1. Introduction and defined terms
2. About us
3. Fraud Detection Service
4. Customers with a loan powered by Glow via our Corporate Clients
5. Website Users
6. Employees or Potential Employees
7. Corporate Clients
8. Third-Parties
9. How we market Glow's products and services
10. How we use automated decision-making
11. Where we process your information
12. Your legal rights in relation to your information
13. Keeping you up to date
14. Contacting us
15. All changes to this Notice

Privacy Notice

1 – Introduction and defined terms

We at Glow Financial Services Limited (the “Company”, “Glow”, “we”, “us” or “our”) are committed to protecting the privacy and security of your personal information and ensure that all personal data handled by us is done so in accordance with the applicable data protection laws and regulations and guidance laid out by the Information Commissioner’s Office (“ICO”).

This Privacy Notice (“Notice”) explains how we process, collect, use, and disclose personal information about you when you interact with Glow in varying capacities, including as a borrower of a loan product or service in relation to a purchase from our corporate client or its (together “Corporate Client”), a job applicant, a user of this website (“Website”), a Glow employee or an employee or representative of our Corporate Clients or our suppliers.

For the purpose of applicable data protection law, including the Data Protection Act 2018 and UK GDPR (together, “DP Law”), Glow is the Data Controller of your personal information that we collect, hold, and process.

This Notice was last updated April 2024. For a summary of all updates to this Notice, please refer to Section 15 ‘All changes to this Notice’.

2 – About us

Glow is a company registered in England with Company No. 09127663.

Our contact details are:

Company name: Glow Financial Services Limited

Registered Address: 71 Queen Victoria Street London EC4 4AY

Phone Number: +44 (0)207 126 8167

E-mail: dataprotection@glowgfs.com

We are authorised and regulated by the Financial Conduct Authority ( Reference Number: 751308 ). Find out more about us at https://www.glowfinsvs.com/

3 – Fraud Detection Service

What and how we collect

Contact information

• Your name, surname, and title
• Your date of birth
• Your contact details such as your email address, telephone number(s)
• Your home address
• Your residential status and address details for the last three (3) years.

Financial information

• Your occupation and annual income
• Your employment statusYour employer’s details
• Your bank details, including: your bank name and address, sort code and account number
• Number of dependants.

Information relating to your access and use of our services or that of our Corporate Client

Information relating to your access and use of our services, including but not limited to:

• Your IP address
• Your locationDevice type
• Software used
• User name and passwords.

Loan Information

• Your delivery address
• Information about your loan (including your payment history)
• Information which allows us to create your user account and your unique agreement number
• Your passwordInformation about the products or services being purchased.

We collect this information from you directly when you access our or our Corporate Client’s services and/or products, and from Fraud Detection agencies.

Information relating to your identity

In some instances, where you have applied for a Glow loan product, we may also process the following:

• A copy of your photo identification documents (such as a valid passport or current driving licence)
• Selfie – as defined by the ICO, this is biometric data used for identity verification purposes and is therefore processed according to special category information requirements.

4 – Customers with a loan powered by Glow via our Corporate Clients

What and how we collect

Contact information

• Your name, surname, and title
• Your date of birth
• Your contact details such as your email address, telephone number(s)
• Your home address
• Your residential status and address details for the last three (3) years.

Financial information

• Your occupation and annual income
• Your employment statusYour employer’s details
• Your bank details, including: your bank name and address, sort code and account number
• Number of dependants.

Information relating to your access and use of our services or that of our Corporate Client

Information relating to your access and use of our services, including but not limited to:

• Your IP address
• Your locationDevice type
• Software used
• User name and passwords.

Loan Information

• Your delivery address
• Information about your loan (including your payment history)
• Information which allows us to create your user account and your unique agreement number
• Your passwordInformation about the products or services being purchased.

We collect this information from you directly when you access our or our Corporate Client’s services and/or products, and from Fraud Detection agencies.

Information relating to your identity

• A copy of your photo identification documents (such as a valid passport or current driving licence)
• Selfie – as defined by the ICO, this is biometric data used for identity verification purposes and is therefore processed according to special category information requirements.

5 – Website Users‍

What and how we collect

Emails submitted by Website Users

• The information we collect via emails depends on the content of the emails but can include personal information.

6 – Employees and Potential Employees‍

What and how we collect

Recruitment Information

• CV
• Interview questions and interview notes
• Offer Letter.

Payroll information

• Payroll information

Personnel Files

• Copy of passport (or other right to work documentation) and driver’s licence
• Redundancy details, calculations of payments and refunds
• Sick certificates, self certificates and medical records
• References
• Credit Check results
• Criminal Record Check results
• Contract of Employment
• Confidentiality Letters (including Non-disclosure agreements)
• Name, Address, personal email and telephone number
• PPS NumberDate of birthDetails of next of kin
• Qualification certificates
• Performance scoring/rating documents
• Disciplinary warning and investigations
• Grievances
• Absence data
• Training Completion details
• Maternity and Paternity details.

7 – Personnel of our Corporate Clients‍

What and how we collect

Business Contact information:

• Your name, surname, title and job role
• Your contact details such as your address, email address, telephone number(s).

Information relating to your access and use of our services, including but not limited to:

• Your IP address
• Your location
• Device type
• Software usedUser name and password.

