Privacy Statement for Glow

Glow Technology AB, reg. no. 559275-0326/ Glow Technology AS, reg. no. 927 600 676  (“Glow”, “we”, “our”, “us”), takes the protection of your personal data seriously. With this privacy statement, we want to inform you of how we process your personal data.

1. The framework for our processing of personal data

We process your personal data within the framework of applicable data protection laws and this privacy statement. Personal data is collected when necessary for our execution of the tasks and services we are required to perform in accordance with laws and/or agreements, or when you otherwise provide us with your personal data.

Personal data is information and assessments that can be used to either directly or indirectly identify a natural person. When we use the term “processing” of personal data, this means any use of personal data, such as the collection, registration, compilation, storage and disclosure of data or a combination of these uses.

All processing of personal data requires that there is a lawful basis for the processing. We will always ask for your consent before processing your personal data, unless we have another lawful basis for the processing, such as an agreement, a legal obligation or our legitimate interest.

2. Which personal data is processed?

By using our services, visiting our website or contacting us, you will share personal data with us. We only collect personal data from you that is necessary in order for us to fulfill the purposes of our processing. The categories of personal data that we collect may include:

• identification data (e-mail, address, phone number, name, employer or the company you represent, log in details, etc.);
• electronic identification data (IP-address, device data, cookies, etc.); and
• other data that you share with us (information in correspondence, etc.).

We may also collect information from public registers for the purpose of register maintenance.

3. Purposes of processing, legal basis and retention

The purpose of our processing of your personal data is primarily to administer the customer relationship and such other processing as is necessary to fulfill the obligations we have undertaken for you, or the company you represent, as a customer and/or user of our services. We may also process personal data as required or permitted by legislation or in cases where you have consented to the processing in question. You are not required to provide us with any personal data. However, if you do not provide us with, or allow us to collect, your personal data, this may affect our ability to provide you, or the company that you represent, with our services.

We may process your personal data for the purposes explained in 3.1-3.6.

3.1. In order to fulfill the customer agreement and provide our services

As the representative of a customer, we will process your personal data with the purpose of fulfilling the customer agreement and providing our services. The lawful basis of the processing is our legitimate interest to be able to provide our customer with the ordered services.

Retention period. We will save your information for this purpose until the agreement has been terminated and for the period thereafter required in order to be able to handle complaints and warranty matters.

3.2. In order to enable contact with you

We will process your personal data with the purpose of enabling communication with you. The lawful basis for the processing is our legitimate interests of being able to communicate with you.

Retention period. Your personal data will be retained for as long as is necessary in order to maintain communication with you for its purpose.

3.3. Customer follow-up and marketing

We will process your personal data for the purpose of sending marketing to you as a contact person or representative for a customer or potential customer. The lawful basis for the processing is our legitimate interest to be able to inform customers and potential customers about products and services that may be of interest within your profession.

Retention period. We will store your personal data for a period of 1 year after the customer relationship between the company that you represent and Glow has ended, or until you notify us that you no longer wish to receive such marketing.

3.4. System testing and quality assurance

Your personal data is handled by several IT systems, all designed for specific and necessary operational purposes. To ensure both satisfactory operating stability and, not least, information security, it is necessary to do regular updates, testing, troubleshooting, etc. In this context, data may be cloned and individual systems may be duplicated. This will take place in a secure, dedicated environment, so that these operations do not affect the daily operation of the main system. All information that we process as part of internal system testing and quality assurance, etc., is subject to the same requirements for information security and stringent routines as when the information is processed in other contexts. The lawful basis for such processing is our legitimate interest of ensuring both satisfactory operating stability and information security.

Retention period. No copies or back-up of personal data will be stored any longer than necessary. Any copies or back-ups will be deleted when the system testing and quality assurance procedures have been carried out.

3.5. Customer satisfaction surveys

We will process your data with the purpose of conducting customer satisfaction surveys to provide a better understanding of how our customers experience us and how to improve our services. In this regard, we process names, emails, telephone numbers and the answers you give in the survey. It is voluntary to participate in customer satisfaction surveys and the lawful basis for the processing is consent. We employ third parties to conduct customer surveys on our behalf. If you participate in a customer survey, the survey information will be stored separately from other information that we have registered about you.

Consent is voluntary. You are free to decide whether or not to consent and may withdraw your consent at any time.

Retention period. Your personal data will be stored for 6 months after the survey was completed.

3.6. In order to fulfill our legal obligations

We will process your personal data with the purpose of fulfilling our legal obligations according to the law and government regulations. The lawful basis for the processing is legal obligation.

Retention period: We will store your data until the legal obligation has been fulfilled.

4. Recipients of personal data

Authorities. If there is a statutory requirement to disclose data to public authorities, the relevant personal data will be disclosed in accordance with the requirements stipulated by the authorities.

Data processors. We employ third parties who process personal data on our behalf (“data processor”). Before we give such data processors access to your personal data, we always enter into agreements (i.e. data processing agreements) that describe, among other things, what the data processor will do for us. Examples of the types of data processors that we use are suppliers of different systems, suppliers of analysis services, customer surveys, etc.

Others. In some cases, your personal data may be transferred to third parties who have an independent responsibility for the further processing of your personal data. We will never transfer your personal data to such third parties without having a lawful basis for it, or unless you have requested or otherwise approved it.

Links to third-party websites. We may make links available to other websites in our digital channels. If you click on such a link, the website may be able to record your personal data. In such case, the website owner is responsible for the processing of your personal data. We encourage you to inform yourself of how the website processes your personal data by reading their privacy statements.

5. Transfer to third countries

We, or our suppliers, may process, store and transfer your personal data to countries outside the EU/EEA. When we transfer your personal data to a third country, we ensure that the data is processed with the same level of security as within the EU/EEA. As an addition to the technical, organizational and contractual measures we take, a transfer to a third country will only be made when one of these conditions apply:

• there is an adequacy decision from the EU-commission;
• we have put in place security measures, such as standard contractual clauses that have been approved by the EU-commission; or
• an exemption applies in certain situations and in occasional cases.

 6. Your rights

You may have the following rights in relation to our processing of your personal data:

• You have the right to access information regarding the processing of your personal data.
• You have the right to request that inaccurate data be rectified.
• You have the right to request erasure of your data if the data is no longer needed for the purposes for which it was collected.
• You may have the right to demand that the processing of your data be limited.
• You have the right to deny to your data being used for direct marketing.
• You may have the right to object to the processing of your personal data.
• If the processing is based on your consent, you have the right to withdraw that consent at any point. The withdrawal of your consent does not impact the lawfulness of the processing that took place before you withdrew your consent.
• You may have the right to request a transfer of your personal data to another entity.

Please note that there may be conditions and limitations to these rights.

Please contact us if you wish to use any of these rights. See the contact information below.

7. Use of cookies

We use cookies on our website to ensure reliable visitor statistics and to increase the functionality of our pages. Here you can read more about our use of cookies and how you can control the use yourself: https://glowtechnology.com/cookies/

8. Questions or complaints

If you have questions about our processing of personal data or believe that we do not meet our obligations to you regarding how we process your personal data, we encourage you to contact us (see contact information below). You also have the right to lodge a complaint with the Swedish Authority for Privacy Protection, but we encourage you to contact us first.

9. Controller and contact information

Controller: Glow Technology AB, 559275-0326, is responsible for processing your personal data.

Contact information: info@glowtechnology.com