Glush Agency Limited Privacy Policy

This policy applies to all processing of personal data carried out by Glush Agency Limited and aims to inform you about how Glush Agency Limited carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and about your rights in relation to your personal data.

In case you have any questions about the Privacy Policy, you can contact Glush Agency Limited by the following means:

The registered office is located at: Suite 5 39-41, Chase Side, Southgate, London, N14 5BP
The contact telephone number is: +447411956326
You may establish direct and effective communication with Glush Agency Limited by written communication sent to any of the addresses indicated or also by sending an email message to: [email protected]
In addition, the information of the employee in charge of processing your personal data is listed below:

Business name: Glush Agency Limited
Identity of controller: Glush Agency Ltd
Address: Suite 5 39-41, Chase Side, Southgate, London, N14 5BP
Email: [email protected]

In accordance with the current regulations on the protection of personal data, especially,

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the ‘GDPR’),
Argentine Law No. 25,326 on the protection of personal data, its regulatory decree 1558/01 and its complementary rules (the ‘Argentine LPDP’),
The General Data Protection Law of Brazil, Law No. 13,709, (the ‘LGPD’)
The California Consumer Privacy Act (CCPA), Assembly Bill No. 375
Glush Agency Limited collects personal data in its possession when you:

(i). completes the (‘Site’) forms;
(ii). subscribes to the newsletter;
(iii). responds to a survey or fills in a web form;
(iv). fills out a paper form;
(v). sends an e-mail or communicates by telephone, which are then loaded into the corresponding forms;

Glush Agency Limited collects information when by visiting its website, and primarily by completing its registration forms.

The following data is collected: .

As a general rule, when personal data is requested in order to use a service or access certain content, its delivery shall not be obligatory, except in those cases in which it is specifically indicated that it is necessary for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.

The user declares and guarantees that all of the data provided are true and correct and undertakes to keep them up to date. Any changes may be communicated to the Data Protection Officer or to the address indicated in Section 2 of this document.

Likewise, you acknowledge that the data required by Glush Agency Limited is necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data were not provided.

Any misrepresentation or inaccuracy that occurs as a result of the information and data provided, as well as the damage that such information may cause, shall be the responsibility of the user.

The personal data requested from the user will be used for the following purposes:

In case of contracting services offered through the Site, to create and maintain the business relationship, and to carry out the activities and provide the services of Glush Agency Limited (including, without limitation, the management, administration, provision and improvement of the services).
Send newsletters, as well as commercial communications, promotions and/or announcements from Glush Agency Limited, occasionally or periodically. Consequently, the email address you provide when completing the form on the Site may be used to send you information and updates on your request for services, as well as news about Glush Agency Limited (occasionally or periodically), updates, information on related products or services, among others. This processing is based on our legitimate interest in promoting our products and services.
To carry out a survey or a competition
To personalise the user experience by enhancing our ability to respond to your needs
To improve Glush Agency Limited’s Site and service offering, based on Glush Agency Limited’s legitimate interest in constantly improving its products and services.
Process transactions and comply with legal obligations to which Glush Agency Limited is subject, such as tax obligations. The data subject to processing shall not be used for purposes other than or incompatible with those mentioned above and which motivated their collection. Notwithstanding the above, it is hereby stated that the recorded data may be used, in addition to the purposes for which they were expressly collected, for the purposes of statistics, incident management or carrying out market research. However, should personal data be processed for a purpose other than that initially specified when the said data was collected, a compatibility analysis will be carried out by Glush Agency Limited in compliance with the applicable regulations. Processing will only be allowed if the original purpose is compatible with the new purpose or permitted according to an independent legal basis. In such cases, you will be informed of the changes in purpose or legal justification for processing your data.
You are reminded that you may object to receiving commercial communications from Glush Agency Limited (unsubscribe) and stop receiving emails from Glush Agency Limited by giving Glush Agency Limited reliable notice, which will stop as soon as possible after receipt of such notice. For this purpose, you may send an email to the address set out in Section 2, a postal mail addressed to the address set out in Section 2, or directly follow the unsubscribe instructions detailed at the end of each email from Glush Agency Limited.