Personnel Files

• Copy of passport (or other right to work documentation) and driver’s licence
• Redundancy details, calculations of payments and refunds
• Sick certificates, self certificates and medical records
• References
• Credit Check results
• Criminal Record Check results
• Contract of Employment
• Confidentiality Letters (including Non-disclosure agreements)
• Name, Address, personal email and telephone number
• PPS NumberDate of birthDetails of next of kin
• Qualification certificates
• Performance scoring/rating documents
• Disciplinary warning and investigations
• Grievances
• Absence data
• Training Completion details
• Maternity and Paternity details.

8 – Third-Parties‍

What and how we collect

Business Contact information:

• Your name, surname, title and job role
• Your contact details such as your address, email address, telephone number(s).

Information relating to your access and use of our services, including but not limited to:

• Your IP address
• Your location
• Device type
• Software usedUser name and password.

9 – How we market Glow's products and services

Glow may send you marketing promotions about products and services, where you have provided your consent to do so either to us or our Corporate Clients. There may be exceptions where we can inform you about other products or services where we are allowed to do so under DP Law. Glow may share your personal information with our Corporate Client for the purposes of our Corporate Client contacting you with marketing promotions.

10 – How we use automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. These decisions can be based on factual data, as well as on digitally created profiles or inferred data.

As part of our processing of your personal information, we may take decisions by automated means. In the context of the products and services provided to our Corporate Clients, we use automated decision-making in some aspects of our fraud detection and prevention. Where you may be applying for a loan, you may be automatically considered to pose a fraud risk if our processing suggests fraudulent activity which may mean you are found to not be eligible for our products and services provided to our Corporate Clients, resulting in your application being rejected.

The logic involves data matching which compares sets of data, such as your phone number against other records held by the same or another body to see if they match. The data is usually personal information. The data matching allows potentially fraudulent applications to be identified and for your application to be potentially declined. It also allows us to identify non-fraudulent activity. You have rights in relation to automated decision making (refer to section 12: ‘Your legal rights in relation to your information’ ).

We do not use any automated decision-making in relation to our website users, employees, potential employees, Corporate Clients, or third-parties.

11 – Where we process your information

Glow processes all your information in the United Kingdom (UK) but may need to transfer your information outside the UK to service providers, agents, or subcontractors, and to carry out the Fraud Detection services and carrying out Glow’s business activities.

In some cases, data protection laws outside of the UK may not provide the same level of protection as those in the UK. Where we share your personal information with service providers, agents or subcontractors located in a country that has not been approved by the ICO as having a suitably high standard of data protection law, we will use specific contracts (known as Standard Contractual Clauses) approved for use in the UK, and if necessary additional supplementary measures, which give personal data the same protection it has in the UK.

Financial information, contact information, information relating to your identity and information relating to your access and use of our services (including your IP address, your location, and the device being used) may be processed in the US, Ireland, the Netherlands and Germany.

Please contact our data protection team at dataprotection@glowgfs.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

12 – Your legal rights in relation to your information

You have several rights under DP Law that you may wish to exercise. These include the right to:

• Access or obtain copies of your personal information;
• Rectification, you have the right to request inaccurate information about you corrected;
• Request restriction of processing concerning you or to object to processing of your personal data;
• Request erasure of your personal data where it is no longer necessary for us to retain;Object to automated decision-making;
• Data portability including to obtain personal data in a commonly used machine-readable format in certain circumstances such as where our processing of it is based on your consent
• Withdraw consent to any processing for which you have previously given that consent (regardless of our legitimate interest).

Where you exercise any of your rights, you have the right to be informed about the potential consequences of such exercise. For example, if you ask us to remove all contact details like email addresses and phone numbers, this would mean we have no way to contact you about your loan/agreement.

Please contact us at dataprotection@glowgfs.com if you would like to exercise any of your rights in relation to your personal information. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we are allowed under DP Law to charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we can refuse to comply with the request in such circumstances.

We sometimes need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.

We will act upon the request without undue delay and at the latest within one (1) month of receipt. We may extend the time to respond by a further two (2) months if the request is complex or we have received several requests from the same person. In these circumstances, we will let you know without undue delay and within one (1) month of receiving your request and explain why the extension is necessary.

It is also important that the personal information we hold about you is accurate and current. You need to keep us informed if your personal contact information changes by emailing dataprotection@glowgfs.com.

Without prejudice to any other administrative or judicial remedy you might have, you have the right to lodge a complaint with the Information Commissioner if you consider that we have infringed applicable data privacy laws when processing your personal data. The Information Commissioner’s Office can be contacted using the following link: https://ico.org.uk/.

13 – Keeping you up to date

We keep this Notice under regular review. We may change this Notice from time to time by updating it to reflect changes in the law and/or our privacy practices. The date at the top of this Notice will be updated accordingly and we encourage you to check this from time to time for any updates or changes. We may also contact you to let you know that we have updated the Notice. We may also take that opportunity to ask you if you would like to update your marketing preferences.

14 – Contacting us

If you have any questions regarding our Privacy Notice, please email us at dataprotection@glowgfs.com.

15 – All changes to this Notice

April 2024:

1. Adding Section 15 ‘All changes to this Notice’ to summarise all changes that have been made to the Notice.
2. Providing more detailed information on what information we collect from you and how it is processed to provide you with greater transparency.
3. Adding more detail to the time periods we hold your personal information for depending on the circumstances and any applicable laws. Glow Financial Services Limited (“Glow”), 71 Queen Victoria Street London EC4V 4BE. Registered in England No. 09127663. Glow is authorised and regulated by the Financial Conduct Authority (Reference No. 751308). The register can be accessed through www.fca.org.uk

January 2025:

1. Updated Glow's data retention period as disclosed in section 3 & 4.