Platform Terms of Use

Version:: 2026.04
Effective from:: April 01, 2026

Accepted by franchisors, franchisees, managers and sellers when accessing the Glivo platform within the European Union / European Economic Area.

Company identification

The Glivo platform is developed and operated by Glivo LLC, a limited liability company incorporated under the laws of the State of Wyoming, United States of America, with its registered office at [address to be completed].

The platform is offered globally. For users located in the European Union / European Economic Area, Glivo LLC has appointed an EU Representative under Article 27 GDPR, as set out in the Privacy Policy.

Glivo processes personal data in secure data centers, operated by cloud providers with internationally recognized certifications (ISO 27001, SOC 2 or equivalent), as detailed in the Privacy Policy.

Before accepting

By creating an account, signing in or using the application, the web dashboard, the APIs or any other functionality of Glivo, the user declares that they have read, understood and accepted in full these Terms of Use and the Privacy Policy.

If you do not agree with any of the provisions below, do not use the platform.

Glivo may update these Terms at any time, notifying users with reasonable advance notice. Continued use of the platform after notification implies acceptance of the new version.

1. Definitions

Glivo: technological platform for recording, transcription and AI-based analysis of commercial interactions, developed and operated by Glivo LLC (Wyoming, USA).
Platform: the mobile application, the web dashboard, the APIs, integrations and other functionalities made available under the Glivo brand.
User: any natural or legal person who accesses or uses the platform.
Franchisor: the network that contracts the platform for use by its franchises.
Franchisee: the natural or legal person holding a franchise contract that operates one or more units.
Manager: an employee of the franchisor or franchisee with administrative permissions.
Seller: a professional registered to carry out commercial interactions through the platform.
End customer: the person served by the seller, whose interaction is recorded through the platform.
GDPR: Regulation (EU) 2016/679.

2. Object and nature of the platform

Glivo provides a technology tool to support sales development and coaching, enabling the recording, automatic transcription, PII anonymization and AI-based analysis of in-person commercial interactions.

Nature of the platform — read carefully

Glivo is a productivity and professional development tool. Glivo:

Does not make sales, does not deal with end customers, does not manage commercial teams.

Is not responsible for commercial results obtained by users.

Is not a formal performance evaluation, monitoring or disciplinary control system.

Does not recommend, suggest or endorse employment decisions (warnings, dismissals, promotions) taken on the basis of its outputs.

Has no influence over how franchisors, franchisees or managers use, interpret or apply the data generated.

The outputs of the artificial intelligence are probabilistic, advisory and subject to error — they must not be used in isolation as a basis for impactful decisions. In accordance with Art. 22 GDPR and applicable national labor law (in particular EU Member-State rules on workplace monitoring and digital rights at work), all employment decisions require qualified human intervention.

3. Registration and access

Access to the platform requires prior registration with the provision of true, current and complete data.
Each user is responsible for the safekeeping and confidentiality of their access credentials (login and password).
Sharing of credentials between users is prohibited — each access is personal and non-transferable.
Glivo may suspend or terminate accounts that show signs of misuse, fraud, breach of these Terms or security risk.

4. Mandatory rules of use

The use of the platform is conditional on full compliance with the rules below. Non-compliance entitles Glivo to suspend access, terminate the account and notify competent authorities, where appropriate.

4.1 For all users

Use the platform only for lawful, professional purposes related to the authorized commercial activity.
Comply with applicable law, in particular the GDPR, applicable national data protection laws, applicable labor law of the Member State (e.g. Spanish Estatuto de los Trabajadores; Portuguese Código do Trabalho; etc.), applicable consumer protection law (e.g. Directive 2011/83/EU as transposed) and other applicable rules.
No reverse engineering, decompilation, copying or attempt to access non-authorized parts of the platform.
Do not use the platform to send spam, offensive, discriminatory, illegal content or content that violates third-party rights.
Do not interfere with the operation, security or availability of the platform.
Do not export, share or disclose audio, transcripts or analyses outside the platform without express authorization.