We will use the information we collect about you for the following purposes:

Administration info
If we want to use your information for any other purpose, we will ask for your consent and use your information only when we receive your consent and then only for the purpose(s) for which consent will be granted, unless we are required by law to do otherwise.

We will retain your personal information with us for 24 months after user accounts remain idle or for as long as necessary to fulfil the purposes for which it was collected, as detailed in this Privacy Policy.

By providing personal data to Glush Agency Limited, the user declares to accept its processing fully and without reservation by Glush Agency Limited. The user gives his/her free, express and informed consent to Glush Agency Limited’s use of the data collected for the purposes indicated in Section 5, as well as its incorporation into a Glush Agency Limited database.

The Glush Agency Limited carries out the processing of legitimised user data: (i) the contracting of Glush Agency Limited services by the user, in accordance with the terms and conditions that are made available to the user at the end of the completion of the service request form (prior to possible contracting) and which the user (after reading them), and if the user agrees, can accept by ticking the box that has been included for this purpose; and (ii) the free, informed and unambiguous consent of the user, made after reviewing this privacy policy, where Glush Agency Limited informs you of the processing it will carry out with your data, and if you agree, by ticking the box that has been included for this purpose in the service request form. Data processing that is not covered by any of the above legal bases will be carried out if Glush Agency Limited considers it necessary to protect a legitimate interest and only if it does not infringe the fundamental rights and freedoms of the user.

The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes described in Section 5 above. In particular, personal data will be kept for as long as the business relationship is in force (and to the extent that you have not previously requested their deletion) and for as long as obligations, indemnities and/or liabilities may arise under the business relationship or for the services provided.
Glush Agency Limited informs you that it will retain information essential to identify the origin of the data stored for the duration of the client’s relationship with Glush Agency Limited and/or revocation of the user’s consent in accordance with the information in Section 5 of this Privacy Policy and/or as long as required by applicable law.

Glush Agency Limited will keep collected personal data private and confidential, and will not use it for purposes other than those set out in Section 5 hereof. Glush Agency Limited requires its employees and third parties providing services that access the contents of the databases to sign confidentiality and personal data processing agreements (or include such obligations in the service agreements it signs with such providers, as indicated in the following paragraph).

The user’s personal data collected by Glush Agency Limited will not be transferred, sold, exchanged, transmitted and/or communicated to third parties outside Glush Agency Limited without the user’s consent, except for legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers enabling Glush Agency Limited to keep the Site operational, fulfil the objectives set out in Section 5 of this document and/or provide services to the user, who have undertaken the obligation to maintain the confidentiality of the data provided and undertake to comply with applicable regulations on the protection of personal data, at the time of contracting. Contracts with service providers stipulate the purpose, scope, content, duration, nature and purpose of data processing, the type of personal data, the categories of data subjects and the obligations and responsibilities of Glush Agency Limited and contracted third parties.

In particular: Glush Agency Limited may share the personal information provided with parent companies, affiliates, subsidiaries, related companies and/or intermediaries related to Glush Agency Limited.

Glush Agency Limited may share certain user-provided personal information internally within Glush Agency Limited, with certain departments, such as administration, marketing, or IT.

**- In certain cases, Glush Agency Limited transfers personal data based on legitimate interests and the economic and technical advantages associated with the use of specialised providers. In this regard: – Maps. Glush Agency Limited uses Google Maps to include maps on the Site. The integration to Google Maps allows Google to collect the IP address of the user. The user can consult the privacy policy and other legal aspects of that company at the following link: – YouTube. The Site links to YouTube in relation to videos linked to Glush Agency Limited services. As indicated in Section 13, by using these links the user leaves the Site and is redirected to the YouTube page. You can view YouTube’s privacy policy and other legal aspects at the following link: – Instagram. The Site has links to Instagram. As indicated in Section 13, by using these links the user leaves the Site and is redirected to Instagram. The user can view Instagram’s privacy policy and other legal aspects at the following link: – Linkedin. The Site has links to Linkedin. As indicated in Section 13, by using these links the user leaves the Site and is redirected to Linkedin. The user can view Linkedin’s privacy policy and other legal aspects at the following link: ** **- Social Networks. Glush Agency Limited also uses social networks, such as Facebook or Instagram, and has integrated functions of these networks into its services. The user can only use these social networks insofar as they are registered on them and have accessed the corresponding social network with their user. These social networks have their own privacy policies and their own terms and conditions, over which Glush Agency Limited has no interference or control. **

