1 July 2022.
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate your giving us the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Our EU representative is Ruben Onderdelinden and can be contacted at email@example.com.
What is Personal Data?
The definition of personal data varies by different laws and regulations established around the world.
Under the GDPR, Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). It includes your name, email address, telephone number, or mailing address, and other information that directly identifies who you are. It also includes information that may be used to uniquely identify you, or a device you use, such as a cookie, or unique identifier. The Internet Protocol (IP) address associated with a computer you use to access our Site, Solution or Application is considered personal data.
For the purpose of the Data Protection Act 2018, Glisser is the Data Controller and our Data Controller registration number is ZA062440. For the purposes of GDPR, Glisser may also act as the Data Processor on behalf of its clients.
For clarity, we act in these two roles as follows:
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1. COLLECTION OF PERSONAL INFORMATION AND REQUESTS FOR CONSENT
1.1 We need to collect certain personal details from you as a Customer so that you may use the Solution, to facilitate the provision of the Solution, and to maintain our quality standards. These details may include your name, email address, contact details, company name and other basic information (together, “Customer Personal Data”). You can amend or update the information you have provided at any time.
1.2 We need to collect a unique identifier from you as Audience Member when you use the Application in order to facilitate the provision of the Solution, to allow you use the Application, and to receive the Content. As standard we only collect an Audience Member’s email address (“Audience Personal Data”) unless an alternative unique identifier is selected by our Customer.
1.3 By registering your details on the Site you permit us to process your Customer Personal Data and contact you via email or telephone, for the purposes of monitoring the provision of the services through the Site, the Application and the Solution, in order to fulfil our contract to you as a Customer.
1.4 By registering your details on the Site as a free user you permit us to process your Customer Personal Data and contact you via email or telephone, for the purposes providing you with relevant information pertaining to our Site, the Application and the Solution, and ensuring you are happy with the level of service you are receiving, on the basis of legitimate interest as a Customer.
1.5 By registering your details on the Application, you consent to us, and the providers of any presentations you attend via the Solution, to process your Audience Personal Data in order for the Application and the Solution to function allowing you to participate in the Event and receive the Content, and participate in any interactivity, on the basis of legitimate interest as an Audience Member.
1.6 When registering your details on the Application you are able to provide clear consent to the processing and use of your Audience Personal Data for a specific purpose, as defined by us and/or our Customers at the point of providing that data. You have the option of not providing consent, in which case your personal details will only be held in order to provide product functionality according to our Terms.
1.7 Provided that you consent to receiving such communications, we (where the Presenter is using our free Solution) or our Customers (the providers of any Presentations you have attended via the Solution) may send you promotional emails about our or their own or third parties’ product developments, new products or special offers, or other information which we or they think you may find interesting, or for market research purposes, as defined at the point of consent.
1.8 Visitors to our website have the opportunity to download content by providing basic information including an email address (“Visitor Personal Data”). By registering your details on the Site in order to download information as a Visitor you are able to provide clear consent to the processing and use of your Visitor Personal Data for a specific purpose, as defined by us at the point of providing that data.
1.9 We will not share, trade or sell your personal information to any company or parties not directly associated with its proper use within the Site or as described above, except when you give us explicit permission.
1.10 We collate information such as site traffic, sales and interaction data which we may use for internal purposes or pass on to third parties (whether within or outside the EEA). This information does not include any data which can identify you or contain confidential information. It does not meet the definition of Personal Data under the GDPR or the Act.
1.11 In certain circumstances we may have a legal obligation to disclose personal information, and we reserve the right to do so.
1.12 Under certain conditions the individual has the right to invoke binding arbitration,
1.13 Appropriate technical and organisational measures are taken to protect personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into consideration the state of the art, the risks involved, and the rights of natural persons. Risks are analysed and controlled under the ISO27001 certification.
2. HOW WE STORE, PROCESS AND TRANSMIT YOUR PERSONAL DATA
2.1 Customer Personal Data and Audience Personal Data will be held by Glisser, implementing appropriate technical and organisational safeguards to maintain its privacy and security. However, it should be noted that data transfers may take place over Wi-Fi or mobile networks over which we have no control. No Customer Personal Data and only very limited Audience Personal Data is transferred between devices via our Application. This is limited to the email address entered into the device of the Audience Member using the Application. Email address details are only stored on our password-protected website.
2.2 Your Personal Data, including back-ups, is stored in the Microsoft Azure Cloud in the European Economic Area (“EEA”) and/or the UK. More information on the physical security at this data centre is available from Microsoft: https://www.microsoft.com/en-us/trustcenter/privacy/
2.3 Your Personal Data may be transferred to, and stored or otherwise processed at a destination within the EEA, in the UK or outside the EEA. Your Personal Data may be shared with a subsidiary or an affiliate entity within the Glisser corporate family, or a third party entity required to deliver the Solution. This may involve transferring your data outside the EEA.
2.4 Whenever we transfer your Personal Data out of the UK and/or EEA for storage or processing, we will take all reasonable steps necessary to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
2.5 Notwithstanding clause 2.4, we will not transfer your Personal Data to the United States, unless accessed by your users in the United States.
2.7 The transmission of information via the internet is not completely secure. Although we do our best to protect Personal Data, and while we transfer all data over a secure transport method, we cannot guarantee the security of your data whilst it is being transmitted to or from our website. Any transmission is at your own risk.
3. RETENTION OF YOUR DATA
3.1 We will retain Customer Personal Data for two years after the Customer has ceased their use of the Solution. All uses of Customer Data will remain subject to the provisions of the Agreement.
3.2 We will retain Audience Personal Data collected on behalf of Customers for six months after the associated Customer has ceased their use of the Solution, unless otherwise requested by the Customer.
3.3 We will retain Visitor Personal Data for two years after the point at which it was submitted to our website or the last email contact with that individual.
3.4 The individual can choose (opt out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorised by the individuals.
3.5 Sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership) is not collected by Glisser.
4. YOUR RIGHT TO REQUEST INFORMATION
4.1 You have the right to request copies of all Personal Data processed by us relating to you, and the right to erasure of any Personal Data (except those processes based upon legal obligation or public task).
4.2 You have the right to withdraw consent for us to process your data based upon this consent. You can request erasure or withdraw consent at any time via the contact form on this website. We will not charge for initial requests, but may make a small charge to cover our administrative costs on repeat requests.
4.3 For security reasons we may ask for proof of your identity before we disclose information about you, or to you, via email or over the telephone.
5. LINKS TO THIRD-PARTY SITES
6. COLLECTION OF TECHNICAL DATA AND COOKIES
6.2 We may use the following cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of the website.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to the website. This enables us to personalise our content for you, greet you by name and remember your preferences.
(d) Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
6.3 By using the Site, you agree that we can place the following cookies on your device:
(a) Session cookie. This cookie allows users to stay logged into the website whilst using it. This cookie is essential for the website as it enables us to manage communication between our servers. The session cookie contains the API key and an expiry time stamp. When the user logs out the cookie is destroyed.
(b) Google Analytics Tracking. This cookie allows us to estimate our audience size view and analyse site usage. This cookie does not store information that can be used to identify individual users.
(c) Google Adwords Remarketing Cookie. This cookie resides on the user’s computer and allows Google Adwords to show ads promoting Glisser to previous site visitors.
7. CONTACTING OTHER USERS THROUGH THE WEBSITE OR APPLICATION
7.1 If you send a message to other users via the Solution then in doing so you are providing them with the information in that message. Glisser will not have any responsibility for how they use this information.
8.1 Glisser complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Glisser has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
8.2 Glisser commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
8.3 Glisser is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).