INTRODUCTION

Welcome to the Glo website. This Privacy Notice explains what we do with your personal information when you visit www.discoverglo.com (“Website”). It describes how we collect, use and process your personal information, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your rights.

For the purpose of applicable data protection legislation, Nicoventures Trading Limited, a company incorporated in England and Wales with company number 06665343, whose registered office is at Globe House, 1 Water Street, London, WC2R 3LA, United Kingdom (“we”, “our” or “us”) is the ‘controller’ of your personal information. This means we decide why and how your personal information is used and are responsible for protecting it. Please refer to the end of this notice for our contact and company information.

We may amend this Privacy Notice from time to time. Please visit this page regularly as we will post any changes here. Where appropriate, we may also notify you of the changes by email. Please see further the section Changes below.

If you are dissatisfied with any aspect of this Privacy Notice, you may have legal rights which we have described below where relevant.

CONTENTS

1. Information we collect about you
2. How we use your information
3. Verifying your age
4. Marketing
5. Automated decision-making
6. Sharing your information with third parties
7. Where we store your information
8. How we safeguard your information
9. How long we keep your information
10. Your rights
11. Changes
12. How to contact us

1. INFORMATION WE COLLECT ABOUT YOU

We collect personal information that you submit to us online via the Website or give to us when you contact or otherwise communicate with us. This information includes:

• your name;
• email address;
• confirmation that you are 18 years of age or older;
• details of your marketing preferences;
• information that you submit in any correspondence we have with you over email or phone; and
• technical information about your visit, including details of your visits to the Website and your navigation around the Website, traffic data, information about the device you use to access the Website, your Internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (collectively “Device Data”).
We also collect information about how visitors use our Website by using cookies and similar technologies. To learn more about how we use cookies, please see our Cookies Policy.
For details of the lawful bases that we rely on to be able to use and process your personal information, please see How we use your information.

2. HOW WE USE YOUR INFORMATION

The purposes for which we use your personal information and the lawful basis under data protection laws on which we rely to do this are explained below.

Where you have provided CONSENT

If you provide us with your consent, we will rely on this:

• to send you marketing communications by email;
• to use your Device Data for analytical and insight purposes;
• to use any personal information we receive through the use non-essential browser cookies on your device (please see our Cookies Policy for more information); and
• to identify and record when you have received, opened, forwarded or engaged with our electronic communications, or our Website (please see our Cookies Policy for more information);

You may withdraw your consent at any time. Please see the Marketing section below for further details.

Where it is required to performed the terms of our CONTRACT
We may use certain cookies and obtain personal information which are essential to allow you to access and use the Website and to provide the Website in accordance with our Terms of Use.

Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations, including where the law requires us:

• to identify you when you contact us;
• to verify the accuracy of data we hold about you;
• to remember whether you have provided your consent for cookies to be used on your device;
• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
• to verify you are old enough to use the Website (please see Verifying your age for further details); and
• to respond or assist public authorities, regulators, the courts or the police or other criminal investigation bodies;

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue the following legitimate interests (whether ours, in connection with our business, or that of a third party), for the following purposes:

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

• for analysis and insight conducted to understand our audience, inform our marketing strategies, and to enhance your visitor experience; and
• to send you market research surveys and related communications and to use your responses to those communications individually, or combined with responses from other individuals, for insight purposes;

Processing necessary for us to support Website visitors with their enquiries

• to respond to correspondence you send to us and fulfil the requests you make to us;
• processing necessary for us to respond to changing market conditions and the needs of our visitors;
• to analyse, evaluate and improve our Website so that your visit and use of the Website is more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);
• to ensure that the Website’s content is presented as effectively as possible for you;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

• to administer the Website and for internal operations, including troubleshooting, testing, statistical purposes;
• to verify the accuracy of data that we hold about you and create a better understanding of you as a visitor or customer, including by linking your personal information with other information or records we, our group companies or third party data providers hold about you;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• to correspond or communicate with you in relation to administrative, legal and business matters;
• for the purposes of corporate restructure or reorganisation or sale of our business or assets;
• for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
• to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
• to inform you of updates to our terms and conditions and policies;
• for our internal purposes, such as quality control, Website performance, system administration and to evaluate use of the Website, so that we can provide you with enhanced services;
• for other general administration including managing your queries, complaints, or claims, and to send service messages to you.

3. VERIFYING YOUR AGE

As this Website relates to vaping and vaping products, we are legally obliged to ask visitors to confirm that they are aged 18 years or over. You cannot use the Website if you indicate that you are under the age of 18.

4. MARKETING

We may collect your preferences to send you marketing information directly from us by email, if you sign up to our newsletter.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above at any time. Please see Your rights below for further details on how you can do this.

5. AUTOMATED DECISION MAKING

We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this Privacy Notice and inform you if this position changes.

6. SHARING YOUR INFORMATION WITH THIRD PARTIES

We will share your information primarily to ensure that we provide you with the most exciting and up to date products. We may share your information with any of the following groups:

• any of our group companies, where this is necessary for administration or audit purposes or for any of the purposes listed above, and in accordance with laws on data transfers;
• tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
• third party service providers who perform functions on our behalf (including external consultants and professional advisers such as lawyers, auditors and accountants, technical support functions, analytics and IT consultants carrying out testing and development work on our business technology systems);
• third party market research providers such as Kantar and Ipsos;
• third party outsourced IT providers where we have an appropriate data processing agreement (or similar protections) in place; and
• if any of our group companies merge with or are acquired by another business or company in the future, we may share your personal information with the new owners of the business or company, as well as with any administrators or insolvency practitioners, where they are involved (and provide you with notice of this disclosure).

We may share the non-personal aggregated statistical data about visitors to the Website with third parties for analytics and statistical purposes.