Finally, you should be aware that Glush Agency Limited may (and that Glush Agency Limited reserves the right to) disclose your information in the following cases: (i) if required by a judicial or administrative authority; (ii) if necessary to exercise your rights under the Terms and Conditions of Glush Agency Limited and this Privacy Policy; (iii) if necessary to comply with the law; (iv) if such data may be useful for the protection of the rights of third parties; (v) if it is useful for the protection of the rights, property or safety of Glush Agency Limited, its controllers, subsidiaries, affiliates, directors, managers, employees, users or the general public; and (vi) if there are well-founded reasons relating to public safety, national defence or public health.

Glush Agency Limited declares its intention to adopt the necessary technical and organisational measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of GDPR,, ,the Argentinean LPDP, and ,LGPD in order to prevent its tampering, loss, consultation or unauthorised processing.

Glush Agency Limited does not guarantee absolute privacy when using the Site, since the possibility that unauthorised third parties may have knowledge of it cannot be excluded. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information. In the event that a security incident is detected and entails a significant risk to the data owner, such event will be reported without delay to the competent control authority, together with the corrective and remedial measures implemented and/or to be implemented.

Glush Agency Limited is not responsible for the loss or deletion of data by users. Similarly, Glush Agency Limited accepts no responsibility for possible damage caused by computer viruses.

Finally, the user must also take measures to protect their information. Glush Agency Limited insists that you take every precaution to protect your personal information while on the Internet. At the very least, it is advisable to change your password periodically, using a combination of letters and numbers, and to make sure you are using a secure browser.

The data owner user may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality and deletion of his/her personal data, in accordance with the provisions of Articles 15 et seq. of the GDPR, the provisions of the Argentine LPDP, the provisions of the LGPD, as applicable. The exercise of these rights may be carried out by the user him/herself by means of an e-mail addressed to [email protected], or by written communication addressed to the Data Protection Officer at the following address [email protected], or by any of the methods provided for in the applicable regulations referred to above. Glush Agency Limited may request the data necessary to validate the identification of the data owner. The deletion of some data shall not be carried out where it may cause damage to the legitimate rights or interests of third parties, or where there is a legal obligation to retain the data.
The Site may contain links to third party websites, with or without advertising content, whose privacy policies are foreign to Glush Agency Limited. The linked sites are not related to Glush Agency Limited and, their existence in no way presupposes that there is any kind of suggestion, invitation or recommendation to visit the target sites or any kind of link or association between Glush Agency Limited and such sites. Glush Agency Limited is not responsible for the content, use and activities of these linked sites, or for any actual or potential, material or moral, direct or indirect damages suffered by users and derived from the information contained in such sites or the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the above, any feedback on these linked sites will be useful to Glush Agency Limited in order to improve the services and/or ensure the integrity of the Site. Glush Agency Limited undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content.
When you visit the Site, Glush Agency Limited may store certain information on your computer in the form of a “cookie” or similar file. The Site uses cookies to (i) track advertising, (ii) collect traffic data from the Site, and (iii) improve the user experience when using the Site. The user should be aware that, in order to browse the Site, it is not necessary for him or her to allow the installation of cookies sent by the Site. This may only be required in relation to certain services. You may delete cookies from your computer hard drive, prevent access to your computer through your browser or by choosing the corresponding option when asked about the possibility of using cookies for these purposes and in accordance with Glush Agency Limited Cookie Policy. Cookies are files of information that a website or the provider of certain services on the site transfers to the hard drive of the user’s computer via the browser. Cookies by themselves cannot personally identify the user (although they may contain the user’s IP address) but they allow them to recognise the user’s browser, and to capture and store certain data (the user’s operating system, the domain name of the website from which the Site was linked, among others). Glush Agency Limited reserves the right to hire the services of third parties to analyse and understand the users of the Site, who may not use the information collected for purposes other than improving Glush Agency Limited’s services.
Your use of the Site constitutes your acknowledgement and approval of Glush Agency Limited’s Privacy Policy and Glush Agency Limited’s Terms and Conditions, if any. Likewise, the user accepts Glush Agency Limited’s Privacy Policy and Glush Agency Limited’s Terms and Conditions by completing the request for services.
This is the current version of the Glush Agency Limited Privacy Policy, updated on February 26, 2023. Glush Agency Limited may, at any time and without notice, modify this Privacy Policy. Such modifications will be operative as of their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed of the terms included herein by logging in periodically.

