In case of having any questions about the Privacy Policy, the user can contact Glush Agency Limited through the following means:
The user may establish direct and effective communication with Glush Agency Limited by written communication sent to any of the indicated addresses or also by sending an email to the address: [email protected]
In addition, information of the officer in charge of processing your personal data is listed below:
In compliance with current regulations on the protection of personal data, especially:
Glush Agency Limited collects personal data in its possession when the user:
Glush Agency Limited collects information when visiting its web page, and mainly by completing its registration forms.
The following data is collected: full name, email and phone number.
As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required 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 the data provided by him are true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof.
Likewise, the user acknowledges that the data required by Glush Agency Limited are necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfil if said data are not provided.
Any false or inaccurate statement that occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user.
The personal data requested to the user will be used for the following purposes:
To provide our Service and fulfill your requests. We use your information to provide and maintain our Service, to process and fulfill your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your inquiries, and for other customer service and business administration purposes. For example, when you enroll in a newsletter, we may use your personal information to deliver that newsletter to you.
Identification and authentication purposes. We may use your information for identification and authentication purposes. For example, when you enter your account login ID and password to enter one of our registration or login portals, we use your login credentials to authenticate your identity.
Personalization. We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Service. For example, if you allow us to collection geolocation data, we use this information to deliver content that is around your specific location and identify business location/listings around your location.
Marketing and promotional purposes. We may use your information to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to otherwise contact you about information we think may be of interest to you. We may also use your information to display advertisements to you on our site (including to sell advertising space on the Service) and on other unaffiliated websites and services.
Research and reporting. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products, services, and educational information we provide. The survey responses may be utilized to determine the effectiveness of our Service, various types of communications, advertising campaigns and/or promotional activities.
Combining information. We (and our third party business partners on our behalf) may merge, co-mingle, or otherwise combine information, including your personal information, in furtherance of the purposes described above.
To comply with legal obligations. We may use your information to comply with our legal obligations or to exercise or defend our rights or the rights of a third party, including complying with law enforcement or government authority requests and participating in compliance audits.
To protect us and others. We may use your information where we believe it necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person or to otherwise enforce this Policy, our Terms and Conditions, and the integrity of the Service.
Deidentified data. We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by us or another party, and we may use this deidentified data for any purpose permitted under applicable law. To the extent we deidentify any data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data.
The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics, managing incidents or conducting market studies. However, in the event that personal data is processed for a purpose other than that initially specified when collecting said data, a compatibility analysis will be carried out by Glush Agency Limited in accordance with applicable regulations. The processing will only be authorized if the original purpose is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or legal justification for the processing of their data.
We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from Glush Agency Limited, reliably notifying Glush Agency Limited, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, it may send an email to the address indicated in Section 2, a postal mail addressed to the address indicated in Section 2 hereof, or directly follow the unsubscribe instructions detailed at the end of each email of Glush Agency Limited.
We will use the information we collect about you for the following purposes:
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.
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 may only use these social networks to the extent that they are registered in 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:
Business transfer: If we or our subsidiaries are acquired, merged, or invested in by another company, or if any of our assets are transferred or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain information about you to lenders, auditors, and outside advisors, including lawyers and consultants.
Compliance with the law: We may disclose your personal information to comply with the law, a legal proceeding, a court order, or other legal process, such as in response to a court order or subpoena.
Protection and Facilitation of Rights: We may disclose your personal information when we believe it is appropriate to investigate, prevent, or take action against illegal activities, suspected fraud, situations that may pose potential threats to the safety of any person, or violations of our Terms and Conditions or this Policy. This disclosure may also include using your personal information as evidence in litigation in which we are involved. Additionally, we may disclose your personal information when necessary to assist you in exercising your rights under the Terms and Conditions of Glush Agency Limited and this Privacy Policy.
Reasons related to public safety, national defense, or public health: In situations where there are well-founded reasons related to the safety of the community, national defense, or public health, your personal information could be disclosed.
Aggregate, anonymized, or de-identified information: We may disclose aggregate, anonymized, or de-identified information about you for any purpose permitted by applicable law.
Consent: We may disclose your personal information with your consent.
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 RGPD, LGPD, CCPA, and nFDPA Swiss 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 and following of the RGPD, the provisions of the LGPD, the provisions of the CCPA, the provisions of the nFDPA, 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.
If you are located in the UK or EEA, and subject to national or local law exemptions, you have certain data protection rights in certain circumstances. Please contact us if you would like to exercise any of these rights.
Glush Agency Limited has appointed delegate for the application and control of this Privacy Policy and the relationship with the application authority to Goncalo Sa who can be contacted by the following means:
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.
You may have certain rights regarding our processing of your personal information under applicable local law. If our processing of your personal information is governed by such laws, this section provides you with additional information regarding your rights and our processing of your personal information under applicable local law.
MARKETING COMMUNICATIONS
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
DATA RETENTION
Your personal information will be held for only so long as it is necessary for the purpose for which it was originally collected, and in accordance with applicable local law. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy. When assessing retention periods, we first examine whether it is necessary to retain the personal information collected and, if retention is required, work to retain the personal information for the shortest possible period permissible under applicable law.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
YOUR PRIVACY CHOICES AND RIGHTS
Depending on the jurisdiction in which you live, you may have the following rights under applicable local law:
These rights may be limited or denied in some circumstances. For example, we may retain your personal information where required or permitted under applicable law.
You may also opt-out of our “sale” or “sharing” of your personal information through privacy preference signals recognized under applicable local law, such as the Global Privacy Control (GPC), but please note that this signal will be linked to your browser only. For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/.
VERIFICATION PROCESS
In order to protect your information, we will confirm a requestor’s identity before responding to any request. To start the process, you must provide your name and email. We will ask you at least one question, and you must reply by email with the correct answer for each question based on your previous interaction with us. If we still cannot verify your identity as required by applicable laws, we will let you know and may ask additional questions. Otherwise, we will acknowledge your request and contact you later with our full response.
We will only send verification questions from [email protected]. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our verification email address listed above, do not respond.
Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.
AUTHORIZED AGENTS
You may designate an authorized agent to exercise your rights under applicable laws on your behalf.
Pursuant to applicable laws:
You must provide the authorized agent written permission to exercise your rights under applicable laws on your behalf.
We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by applicable laws.
Even if you use an authorized agent to exercise your rights under applicable laws on your behalf, pursuant to applicable laws we may still require that you verify your own identity directly to us.
FINANCIAL INCENTIVES
“Financial incentive” means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, sale, or sharing of personal information.
The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer’s data. A business must be able to explain how the financial incentive or price or service difference is reasonably related to the value of the consumer’s data.
The explanation must include:
We do not offer financial incentives to collect personal information and we will not discriminate against you if you exercise any of the rights provided by applicable laws set forth in this Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by applicable laws.
APPEALS
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
CALIFORNIA RESIDENTS
California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated.
With your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
This is the current version of the Glush Agency Limited Privacy Policy, updated on November 17, 2023.
Glush Agency Limited may at any time and without prior notice, modify this Privacy Policy. Such modifications will be operative from their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed about the terms included here by entering periodically.
Office 11997, 182-184 High St N
London, E6 2JA
United Kingdom
+44 (0) 74 1195 6326
59350 Saint-André-lez-Lille
France
+33 (0) 6 47 49 49 67
