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Brazil-based users hold LGPD rights including review of decisions made solely through automated processing that affect their personal, professional, consumption, or credit profile, with Glean obligated to provide information about the criteria and procedures used, subject to commercial and industrial secret limitations.
This analysis describes what Glean's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The automated decision review right under LGPD is operationally significant for any Glean website interaction involving automated personalization or profiling, and the commercial secrets limitation on disclosure of criteria may require case-by-case assessment of what information must be provided.
Interpretive note: The scope of the commercial and industrial secrets limitation on automated decision criteria disclosure is not defined in the document and will depend on LGPD regulatory guidance and case-by-case application.
Under this clause, Brazil residents may request review of and information about automated decisions affecting their profiles; the statement conditions the disclosure of decision criteria on commercial and industrial secret protections, which may limit the scope of information provided in response to such requests.
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"Review of decisions made solely based on automated processing of personal data that affect your interests, including decisions aimed at defining your personal, professional, consumption, and credit profile or aspects of your personality; and Information about the criteria and procedures used for automated decisionmaking, subject to commercial and industrial secrets.Excerpt from Glean's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates Brazil's LGPD, specifically provisions governing automated processing and profiling, enforced by the Autoridade Nacional de Proteção de Dados (ANPD). The commercial and industrial secrets carve-out aligns with LGPD's text but its application to specific decision criteria requires case-by-case legal assessment. 2) GOVERNANCE EXPOSURE: Low to Medium. Glean's primary business involves enterprise software rather than direct consumer profiling, which may limit the practical scope of automated decision claims from Brazil-based website visitors; however, any personalization or inference-drawing on the website may engage this right. 3) JURISDICTION FLAGS: Brazil only. The ANPD is the primary supervisory authority for LGPD enforcement. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers in Brazil should assess whether Glean's Solutions agreements separately address LGPD compliance for employee data processed through enterprise deployments, as this statement explicitly excludes Solutions. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether Glean's website personalization and inference-drawing activities constitute automated decision-making under LGPD's definition, and whether documented criteria and procedures for such decisions are maintained and available for disclosure subject to the commercial secrets limitation.
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The automated decision review right under LGPD is operationally significant for any Glean website interaction involving automated personalization or profiling, and the commercial secrets limitation on disclosure of criteria may require case-by-case assessment of what information must be provided.
Under this clause, Brazil residents may request review of and information about automated decisions affecting their profiles; the statement conditions the disclosure of decision criteria on commercial and industrial secret protections, which may limit the scope of information provided in response to such requests.
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