This part of the document incorporates and supplements the information contained in the rest of the privacy policy and is provided by the company that manages this Application and, if applicable, its parent, subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, pursuant to “The California Consumer Privacy Act of 2018” (Users are referred to below simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information” as defined in the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold.

In this section we summarize the categories of personal information we collect, disclose or sell and their purposes. You can read about these activities in detail in the section entitled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect.

We collect the following categories of personal information about you: information from the Internet.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above categories of personal information directly or indirectly from you when you use this Application.

For example, you provide your personal information directly when you submit orders through any forms on this Application. You also provide personal information indirectly when you browse this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the Service or the operation of this Application and its features.

How we use the information we collect: sharing and disclosing your personal information with third parties for a commercial purpose.

We may disclose the personal information we collect about you to a third party for commercial purposes. In this case, we enter into a written agreement with that third party requiring the recipient to keep the personal information confidential and not to use it for any purpose other than to carry out the agreement.

We may also disclose your personal information to third parties where you expressly request or authorise us to do so in order to provide you with our Service.

To learn more about the purposes of the processing, please see the relevant section of this document.

Selling your personal information

For our purposes, the word “sale” means any “sale, rental, release, disclosure, dissemination, making available, transfer or other communication orally, in writing, or electronically, of personal consumer information by the company to another company or to a third party, for valuable consideration or otherwise.”

Your right to opt out of the sale of personal information.

You have the right to opt-out of the sale of your personal information. This means that whenever you ask us to stop selling your data, we will comply with your request. Such requests can be made freely, at any time, without any verifiable request, by simply following the instructions below.

Instructions for not allowing the sale of personal information

If you wish to know more, or exercise your right to opt-out in relation to all sales made by this Application, both online and offline, you may contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to enable the operational functioning of this Application and its features (“business purposes”). In such cases, your personal information will be processed in a manner necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated in the “Detailed information on the processing of personal data” section in this document), as well as to comply with the law and defend our rights before the competent authorities, where our rights and interests are threatened or we suffer actual harm.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them The right to know and portability

You have the right to ask us to disclose to you:

the categories and sources of the personal information we collect about you, the purposes for which we use your information, and with whom such information is shared; in the event of a sale of personal information or disclosure for a commercial purpose, two separate lists where we disclose for sales, the categories of personal information purchased by each category of recipient; and for disclosures for commercial purposes, the categories of personal information obtained by each category of recipient. The disclosure described above will be limited to personal information collected or used over the past 12 months.

If we deliver our response electronically, the enclosed information will be “portable”, i.e. delivered in an easily usable format to allow you to transmit the information to another entity without hindrance – provided this is technically feasible.

Right to request deletion of your personal information

You have the right to request the deletion of any personal information, subject to exceptions provided by law (such as, but not limited to, where the information is used to identify and repair errors in this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights, etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and instruct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you must make your verifiable request to us by contacting us using the details provided in this document.

In order for us to respond to your request, we need to know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must be made by:

provide sufficient information to enable us to reasonably verify that you are the person about whom we collect personal information or an authorised representative; describe your request in sufficient detail to enable us to understand it, assess it, and respond appropriately. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession that actually relates to you.

If you cannot personally submit a verifiable request, you may authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you may make a verifiable request on behalf of a minor under your parental authority.

You can file a maximum number of 2 requests over a 12-month period.

How and when your application is expected to be dealt with

We will confirm receipt of your verifiable request within 10 days and provide information on how we will process your request.

We will respond to your request within 45 days of receipt. If we need more time, we will explain the reasons, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfil your request.

Our disclosure(s) will cover the previous 12 month period.

If we deny your request, we will explain to you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices to you.