Behavioral Analytics Policy

1. Purpose

This Policy describes how Glancers may collect and analyze data about how a User interacts with the Platform (navigation, timing, and similar interaction patterns) to support security, fraud prevention, and product improvement. It operates together with the Privacy Policy, the Cookies Policy, the Automated Decision-Making Policy, and, where conversation content is involved, the AI Monitoring & Conversation Analysis Policy. Where this Policy and the Privacy Policy describe the same processing activity differently, the Privacy Policy's statement of legal basis and data-subject rights controls.

2. What This Data Is — and Is Not

2.1 Linkage Categories

Data addressed by this Policy falls into one of the following categories, and this Policy does not describe data in a more anonymous category than it actually is:

• Account-linked: associated with a specific, identified User account (for example, login timing, in-Platform navigation while signed in).
• Device-linked: associated with a specific device or browser session, whether or not the User is signed in at that moment (for example, via a device or session identifier).
• Pseudonymous: processed under an identifier that does not itself reveal the User's identity but that Glancers can, using other information it holds, reasonably link back to an identified User.
• Irreversibly anonymized: processed such that Glancers cannot, using any means reasonably likely to be used, re-identify the individual it came from.

Where interaction data is account-linked, device-linked, or pseudonymous, this Policy does not describe it as "anonymous" or "anonymized." Where this Policy or another Glancers policy uses those terms, they refer only to data that meets the irreversibly-anonymized standard above. Most of the behavioral data described in this Policy is account-linked or device-linked, not anonymous, because its security and fraud-prevention purpose generally requires being able to associate a pattern with a specific account or device.

2.2 Data Points Collected

Where implemented, Glancers may collect interaction data including navigation patterns, time spent on pages, click interactions, and, where implemented, typing rhythm, and mouse or touch movement patterns. Typing rhythm and pointer-movement data are treated with particular caution: they are collected, where implemented, only for the security and fraud-prevention purposes described in Section 3, are not used to build a profile of the User's health, emotional state, or personal characteristics, and are not shared for advertising or any purpose outside this Policy's stated purposes.

2.3 Behavioral Biometrics

This Policy does not state that Glancers operates a behavioral-biometrics system that generates a persistent "behavioral signature" for every User. Where such a capability is implemented, in whole or in part, the safeguards in Section 4 apply to it in full.

3. Purposes

Where implemented, interaction data described in this Policy may be used for: fraud and account-takeover detection; abuse and bot/automated-activity detection; security monitoring; identifying friction points and improving the Platform's usability; and, where a User has not objected and where consistent with the Privacy Policy's stated legal basis for this purpose, personalized recommendations and matching. Interaction data is not used to build a profile of a User's health, religion, sexual orientation, or other special-category data, and is not used for third-party advertising, and is not sold to, or shared with, a third party for that third party's own independent purposes.

4. Safeguards for Security-Related Signals

Where Glancers uses interaction data (including any behavioral-biometric signal described in Section 2.3) as part of a security or fraud-prevention determination:

• it is treated as a supporting signal that may contribute to a risk assessment, not, by itself, an automatic basis for an adverse account action;
• a significant deviation from a User's typical pattern may trigger an additional verification step (such as multi-factor authentication) before any restriction is applied;
• a permanent or materially adverse account action (such as suspension or termination) based even in part on this kind of signal requires human review before it takes effect, consistent with Section 3.2 of the Automated Decision-Making Policy; and
• this Section does not authorize, and this Policy does not describe, fully automated permanent account actions based solely on behavioral-analytics signals.

5. Retention, Deletion, and Account Closure

Interaction data described in this Policy is retained for the period necessary for the security, fraud-prevention, or product-improvement purpose it was collected for, consistent with the retention principles in the Privacy Policy and the Data Processing & Protection Policy. Upon account closure, Glancers aims to delete or irreversibly anonymize behavioral interaction data associated with the closed account, except where a longer retention period is required by applicable law (for example, fraud-investigation, tax, or accounting retention obligations) or is necessary to establish, exercise, or defend a legal claim.

6. External Sharing

Glancers does not sell interaction data described in this Policy to a third party, and does not share it with a third party for that third party's own independent advertising purposes. Interaction data may be shared with a Glancers data processor engaged to help provide the security, fraud-prevention, or product-improvement functions described in this Policy, under the terms described in the Privacy Policy and Data Processing & Protection Policy, and may be disclosed where required by applicable law, to a competent authority, or to establish, exercise, or defend a legal claim.

7. User Controls and Transparency

Glancers aims to make information about the categories of behavioral data it collects, and their purposes, available to Users through the Privacy Policy and related in-Platform disclosures. This Policy does not state that a dedicated, User-facing privacy dashboard for behavioral data is available. Where a User wishes to exercise a data-subject right (such as access, correction, or deletion) with respect to interaction data, the mechanism described in the Privacy Policy applies.

8. Legal Basis

The legal basis for collecting and using the interaction data described in this Policy is addressed in the Privacy Policy, not restated independently here, because a single processing activity should have one stated legal basis rather than two documents each asserting their own. In general terms, and subject to the Privacy Policy's own statement controlling: security and fraud-prevention uses are generally based on Glancers' legitimate interest in protecting the Platform and its Users, and, where applicable, a legal obligation; and non-essential personalization uses that are not necessary to provide the Service are generally based on consent, which a User may withdraw at any time through the mechanism described in the Cookies Policy or Privacy Policy without affecting the lawfulness of processing carried out before that withdrawal.

9. Relationship to Automated Decision-Making and Monitoring

This Policy operates together with, and does not override, the safeguards in the Automated Decision-Making Policy (including its human-review requirement for a legally or similarly significant, fully automated decision) and, where message or conversation content is analyzed rather than interaction metadata, the AI Monitoring & Conversation Analysis Policy. Where those policies impose a stricter safeguard than this Policy for a given kind of data or decision, the stricter safeguard applies.

10. Effective Date

This policy is effective upon publication and subject to updates at the Platform's discretion, consistent with Section 15.1 of the Terms and Conditions.

Procedural Review & Appeals

Any adverse administrative action, temporary restriction, or account decision taken under this policy is subject to procedural review and may be appealed in accordance with the Appeals & Reconsideration Policy.

Version History

• 2026-09 — Streamlined policy wording.
• 2026-09 — Revised selected provisions for accuracy and consistency with related policies.
• 2026-09 — Clarified consistency with related policies and qualified statements about Platform features.
• 2026-09 — Updated payment, compensation, and relationship terminology to reflect that Clients purchase Services from Glancers and that Glancers separately engages and compensates Freelancers.