Privacy Policy

Policy version: v.1.052024

GlowStrategy.co.uk (our website) is provided by Glow Strategy Group Limited (‘we’, ‘our’ or ‘us’).We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have acomplaint.

We collect, use, and are responsible for, certain personal data about you. When we do so we are subject to the Data Protection (Bailiwick of Guernsey) Law, 2017 (GDPR).

This privacy policy is divided into the following sections:

• What this policy applies to

• Personal data we collect about you

• How your personal data is collected

• How and why we use your personal data

• Marketing

• Who we share your personal data with

• How long your personal data will be kept

• Transferring your personal data out of Guernsey and the UK

• Cookies and other tracking technologies

• Your rights

• Keeping your personal data secure

• How to complain

• Changes to this privacy policy

• How to contact us

What this policy applies to

This privacy policy relates to your use of our website only.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We may collect and use the following personal data about you:

• your name, address and contact information, including email address, telephone number, and company details

• location data, if you choose to give this to us

• details of any information, feedback or other matters you give to us by phone, email, post or via social media

• your activities on, and use of, our website

• your professional online presence, eg LinkedIn profile

• information about the services we provide to you

• information about how you use our website and technology systems

• your responses to surveys, competitions and promotions

The majority of users will not be required to provide any personal data to use this website, if you must provide personal data to access the website or utilise any services we provide, you will have a choice.

Where you are given a choice, we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on the use of our website or on the provision of services

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

• directly, when you enter or send us information, such as when you contact us (including via email), send us feedback, complete customer surveys or participate in competitions via our website, and

• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

• where you have given consent

• to comply with our legal and regulatory obligations

• for the performance of a contract with you or to take steps at your request before entering into a contract, or

• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Creating and managing your account with us

To perform our contract with you or to take steps at your request before entering into a contract

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Enforcing legal rights or defend or undertake legal proceedings

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect our business, interests and rights

Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)

Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price

Protecting the security of systems and data used to provide the services

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us understand our customer base

Updating and enhancing customer records

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract

—to comply with our legal and regulatory obligations

—where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant.

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers

For our legitimate interests, ie to promote our business to existing and former customers

See ‘Marketing’ below for further information

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your personal data—in more detail

More details about how we use your personal data and why are set out in the table below.

Purpose

Processing operation

Lawful basis relied on under the Data Protection (Bailiwick of Guernsey) Law, 2017

Relevant categories of personal data

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices

Addressing and sending communications to you as required by data protection laws, ie:

— Data Protection(Bailiwick of Guernsey) Law, 2017

Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)

Processing is necessary for compliance with a legal obligation to which we are subject(Schedule 2)

Our legitimate interests (Schedule 2)which is to be as efficient as we can so we can deliver the best service to you

—your name, address and contact information, including email address and telephone number and company details

—your account details(username)

—your name, address and contact information, including email address telephone number and company details-your account details

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post)about our services, including exclusive offers, promotions, or new products and services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at hello@glowstrategy.co.uk

• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell OR share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

• third parties we use to help deliver our services to you, eg payment service providers, or

• other third parties we use to help us run our business, eg marketing agencies, website hosts and website analytics providers, or

• our bank.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations,

• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations,

• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. Further details on this are available on request.

Transferring your personal data out of Guernsey or the UK

The Guernsey, the UK and other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside Guernsey or the UK. In those cases, we will discuss with you any transfer in advance.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies and similar technologies, eg web beacons, action tags, or single-pixel gifs on our website. These help us recognise you and your device and store some information about your preferences or past actions.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)

—in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our website

The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consents by emailing us.

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please complete a request form—available on our homepage or email us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself and any additional identity information we may reasonably request from you, and

• let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

• the Office of the Data Protection Authority in the Bailiwick of Guernsey.

The Office of the Data Protection Authority may be contacted using the details at https://www.odpa.gg/for-individuals/make-a-complaint/ or by telephone: 01481 742 074.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period of time.

How to contact us

Individuals in Guernsey or the UK

You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

hello@glowstrategy.co.uk

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