4.2 For franchisors and franchisees (controllers)

Ensure that each unit complies with the GDPR and the applicable national implementing law, in particular maintaining visible recording signage at points of circulation and customer interaction.
Carry out and document a Data Protection Impact Assessment (DPIA) where the processing is likely to result in a high risk to the rights and freedoms of data subjects (Art. 35 GDPR), in particular due to the use of innovative technology or the systematic processing of workers’ data.
Carry out and document a Legitimate Interest Assessment (LIA) where processing relies on Art. 6(1)(f) GDPR.
Comply with information obligations under Arts. 13 and 14 GDPR vis-à-vis end customers and sellers.
Comply with national workplace monitoring rules of the relevant Member State, including informing workers and, where required, consulting workers’ representatives prior to the deployment of monitoring systems.
Collect and archive the agreements signed by all sellers before enabling use of the platform.
Keep seller registers up to date — including immediate removal of professionals whose engagement has ended.
Designate a local point of contact for data management, handling of data subject requests and communication with Glivo. Designate a Data Protection Officer (DPO) where required (Art. 37 GDPR).
Train the team on the correct use of the platform and the resulting legal obligations.
Respond to data subject requests (customers and sellers) within the legal time frame of one month (Art. 12(3) GDPR).
Use the platform’s outputs solely for purposes of professional development, training and continuous improvement.
Ensure qualified human intervention in any decision affecting sellers that takes into account the data generated by the AI, in accordance with Art. 22 GDPR.

4.2.1 Commitments to appropriate use — worker protection

By accepting these Terms, the franchisor and franchisee expressly declare that they:

Will not rely solely on Glivo’s AI outputs as a basis for warnings, suspensions, dismissals (with or without cause) or any disciplinary sanction.
Will ensure that any employment decision involving the platform’s outputs is reviewed and substantiated by a qualified human manager, in accordance with applicable labor law and other applicable rules.
Acknowledge that the AI is probabilistic and subject to error, and does not constitute definitive evidence or evaluation.
Will respect the worker’s right to human intervention under Art. 22 GDPR.
Will not use the platform for abusive surveillance, persecution, discrimination, workplace harassment or public exposure of staff.
Will comply with specific obligations regarding workplace monitoring under applicable national labor law, including the requirements to inform workers and consult their representatives before deploying monitoring systems.
Will promptly act on requests for data deletion made by customers or sellers, in accordance with the GDPR.
Acknowledge being solely responsible for the decisions taken on the basis of the data — Glivo is not liable for them.

4.2.2 Acknowledgement of receipt of materials

By accepting these Terms, the franchisor and franchisee declare that they received by email the following supplementary materials provided by Glivo:

Usage Guide for Franchises;
Recording Notice template (sign + scripts);
Seller Agreement to be signed by sellers.

They also declare that they read those materials in full, understood their content and undertake to put them into practice — including posting the recording sign, collecting the signed seller agreements before first use of the platform and complying with the other good practices described therein.

Non-receipt of the materials, for any reason, must be notified immediately to Glivo at hello@glivo.ai — failing which, full receipt and reading is presumed.

4.3 For sellers

Use the platform only for legitimate in-person commercial interactions, in the exercise of their function.
Carry out interactions in environments where the recording sign is visible to the customer.
Reinforce the recording notice verbally in the situations indicated by the company.
Promptly respect any refusal or pause request by the customer.
Do not record private conversations, interactions of other units or interactions outside the professional scope.
Do not share recordings, transcripts or analyses outside the platform.
Formally accept the recording and analysis agreement before the first use.

5. Data processing, retention and anonymization

5.1 Automatic PII anonymization

The platform performs, automatically and before making transcripts available to managers, the detection and masking of personally identifiable information (PII) in the transcript, including: national identification numbers, phone numbers, emails, addresses and proper names. The transcript versions visible to managers do not contain these data in identifiable form.

Anonymization is performed by automated algorithms (regex + LLM) and, although robust, does not guarantee absolute removal in 100% of cases. Sellers are encouraged to avoid soliciting sensitive data during interactions.

5.2 Retention and deletion

Raw audio: retained for the standard period of 90 days (configurable per franchisor’s contract), after which it is automatically deleted from Glivo’s servers.
Anonymized transcripts and analysis outputs: may be retained for a longer period in line with the controller’s policy, observing the purpose limitation principle.
Early deletion: end customers, sellers, franchisees and franchisors may request the deletion of specific recordings at any time. The request is processed within the GDPR’s deadlines.
Termination of contract: upon termination, all controller data is deleted or returned, as agreed.

5.3 Processing roles

Glivo acts, as a rule, as processor of the personal data input by franchisors and franchisees, with the controller being the franchisor and/or franchisee.
Each controller is responsible for the legal basis, purpose, retention and handling of data subject requests for the data it collects through the platform.
Glivo adopts appropriate technical and organizational measures (Art. 32 GDPR) to protect the data, including encryption in transit and at rest, per-organization isolation (RLS), role-based access control and auditing.
Data subject requests must be addressed, in the first instance, to the franchisee responsible for the unit.

