“users”, “you” or “your” means customers or anyone else who uses or accesses Gluru.
Attn: Data Protection Officer
8 Warner Yard
Information we may collect about you
We may collect and process the following data about you:
personal information that you provide by filling in forms on Gluru such as your name, mailing address, telephone number, email address, credit or debit card details and other information that can be used to identify you. This includes information you provide at the time of creating your account or at any subsequent point;
if you contact us, we may keep a record of that correspondence;
we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
details of any videos, comments, posts, social media information or other information you post or upload on Gluru;
device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information); and
details of your visits to Gluru, including but not limited to, the Internet protocol address used to connect your computer to the Internet, traffic data, location data, other communication data and the resources that you access.
location information such as GPS signals sent by a mobile device and we may also use various technologies to determine location such as sensor data from your device that may, for example, provide information on nearby WI-FI access points and cell towers.
unique application numbers and information about your installation, for example, the operating system type and application version number may be sent to us when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
we may collect and store information locally on your device using mechanism such as browser web storage including HTML 5 and application data caches.
we use various technologies to collect and store information when you use Gluru, and this may include sending one or more cookies or anonymous identifiers to your device.
We will hold the above information for as long as is necessary in order to provide you with the service on Gluru, deal with any specific issues that you may raise or otherwise as is required by law or any relevant regulatory body.
Information we may collect about others
We may collect and process the following data about others that you provide us with, including (but not limited to) information that you provide by filling in forms on Gluru. You represent and warrant to us that you have obtained the express consent from the individuals whose data you provide us with.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical information about our users’ browsing actions and patterns, and does not identify any individual.
Where we store your personal information
Safeguarding personal data
Your passwords are stored on our servers in encrypted form. We do not disclose your account details, postal or email addresses to anyone except when legally required to do so. We use a variety of technological, physical and organisational protections and procedures to help protect your Personal Data from unauthorised access, use, or disclosure, such as encryption, passwords and physical security measures. Whilst we strive to protect your Personal Data, we cannot ensure or warrant that the Personal Data or private communications you transmit to us will always remain private. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Sensitive information between your browser and Gluru is transferred in encrypted form using Secure Socket Layer (“SSL”). When transmitting sensitive information, you should always make sure that your browser can validate Gluru’s certificate.
It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to Gluru, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent any unauthorised access.
Safeguarding Personal Data
We are committed to protecting the security of your Personal Data. We use a variety of technological, physical and organisational protections and procedures to help protect your Personal Data from unauthorised access, use, or disclosure, such as encryption, passwords and physical security measures. Whilst we strive to protect your Personal Data, we cannot ensure or warrant that the Personal Data or private communications you transmit to us will always remain private. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How we use your information
We use information held about you (and information about others) in the following ways:
to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
to ensure that content from the Website is presented in the most effective manner for you and for your computer;
to conduct, monitor and analyse our business or Website operations. We may use the information to monitor and improve our level of service, to improve the content of the Website, to respond to your requests and for our own internal purposes;
to prevent fraud and other prohibited or illegal activities;
to protect the rights and safety of our affiliated entities and third parties, as well as our own;
to notify you about changes to our service;
to ensure you receive information relevant to you;
to ensure the content on Gluru is presented in the most effective manner for you and your computer or mobile device; and
to notify you about changes to our service.
Our goal is to be clear about what information we collect about you so that you can make meaningful choice about how it is used. For instance, you can review, edit and control certain types of information tied to your Personal or Business Account using Gluru settings.
Disclosure of your information
We may disclose your Personal Data to any of our partners and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your Personal Data to third parties and such disclosure may include for the following purposes:
when we entrust a certain sub-contractor and/or partner with the handling of Personal Data in which case we will carefully check and select such subcontractor and partner and will exercise necessary and appropriate supervision and/or review over such sub-contractor and/or partner in order to ensure the security control of the entrusted Personal Data;
in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
if we are or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets;
if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
we may share aggregated, non-personally identifiable information publicly with our partners such as publishers, advertisers or connected sites for purposes such as to show trends about the general use of our services.
Links to third party sites
How You Can Access Your Personal Data
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
When any person who is the subject of our retained Personal Data requests us to disclose, correct, add, delete, discontinue using or erase such Personal Data, we will appropriately respond to such request in accordance with applicable laws and regulations. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).
The Act gives you the right to access information held about you by submitting a request in accordance with the Act and is subject to a £10 administrative fee. All such requests should be sent to firstname.lastname@example.org.
Changes to this policy
Attn: Data Protection Officer
8 Warner Yard