7. WHERE WE STORE YOUR INFORMATION

Your personal information may be transferred outside of the UK and the European Economic Area (EEA) to the third parties described in Sharing your information with third parties.

We want to make sure that your personal information is stored and transferred in a way which is secure. We will therefore only transfer data outside of the UK and EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

• by way of an intra-group agreement between BAT entities, incorporating the current standard contractual clauses adopted by the European Commission, the UK Information Commissioner’s Office or other competent body for the transfer of personal information to jurisdictions without adequate data protection laws;
• by way of a data transfer agreement with a third party, incorporating the current standard contractual clauses adopted by the European Commission, the UK Information Commissioner’s Office or other competent body for the transfer of personal information to jurisdictions without adequate data protection laws;
• by transferring your data to an entity which has signed up to the EU-U.S. Privacy Shield Framework for the transfer of personal information from entities within the UK and EEA to entities in the United States of America or any equivalent agreement in respect of other jurisdictions;
• by transferring your data to a country where there has been a finding of adequacy by the European Commission, the UK Information Commissioner’s Office or other competent body in respect of that country's levels of data protection via its legislation; or
• where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract; or
• where you have consented to the transfer.
Where we transfer your personal information outside the UK and EEA and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Notice. You can ask to see these by contacting us using the contact details below.

8. HOW WE SAFEGUARD YOUR INFORMATION

We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal information.

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately by contacting our Head of Legal and External Affairs using the details provided at the end of this notice.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information whilst transmitted to the Website and any such transmission is at your own risk.

The Website may from time to time contain links to and from other websites. If you follow a link to any of those websites, please note that those sites ought to have their own privacy notices and that we do not accept any responsibility or liability for those sites or for their privacy notices. Please check those privacy notices before you submit your information to those websites.

9. HOW LONG WE KEEP YOUR INFORMATION

We will keep your information relating to orders you have placed with us as required by law or other regulation (for example, because of a request by a tax authority or in connection with any anticipated litigation).

If you have signed up to receive email marketing from us: we will store your personal information for as long as you are subscribed to our email marketing list. If you unsubscribe or are otherwise removed from our marketing list, we will keep your email address on our suppression list to ensure that we do not send you marketing emails.

If you have contacted us with a complaint or query: we will store your personal information for as long as is reasonably required to resolve your complaint or query.

The exceptions to the above are where:

• we have carefully considered whether we need to retain your personal information after the periods described above to potentially establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement;
• we actually bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
• you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Right to restrict processing below);
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Right to erasure below); or
• in limited cases, a court or regulator requires us to keep your personal information for a longer or shorter period.

When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems (either by erasing or anonymising that data). After that time, we may retain aggregated data (from which you cannot be identified) and retain it for analytical and statistical purposes.

10. YOUR RIGHTS

You have a number of rights in relation to your information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either: (i) the date that we have confirmed your identity; or (ii) where we do not need to do this because we already have this information, from the date we received your request.

Right to object

This right enables you to object to us processing your personal information where we do so for one of the following reasons:

• where we rely on our legitimate interests to do process your information;
• to enable us to perform a task in the public interest or exercise official authority;
• where your right to withdraw consent does not apply; or
• for scientific, historical, research, or statistical purposes.

Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your personal information for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your personal information.

Right to withdraw consent

Where we have obtained your consent to process your personal information for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your personal information for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

To withdraw your consent to marketing communications, please use the unsubscribe tool in the relevant communication.

Right of access (‘Data Subject Access Requests’)

You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

If you would like to request access to your information, it would assist us with dealing with your request if you could use the subject heading ‘Data Subject Access Request’, or quote this over the phone, when contacting us. Please note that this is not mandatory and we will still deal with any requests without this reference.

Right to erasure

You have the right to request that we erase your personal information in certain circumstances. Normally, this right exists where:

• the data is no longer necessary;
• you have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;
• the data has been processed unlawfully;
• it is necessary for the data to be erased in order for us to comply with our obligations under law; or
• you object to the processing of your data and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

Right to restrict processing

You have the right to request that we restrict our processing of your personal information in certain circumstances, for example if you dispute the accuracy of the personal information that we hold about you, you object to our processing of your personal information for our legitimate interests or you require us to keep it in connection with legal proceedings. If we have shared your personal information with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal information.

We may only process your information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

Right to rectification

You have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties to whom we have disclosed the inaccurate or incomplete personal information. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability

If you wish, you have the right to transfer your personal information between service providers where we rely on your consent or the performance of your contract as the lawful basis to use that information. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you if technically possible.

Rights relating to automated decisions

In certain circumstances, you may contest a decision made about you based purely on automated processing and where the processing is not required by law. You may also ask us to stop making such decisions using automated processing alone.

Right to complain

You have the right to lodge a complaint with your local supervisory authority which is the Information Commissioner's Office in the UK. You can contact them in the following ways:

• Phone: 0303 123 1113
• Email: casework@ico.org.uk
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

How to exercise your rights

If you would like to exercise any of these rights, please contact us on the details provided under How to contact us. Please note that we may keep a record of your communications to help us resolve any issues that you raise.

11. CHANGES

We may make changes to this Privacy Notice at any time by posting a copy of the modified notice on the Website or, where appropriate, by sending you an email with that notice. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Website, whichever is the earlier.

12. HOW TO CONTACT US

If you have any queries about this Privacy Notice, including your rights in relation to your personal information, please contact Head of Legal and External Affairs or by post at:
Nicoventures Trading Limited, Globe House, 1 Water Street, London, WC2R 3LA If you wish to contact us with any general queries or concerns, you can write to us by post at the address above.

When contacting us by email or post, please use the subject heading ‘Data protection query’ so that we can direct your query to the appropriate department and deal with it promptly.

Last updated: 28 November 2019