5.4 Data location and processing — international transfers

Glivo processes personal data in secure data centers, operated by cloud providers that meet international information-security standards (ISO 27001, SOC 2 or equivalents).
Glivo may process data in one or more jurisdictions, including those where its affiliates, suppliers and service providers are located. In particular, sub-processors may be located in third countries, including the USA.
For international transfers outside the European Economic Area, Glivo adopts the safeguards under Chapter V GDPR (Arts. 44 to 49), including:
- Standard Contractual Clauses approved by the European Commission (Implementing Decision (EU) 2021/914);
- Adequacy decisions, where applicable (including, with respect to the United States, the EU-U.S. Data Privacy Framework, while in force);
- Transfer Impact Assessments (TIA) under the Schrems II doctrine;
- Supplementary measures, technical (additional encryption, prior anonymization) and organizational, where necessary.
The international sub-processors used (notably providers of language models and transcription) are selected from suppliers offering an essentially equivalent level of protection to the GDPR and enter into appropriate contractual clauses with Glivo. Such sub-processors do not retain data after processing and do not use it to train their own models.

Glivo LLC has appointed an EU Representative for the purpose of communication with supervisory authorities and with data subjects located in the EEA.

Contact	Details
Data Protection Officer (DPO)	[to be defined]
EU Representative (Art. 27 GDPR)	[to be defined]
Channel for data subjects	hello@glivo.ai

6. Limitation of Glivo’s liability

Read this section carefully.

Glivo is a technology provider. Its liability is limited to the technical operation of the platform, as described below.

6.1 Glivo is responsible for

Availability and technical operation of the platform, subject to the service levels agreed in the contract.
Technical security of data in its custody, including encryption, per-company data isolation and access control.
Automatic PII anonymization with the technology available, without guaranteeing absolute removal in 100% of cases.
Compliance with its legal obligations as processor, where applicable.
Continuous update and evolution of the platform’s functionalities.

6.2 Glivo is NOT responsible for

Glivo is not responsible, under any circumstances, for the acts, omissions, decisions or conduct of franchisors, franchisees, managers, sellers or end customers using the platform. In particular, Glivo does NOT answer for:

Acts performed by franchisors, franchisees, managers, sellers or auxiliaries in the use of the platform, even if arising from internal instructions, operational failures or misuse of the tool.
Content of recordings, transcripts, analyses or comments generated, as well as their commercial, employment, civil or criminal consequences.
Management decisions taken on the basis of data or indicators provided by the platform, including:
- Performance evaluations;
- Promotions, transfers, commissions;
- Warnings, suspensions, dismissals and terminations;
- Improvement, development or career plans;
- Variable remuneration decisions.
Employment claims, union actions, proceedings before national labor inspectorates or labor courts arising from inappropriate use of the platform by controllers or their auxiliaries.
Actions for workplace harassment, moral damages, discrimination, breach of worker privacy or similar, arising from misuse of the platform by controllers or their auxiliaries.
Lack, inadequacy, absence or poor maintenance of recording signage in the unit, as well as omission of notices to the end customer, this obligation being exclusive to the franchisee and the seller.
Data leaks or misuse caused by negligence, willful misconduct, carelessness or conduct of users themselves (sharing of credentials, disclosure of screenshots, unauthorized exports, etc.).
Any moral, material, reputational or financial damages suffered by end customers, third parties, sellers, franchisees or franchisors as a result of the use of the platform.
Employment, union, harassment, discrimination or interpersonal disputes arising from the use of the platform or interpretation of its outputs.
Claims, fines, sanctions or actions imposed on franchisees, franchisors or sellers by public authorities, including data protection authorities and labor inspectorates, due to non-compliance with the GDPR, applicable labor law or other rules by the users themselves.
Errors, inaccuracies or biases in the outputs of the artificial intelligence. Users acknowledge that AI is probabilistic and subject to error and that the results must be interpreted with qualified human review.
Acts of unauthorized third parties (intrusions, cyberattacks, external fraud) that occur despite Glivo’s adoption of reasonable security measures.
Unavailability caused by fortuitous events, force majeure, third-party provider failures, user connection failures or scheduled and communicated interruptions.

6.3 Express acknowledgment by the user

By accepting these Terms, the user expressly acknowledges and declares that:

Glivo’s AI is a tool to support professional development, with probabilistic and error-prone outputs.
Any decision affecting staff must be taken by a qualified human manager, on the basis of multiple sources and in accordance with labor law and the GDPR.
Glivo does not recommend, authorize or take responsibility for dismissals, sanctions or disciplinary measures based, in isolation, on AI outputs.
Full responsibility for the decision and its justification lies with the controller (franchisor or franchisee).

