https://iglu.net (the ‘Site’) is owned and operated by Iglu Network Ltd., a company registered in England and Wales, whose registered address is at 41 Devonshire Street, Ground Floor, London W1G 7AJ, United Kingdom.
Under this policy, we adhere to the European Union’s General Data Protection Regulation (the “GDPR”). For users outside of the European Union, the GDPR will be our minimum standard in handling your personal data under this Policy.
Definitions and Interpretation:
In this Policy the following terms shall have the following meanings:
“Personal Data”: In this Policy, Personal Data means any information from which a natural person can be identified. It does not apply to information that has been anonymised.
“Data Controller”: In this Policy, the Data Controller is the natural or legal person responsible for deciding how personal data is collected and stored and how it is used.
“Data Processor”: Data Processor is a natural or legal person which processes personal data on behalf of the controller.
“Third party”: Third Party is a natural or legal person other than the data subject, data controller, data processor and persons who, under the direct authority of the data controller or processor, are authorized to process personal data.
“Cookies”: Cookies means small text files placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites.
“Our Sites”: Our Sites means all websites within [Insert URL].
What Does This Policy Cover?
This Policy applies only to your use of Our Sites. It does not extend to any websites that are linked to from Our Sites (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
What Data Do We Collect?
Some data will be collected automatically by Our Sites, other data will only be collected if you voluntarily submit it via forms and consent to us using it for the purposes set out below.
We may collect some or all of the following data:
a) Usage data automatically collected during your visit on Our Sites
- IP address
- Web browser type and version
- Operating system
- Any information contained in URLs
- Any tracking information stored on your computer and sent automatically
b) Personal data and other information submitted to us by you through form submission
- Any data or personal data that you insert in the form
We only collect the data that is needed for us to perform our part in the given situation.
How Do We Use Your Data?
We may use your personal data for the following purposes:
- To contact you to provide answers to your enquiries.
- To supply our services to you.
- To process your applications and requests.
- To supply you with email newsletters. You would only receive email newsletters from us if you click to subscribe to Iglu newsletter before you submit the contact form. If you no longer want to receive email newsletters from us, you can unsubscribe from our mailing list any time.
- For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, marketing and your experience.
We will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
- processing is necessary to ensure our own legitimate interests or the legitimate interests of a third party (provided that your own interests and rights do not override those interests). Wherever we rely upon this basis, details of the legitimate interests concerned shall be provided to you.
How Do We Store Your Data?
We only keep your data for as long as we need to in order to use it as described above in section “How Do We Use Your Data?“, and/or for as long as we have your permission to keep it. The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of purpose the data is collected or the contract or the initiation of a contract.
Some or all of your data may be stored or transferred outside of the United Kingdom of Great Britain and Northern Ireland or the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Sites and submitting information to us. If we do store or transfer data outside the United Kingdom of Great Britain and Northern Ireland or the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and EEA under the GDPR or any other applicable data protection laws.
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Sites.
Steps we take to secure and protect your data include but not limited to:
- All data transfers are over encrypted channels.
- Wherever possible encrypted at rest.
- Proper access controls.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us.
Do We Share Your Data?
We may contract with third parties to supply services to you on our behalf. These may include search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
We currently share data with:
|Third Party Processor||Data Shared||Purpose|
We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We will not share such data with third parties such as prospective investors, partners and advertisers. Data will only be used within the bounds of the law.
In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or data controller.
How Can You Control Your Data?
When you submit information via Our Sites, you won&t be given options to restrict our use of your data, however, if you wish to restrict the usage of the data please contact the appointed data protection officer (DPO).
You may access certain areas of Our Sites without providing any data at all. However, to use all the features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.
You may withdraw your consent for us to use your personal data at any time by contacting us, and we will delete Your data from our systems. However, you acknowledge that this may limit our ability to provide the best possible services to you and some of the data will not be able to be deleted if there is any contradiction with the requirements of legislation, a court order, or a governmental authority.
How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact the appointed data protection officer (DPO).
Summary of Your Rights Under This Policy
Under this Policy, you have:
- the right to request access to, “deletion of” or “correction of”, your personal data held by us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to the processing of your personal data;
- rights with respect to automated decision-making and profiling.
If you have any questions, concerns, complaints, or requests regarding the use of your personal information, you can contact our Data Protection Officer as detailed below.
Data Protection Officer (DPO):
Name: Somluck Choopinij