Privacy Policy
GLASSBOXX PRIVACY POLICY (END USER AND PLATFORM PROVIDER)
Glassboxx Limited 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 your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union and the United Kingdom and we are responsible as a data ‘controller’ of that personal information for the purposes of those laws.
1 Key terms
Data Protection Officer
Julia Payen
Email: dpo@glassboxx.com
End User - The end customer that receives the eBook or audiobook
Licensee(s) - The commercial organisation that have contracted with us as a vendor or vendor +
we, us, our - Glassboxx Limited
2 Personal information we collect
2.1 We may collect and use the following personal information when you register with us or place an order for our products and/or services:
a) your name, contact information, including email address and company name;
b) mobile devices unique ID (including the mobile operating system and the type of internet browsers you use);
c) your billing information;
d) your contact history, purchase history and saved items;
e) information about how you use our website, IT, communication and other systems;
f) your responses to surveys, competitions and promotions.
2.2 We may collect and use the following personal information:
a) your name, contact information, including email address;
b) your billing information;
c) information about how you use our website, IT, communication and other systems;
d) server location data (including internet IP and addresses);
e) your responses to surveys, competitions and promotions.
2.3 This personal information is required to provide our products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing these to you.
3 How your personal information is collected
3.1 We collect most of this personal information directly from you, this may occur in by telephone, email, through our website or application. However, we may also collect information:
a) directly from a third party;
b) from a third party with your consent;
c) from cookies on our website—for more information on our use of cookies, please see our Cookie Policy at https://glassboxx.com/cookie-policy/
d) via our IT systems;
e) automated monitoring of our websites and other technical systems.
4 How and why we use your personal information
4.1 Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
a) to comply with our legal and regulatory obligations;
b) for the performance of our contract with you or to take steps at your request before entering into a contract;
c) for our legitimate interests or those of a third party; or
d) where you have given consent.
4.2 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
4.3 The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for / Our reasons
To provide products and services to you: For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or us: For our legitimate interests or those of a third party, such as to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity: To prevent and detect fraud
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies: To comply with our legal and regulatory obligations
Operational reasons, such as improving efficiency, training and quality control: For our legitimate interests or those of a third party; for example to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information: For our legitimate interests or those of a third party, such as to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business: For our legitimate interests or those of a third party, such as to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems: For our legitimate interests or those of a third party, such as to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations
Updating customer records: For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, such as making sure that we can keep in touch with our customers about existing orders and new products
Marketing our services and those of trusted third parties to:
- existing and former customers;
- third parties who have previously expressed an interest in our services; and
- third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, such as to promote our business to existing and former customers
External audits and quality checks, for example ISO [or Investors in People accreditation] and the audit of our accounts: For our legitimate interests or a those of a third party, such as to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations
5 Promotional communications
5.1 We may use your personal information to send you updates (by email) about our products and services, including exclusive offers, promotions or new products and services.
5.2 We have a legitimate interest in processing your personal information for promotional purposes (see section 4). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
5.3 We will always treat your personal information with the utmost respect and never SELL OR SHARE it with other organisations outside Glassboxx Limited for marketing purposes.
5.4 You have the right to opt out of receiving promotional communications at any time by:
a) contacting us at glassboxxsupport@firstygroup.com;
b) using the ‘unsubscribe’ link in emails; or
c) updating your marketing preferences on our website.
5.5 We may ask you to confirm or update your marketing preferences if you instruct 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.
6 Who we share your personal information with
6.1 We routinely share [aggregated and anonymised] data with:
a) companies within the Firsty Group;
b) third parties we use to help deliver our products and services to you, (i.e. publishers, retailers, authors, payment service providers, warehouses and delivery companies);
c) other third parties we use to help us run our business (i.e. website hosts);
d) third parties approved by you (i.e. social media sites you choose to link your account to or third party payment providers);
e) our bank(s).
6.2 We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors [in relation to ISO accreditation and the] for the purpose of auditing of our accounts.
6.3 We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
6.4 We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
6.5 We will not share your personal information with any other third party.
7 Where your personal information is held
Information may be held at our offices and those of Firsty Group, third party agencies, service providers, representatives and agents as described above (see section 6).
7.2 Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs (see section 9).
8 How long your personal information will be kept
a) respond to any questions, complaints or claims made by you or on your behalf;
b) show that we treated you fairly; and
c) keep records required by law.
8.2 We will not retain your personal information for longer than necessary for the purposes set out in this policy.
8.3 When it is no longer necessary to retain your personal information, we will delete or anonymise it.
9 Transferring your personal information out of the EEA
9.1 To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), for example:
a) with our offices outside the EEA;
b) with your and our service providers located outside the EEA;
c) if you are based outside the EEA.
9.2 These transfers are subject to special rules under European and UK data protection law.
9.3 The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: USA.
9.4 Our data hosting providers Lexiconn and Google storage comply with the following:
9.5 If you would like further information please contact our Data Protection Officer.
10 Your rights
10.1 You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your personal information
Rectification: The right to require us to correct any mistakes in your personal information
To be forgotten: The right to require us to delete your personal information
Restriction of processing: The right to require us to restrict processing of your personal information in certain circumstances
Data portability: The right to receive the personal information 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: The right to object:
- at any time to your personal information being processed for direct marketing (including profiling); and
- in certain other situations to our continued processing of your personal information.
Not to be subject to automated individual decision making: 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
10.2 For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
10.3 If you would like to exercise any of those rights, please:
a) complete a data subject request form, available by email via dpo@glassboxx.com; or
b) provide us with information to identify to enable us to identify you (including your name, customer reference number and address).
11 Keeping your personal information secure
11.1 We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
11.2 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11.3 If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
12 How to complain
12.1 We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
12.2 The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone (0303 123 1113).
13 Changes to this Privacy Policy
13.1 This Privacy Policy was published on March 6th, 2020.
13.2 We may change this Privacy Policy from time to time. When we do we will inform you via email.
14 How to contact us
14.1 Please contact our Data Protection Officer by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.