes,' creating ambiguity about whether raw user content feeds AI training.

“[ToS] 'Gladly may use any aggregated and anonymized data for any purpose during or after the term of this Agreement, including, without limitation, to develop and improve the Service or other Gladly services and products.'”

The ToS grants Gladly an extremely broad, perpetual, irrevocable, sublicensable, worldwide license to use, modify, reproduce, and create derivative works of all User Content for service provision and improvement. This license survives termination and allows sublicensing through multiple tiers, giving Gladly extensive rights over company data.

“[ToS] 'You expressly grant...to Gladly, a royalty-free, fully paid-up, sublicensable (through multiple tiers of sublicensees), transferable, perpetual, irrevocable, non-exclusive, worldwide license to use, distribute, modify, reproduce, publicly display, publicly perform, and create derivative works of any...User Content...for the purposes of (a) providing the Service, or (b) developing, maintaining, supporting, or improving the Service.'”

Gladly shares data with service providers, affiliates, and partners, but the Privacy Policy indicates these are under contractual restrictions. However, the policy allows sharing with 'affiliates,' 'business partners,' and in M&A scenarios without explicit DPA requirements listed. Aggregate data sharing is permitted. Sub-processor list is not published.

“[Privacy] 'Gladly may share your information with third-party contractors, agents, collaborators, or service providers who provide certain services to Gladly or on Gladly's behalf...Gladly may share some or all of your information with Gladly's parent company, subsidiaries and corporate affiliates, joint ventures or other companies under common control with Gladly.'”

The Privacy Policy states data is retained 'only for as long as it is necessary and relevant for Gladly's operations' but does not specify concrete retention periods. Deletion is available on request but timelines are not stated. Some data may be retained for legal compliance, fraud prevention, and dispute resolution without clear limits.

“[Privacy] 'We retain information about you only for as long as it is necessary and relevant for Gladly's operations, and for Gladly's customers to work with their consumers...Gladly may also retain information collected from you to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation.'”

The ToS explicitly states that Gladly retains a perpetual, irrevocable, sublicensable license to all User Content and can create derivative works. While the company retains ownership of the original content, Gladly's broad license rights mean the company cannot assert exclusive ownership over how Gladly uses or sublicenses the content.

“[ToS] 'Subject to the rights granted to Gladly in this Agreement, as between you and Gladly, you retain all right, title, and interest in and to your User Content.' [But also] 'a royalty-free, fully paid-up, sublicensable...perpetual, irrevocable...license to use, distribute, modify, reproduce...and create derivative works of any...User Content.'”

The Privacy Policy mentions VeraSafe as Gladly's GDPR representative and references GDPR compliance, but no SOC 2, ISO 27001, HIPAA, or other formal certifications are explicitly stated. A security page or trust center is not referenced in the provided documents, and no published security practices are detailed.

“[Privacy] 'VeraSafe has been appointed as Gladly's representative in the European Union and the United Kingdom for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.' [ToS] 'Submitting to the Service or to Gladly any information that may be protected under HIPAA...is prohibited.'”