6.4 Use conditioned on rule compliance

The right to use the platform is conditional on full compliance with these Terms, applicable laws and the guidance provided by Glivo.

A user who breaches any rule automatically loses the right to use the platform and is liable for damages caused to Glivo, other users or third parties.

7. Indemnification

The user undertakes to defend, indemnify and hold harmless Glivo, its members, directors, employees and partners against any claims, actions, losses, damages, fines, costs and expenses (including legal fees) arising from:

Use of the platform contrary to these Terms.
Violation of laws or third-party rights by the user.
Content recorded, transcribed or input into the platform by the user.
Employment, commercial or administrative decisions taken by the user based, in whole or in part, on data generated by the platform.
Employment claims, actions for moral damages, harassment or discrimination arising from the way the user has used the platform’s data.
Acts of the user’s own employees, auxiliaries, franchisees, sellers or partners.
Failure to maintain adequate signage or to collect seller agreements.

8. Intellectual property

All rights relating to the platform — functionalities, code, brand, AI models, prompts, layout, visual identity and related materials — are the exclusive property of Glivo or its licensors. Use of the platform does not transfer any intellectual property rights to the user.

The following are prohibited: copying, modifying, distributing, commercializing, sublicensing, creating derivative works, removing brands or notices, or using the Glivo brand without prior written authorization.

9. Suspension and termination

Glivo may suspend or terminate the access of any user that:

Breaches these Terms or applicable laws.
Engages in conduct that endangers other users, end customers or the integrity of the platform.
Provides false, inaccurate or misleading information at registration.
Has its franchise contract, license or professional engagement terminated.
Uses the platform for prohibited purposes (e.g., basing employment decisions in isolation, abusive surveillance, discrimination).

Suspension or termination does not give rise to any right of compensation by Glivo, except as provided in a specific contract.

10. General provisions

These Terms do not create any corporate, employment, mandate, agency or exclusivity relationship between Glivo and the user.
Glivo’s tolerance of any breach of any clause does not constitute a waiver of the right to require it in the future.
If any clause of these Terms is held to be invalid, the remaining clauses shall remain in full force.

11. Applicable law and jurisdiction

11.1 Applicable law

The relationship between Glivo and users located in the European Union, with respect to personal data processing and consumer protection, is governed by the applicable EU law (in particular the GDPR, the eIDAS Regulation (EU) No 910/2014 and Regulation (EU) No 1215/2012 — Brussels I-bis), together with the national implementing law of the Member State of the user’s habitual residence in matters of mandatory consumer and labor protection, without prejudice to the application of US federal law applicable to Glivo LLC in its jurisdiction of origin.

11.2 Jurisdiction — disputes with consumers and labor matters

For disputes involving end consumers or labor matters raised by sellers or staff of the units, the courts of the claimant’s domicile shall have jurisdiction, in accordance with Regulation (EU) No 1215/2012 (Brussels I-bis), without prejudice to the right of consumers to use any alternative dispute resolution mechanism available in their Member State.

11.3 Jurisdiction — B2B contractual disputes

For disputes arising from the contractual relationship between Glivo LLC and franchisors, franchisees or other corporate users of the platform, the Parties agree, primarily, on arbitration or, alternatively, on the courts of the user’s Member State, with waiver of any other forum, except where mandatory law of the user’s domicile provides otherwise.

11.4 Cooperation with authorities

Glivo undertakes to cooperate in good faith with competent EU and national authorities (data protection authorities, labor inspectorates, public prosecutors, courts, the EDPB) in legitimate investigations relating to the use of the platform, in compliance with applicable legal procedures and with protection of its users’ data.

11.5 Alternative dispute resolution — consumers

Pursuant to Regulation (EU) No 524/2013, consumers may use the European Commission’s online dispute resolution platform at https://ec.europa.eu/consumers/odr and any national alternative dispute resolution body that is competent in their Member State.

12. Acceptance

By clicking “Accept” when entering the platform:

You declare having read, understood and accepted in full these Terms of Use and Glivo’s Privacy Policy.

You acknowledge that use of the platform is conditional on compliance with all the rules described herein.

You acknowledge being aware of the liability limitations of Glivo, in particular those provided in Clause 6.

You acknowledge that AI is probabilistic and subject to error, and that any decision of impact must be taken by a qualified human manager (Art. 22 GDPR).

You undertake, as controller, not to base employment decisions, in isolation, on AI outputs, under your sole responsibility.

Glivo · Sales coaching platform for franchises.

Glivo LLC — Wyoming, USA · EU Representative: [to be defined] (Art. 27 GDPR).

For questions about these Terms: hello@glivo.ai

Version: April 2026.