PRIVACY POLICY
Website privacy notice
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data.
Glow Innovation Ltd is the data controller and we are responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice.)
If you need to contact us about anything related to this notice, you can email us at info@glowinnovation.com.
If any of your personal information changes (e.g. when you have changed your email address, moved house or maybe changed your name because you got married - in which case congratulations!), please email us at the above email address and let us know how it has changed. From time to time we may email you to check that the personal data we hold for you is accurate and up-to-date.
2. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
We may collect the following data about you:
- • Your name
- • Your email address
- • Your address
- • Your phone number
- • Your business name
- • Your financial details
- • Any personal data you post on our website
- • Data about how you use our website
- • Any other information that you directly provide to us whether through our contact form, over the phone, by email
- • Photographs of you at events
3. HOW WE MAY USE YOUR DATA
We will use your data in order to:
- • Enable us to perform a contract with you and respond to queries
- • Send you marketing communications where we are allowed to do so by law
- • Keep records of invoices sent out or paid and communications in relation to such
- • Keep records of communications
- • Manage our business
- • Obtain professional advice
- • Bring legal claims against you if you breach a contract or fail to make payment (we know you won’t…)
- • Comply with any legal obligations we are subject to or as required by a government authority
4. OUR LAWFUL GROUND OF PROCESSING
Under the General Data Protection Data Regulations, we are only legally able to process your personal data if we have a lawful ground for doing so.
Our lawful grounds of processing are:
- • In relation to Customer Data that we have obtained in relation to you entering into a contract with us that we hold for the purpose of fulfilling that contract, the processing is necessary for the performing of the contract to which you are subject and for our legitimate interests in record keeping and to establish, pursue or defend legal claim as responsible business operations
- • In relation to Prospect Data that we have obtained when you enquired about our products or services (whether that be through the website or otherwise) and that we process in order to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request prior to entering into a contract and for our legitimate interests in record keeping and to establish, pursue or defend legal claim
- • In relation to your data that we process in order to comply with legal requirements or as required by a government authority, the processing is necessary for compliance with a legal obligation to which we are subject
- • In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in responsible business operations or defending, pursuing or establishing a legal claim
- • In relation to obtaining professional advice or insurance, this processing is necessary for our legitimate interests in order to protect and grow our business.
We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data.
We do not collect any information about criminal convictions and offences.
We do not carry out automated decision-making or any type of automated profiling.
5. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by your providing the data directly to us (for example by filling in forms on our site or by sending us emails).
We may receive data from third parties such as advertising networks based outside of the EU such as LinkedIn, payment and delivery services, fraud detection agencies and data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
6. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may only send you email or text marketing communications if (i) you asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@glowinnovation.com.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as fulfilling a contract.
7. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- • Service providers who provide IT and system administration services
- • Professional advisers including lawyers, bankers, accountants, auditors and insurers
- • Government bodies that require us to report processing activities or otherwise disclose your personal data
- • Fraud prevention agencies
- • Third parties to whom we sell, transfer or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
8. INTERNATIONAL TRANSFERS
We share your personal data within our company, which involves transferring your data outside the European Economic Area (EEA).
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
- • We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data by; or
- • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- • Where we use certain service providers who are established outsider of the EEA, we may use specific contracts or codes of conduct or certification mechanisms by the European Commission, which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
9. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or access without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
10. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm form unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely and without further notice to you.
11. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at info@glowinnovation.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your rights to access your personal data (or to exercise any of your other rights.) This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisor authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
