PRIVACY POLICY

Glasscubes Limited ("we", “us”) are committed to protecting and respecting your privacy and personal data.

This policy sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the UK GDPR (as per the meaning given to it in section 3(10) ((as supplemented by section 205(4)) of the Data Protection Act 2018) or the EU GDPR (being the General Data Protection Regulation (EU) 2016/679)), as it has effect in EU law), as applicable, you are the data controller and the data processor is Glasscubes Limited (company number 08630188), 20-22 Wenlock Road, London, N1 7GU, United Kingdom.

WHEN WE COLLECT PERSONAL DATA AND WHAT PERSONAL DATA WE COLLECT

We may collect and process the following data about you:

• When you engage us to provide you with our services, we may collect data about you as follows: your name, your email address, your password, your telephone number, including your mobile number, your company billing address and your company’s banking details. We may also collect information about your assets, transaction details about payments made to and from you and other details of services you have purchased from us.
• When you use our services, we may collect information provided at the time of registering with www.glasscubes.com (“Our Site”), or requesting services or information from us as follows: your name, your email address, your phone number, and any data relating to your usage of our services.
• You can ask to be removed from our service at any time. To do so, please contact your account administrator.
• When we engage you to provide us with your goods or services, we may collect data as follows: your name, your email address, your phone number, your quotes, transaction details about payments made to you, your bank details and other details of services or goods we have purchased from you.
• When you provide a review of our services and our performance on a third-party platform (such as on Capterra or TrustPilot), we may collect personal data such as your name and email address.
• When you have consented to receive marketing and technical information from us, we collect personal data such as your name, your email address and your account URL.
• When you fill in a form on our website to request a demo, we will collect your contact details and the information you provide in the form.
• When you contact us by any other means (e.g. email or telephone), we may keep a record of that contact and the information you provide us with at the time.
• If your personal data is on publicly available sources (such as LinkedIn and Companies House) then we may collect your personal data that is available on these sources.
• We may collect personal data of prospect customers from third-parties in order to develop our business and our customer relationship list.
• If you submit a job application to us, we will collect your contact details and any other information that you provide in the application.
• When you complete a survey or participate in competitions, we may collect the information that you provide to us for research purposes.
• When you visit Our Site, we may collect data such as information about your geolocation, weblogs and other communication that is available from the browser.

OTHER INFORMATION COLLECTED VIA OUR WEBSITE AND COOKIES

As you interact with our website, we may automatically collect information about your website usage such as information about your equipment, your IP address, operating system and browser type for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

For the same reason and like most websites, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve Our Site and to deliver a better and more personalised service. They enable us:

• to estimate our audience size and usage pattern;
• to store information about your preferences, and so allow us to customise Our Site according to your individual interests;
• to speed up your searches; and
• to recognise you when you return to Our Site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of Our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you log on to Our Site.

PURPOSE FOR WHICH WE USE YOUR PERSONAL DATA

• To manage our relationship with you which will include pitching for business with you, notifying you about changes to our terms of service, terms of service or privacy policy and registering you to enable you to take part in a forum or comply with a legal obligation.
• To administer and protect our business and the services we provide to you (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) on the basis that it is necessary to comply with our contractual obligation to you and that we have a legitimate interest to do so (for running the services you use, the provision of administration and IT services, network security and to prevent fraud).
• To deliver safe services for you to use, send marketing and technical information to you and measure the effectiveness of these activities. We will do so on the basis that you have consented to us processing your personal data in this way. You can always stop receiving marketing and technical information from us at any time as these communications provide easy ways to unsubscribe.
• To process and deliver our services to you including providing you with a quote, managing payments, fees and charges, collecting and recovering money owed to us on the basis of our performance of our contract with you.
• To obtain information from publicly available sources in order to research and review our customers’ and prospect customers’ records and to administer their account.
• To process job applications and CVs submitted to us on the basis that we have a legitimate interest to do so (to fill vacancies and to grow our business).

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Any changes we may make to our privacy policy in the future will be posted on this page, and where appropriate, may be notified to you by e-mail. Therefore, we advise you to revisit this page regularly.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Our Site may, from time to time, contain links to and from the websites of our suppliers, partner networks, advertisers, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites should have their own privacy policies and we do not accept any responsibility or liability for these policies, the content or operation of these websites. Please check these policies and the terms of the websites before you submit any personal data to these websites.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

WHO WE SHARE YOUR PERSONAL DATA WITH

We may disclose your personal data with third-parties as follows:

• If we are under a duty to disclose or share it in order to comply with any legal obligation (for example our auditors, our insurers and HMRC).
• With other service providers who we engage to assist us in providing our services (such as hosting partners which host our servers, with a customer success tool provider that helps us improve your experience when using our services, emails broadcaster that helps us in sending you monthly marketing and technical information, forum providers which enable our users to exchange ideas on how to improve our services, and financial services providers which process payments made to and from us) in order to comply with our contractual obligations as set out in our terms of service and other agreements in place.
• With other organisations, such as credit reference agencies and fraud prevention agencies on the basis that we have a legitimate interest in preventing and protection ourselves and our customers against fraud.
• With our customers who engage or have engaged us to provide our services to, in order to improve the provision of our services on the basis that we have a legal obligation and a legitimate interest to do so.

DATA RETENTION

We 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.

To determine the appropriate retention period for personal data, we consider the amount, the nature and sensitivity of your personal data, the potential harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve these purposes through other means and the applicable legal requirements.

The table below sets out further details:

WHERE WE STORE YOUR PERSONAL DATA AND HOW IT IS KEPT SECURE

Where we have given you (or where you have chosen) a password which enables you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Some of the information you provide to us will be transmitted electronically (e.g. information provided via our website or by email). We would remind you that information transmitted via the internet is not completely secure and although we will do our best to protect any information transmitted in this way, we cannot guarantee its complete security.

We have put in place appropriate measures to prevent your personal data from being accidentally lost, accessed or used in an unauthorised way, altered or disclosed. Any payment transactions will be encrypted using SSL technology.

Some personal data you have provided to us is stored on secure servers located in the United Kingdom, in Germany and in Ireland.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (where the UK GDPR applies to the transfer) or specific contracts approved for use in the EU which give personal data the same protection it has in the EU (where the EU GDPR applies to the transfer), save where one of the derogations for specific situations applies to the transfer.

This does NOT include any documents or content you upload or add to your account on Glasscubes except if it is unlawful and is requested by the relevant authorities. All documents or content uploaded by you are stored within our datacentres in the UK.

In addition, we limit access to your personal data to those employees, agents, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE HOLD

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

CONTACTING US

If you would like to communicate with us about any of the rights mentioned above, or if you have any other queries about the matters mentioned in this privacy policy, please contact us using one of the following options:

Email: enquiries@glasscubes.com

Post: Glasscubes Limited, 20-22 Wenlock Road, London, N1 7GU, United Kingdom

Telephone: +44 (0)20 3174 2310

COMPLAINTS

You have the right to complain to the Information Commissioner about the way in which we collect and use your personal data: www.ico.org.uk/concerns or telephone 0303 123 1113.

CHANGES TO THIS PRIVACY POLICY

This policy is effective from 6th December 2021. We may change this policy from time to time by updating this webpage.