Welcome to Glow Union https://glow-union.com/), a website operated by DELTARA LTD, a company registered in England and Wales (Company No. 17144041) with its registered office at 5 Brayford Square, London, England, E1 0SG. In this Privacy Policy you will find information about the types of personal data being processed, respective purposes and legal bases, how personal data is protected, as well as other important information related to the processing of your personal data. Please review this document carefully to understand our practices related to personal data processing, when providing to you our Services.
(1) DATA CONTROLLER
The Company acts as the data controller, which means it decides how and why your personal data is processed. It also ensures that all data processing activities comply with applicable data protection laws, including the UK General Data Protection Regulation (GDPR), Data Protection Act 2018 (UK) and other applicable regulations. Where users are located in the European Union, the processing of personal data is also carried out in accordance with Regulation (EU) 2016/679 (EU GDPR). Nothing in this Policy limits the mandatory data protection rights granted under EU law.
(2) CONTACT DETAILS OF YOUR DATA CONTROLLER
Name: DELTARA LTD
Address: 5 Brayford Square, London, England, E1 0SG
E-mail for communication: [email protected]
(3) DATA COLLECTION SOURCES
We collect personal data from various sources, including direct interactions where you provide information, such as when creating an account or making purchases. Additionally, we collect data automatically through cookies and similar tracking technologies. We also obtain data from third-party service providers (e.g., payment processors), government authorities or regulators, and publicly available sources.
(4) TYPES OF DATA COLLECTED
We may process the following categories of personal data:
- Contact Information: Full name, email address, phone number, postal address.
- Identification Data: Date of birth, place of residence, personal identification numbers, and details of identification documents.
- User Account Data: Account credentials, settings, activity logs, referral links and IDs, workplace information, and job role.
- Transaction and Payment Data: Details of orders, purchases, subscriptions, and other transactions. Payment information, such as bank account or payment card details, is processed securely by licensed third-party providers; the Company does not store full payment credentials. All financial data is handled in compliance with UK data protection standards.
- Technical Data: IP address, device type, browser details, and other technical information related to your use of the Website.
- Marketing Data: Your preferences and participation in marketing or loyalty programs.
- User-Generated and Uploaded Content: Any documents, files, or data you upload or share through your account or our services.
- Compliance Data: Information required to meet legal and regulatory obligations, including anti-money laundering (AML), counter-terrorist financing (CFT), know-your-customer (KYC), and similar processes.
- User Support Data: Information generated through support interactions, including technical issues reported, resolution details, and support agent communications.
(5) PURPOSES AND LEGAL GROUNDS FOR PROCESSING
We use your personal data to provide high-quality services. The ways we process your data and the reasons for doing so include:
- Account Management and Registration: To create and manage your user account, ensuring you can access and use our services effectively.Data processed: User Account Data, Contact Information, Identification Data, User Support DataLegal basis: Performance of the agreement (contract)
- Provision of Services: To deliver the services you request efficiently and in line with your needs.Data processed: Contact Information, Transaction Data, User Generated and Uploaded ContentLegal basis: Performance of the agreement (contract)
- Identity Verification: To confirm your identity and residence, protecting your account against fraud and unauthorized access.Data processed: Compliance Data, Identification DataLegal basis: Compliance with legal obligations; Legitimate interests
- Order Fulfillment: To process and complete your orders, ensuring timely and accurate delivery.Data processed: Contact Information, Transaction DataLegal basis: Performance of the agreement (contract)
- Legal Compliance: To comply with laws and regulations, including AML, CFT, KYC, and other legal requirements.Data processed: Contact Information, Identification Data, User Generated and Uploaded ContentLegal basis: Compliance with legal obligations
- Transaction Management: To manage transactions, ensuring accuracy, security, and compliance with relevant standards.Data processed: Payment DataLegal basis: Performance of the agreement (contract)
- Risk Management: To assess, monitor, and manage business risks for smooth operation of our services.Data processed: Identification Data, Payment Data, User Generated and Uploaded ContentLegal basis: Performance of the agreement (contract); Compliance with legal obligations; Legitimate interests
- Customer Communication: To provide support, respond to inquiries, and engage with you regarding your account.Data processed: User Account Data, User Support DataLegal basis: Performance of the agreement (contract)
- Marketing: To send marketing communications and personalized content based on your preferences, subject to consent.Data processed: User Account Data, Identification Data, Technical Data, Marketing DataLegal basis: Your consent; Legitimate interests
- Fraud Prevention: To detect, prevent, and respond to fraudulent or unlawful activity.Data processed: Identification Data, Technical Data, Payment DataLegal basis: Compliance with legal obligations; Legitimate interests
- Security: To protect our systems and data against unauthorized access, maintaining integrity and confidentiality.Data processed: User Account Data, Technical Data, User Support DataLegal basis: Performance of the agreement (contract); Compliance with legal obligations; Legitimate interests
- Technical Support: To diagnose and resolve technical issues, ensuring reliable service functionality.Data processed: User Account Data, Technical Data, User Support DataLegal basis: Performance of the agreement (contract)
- Service Improvement: To analyze feedback, usage patterns, and user behavior to refine and enhance our services.Data processed: User Account Data, User Support DataLegal basis: Performance of the agreement (contract); Legitimate interests
- Dispute Resolution: To manage and resolve legal claims or disputes, protecting our legal interests.Data processed: User Account Data, Contact Information, Identification Data, Transaction Data, Payment Data, User Generated and Uploaded Content, User Support DataLegal basis: Performance of the agreement (contract); Legitimate interests
(6) RECIPIENTS OF PERSONAL DATA
We may share your personal data with trusted partners for the provision of our services, such as payment processors. Additionally, we may disclose your data to government authorities or regulators if required by law.
(7) DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact Information, Identification Data, Payment Data and Transaction Data) for a minimum of 6 years after they cease being customers for tax purposes.
Moreover, we keep data to ensure compliance with legal obligations, such as anti-money laundering (AML) regulations, for a period typically up to 5 years. Additionally, to protect our interests, we may retain data for the duration of the limitation period for claims against the Company, which is usually up to 10 years.
Once your personal data no longer serves any lawful purpose, we ensure it is securely deleted or anonymized to protect your privacy.
If you have consented to our use of your personal data, we will retain this until you withdraw consent.
(8) INTERNATIONAL DATA TRANSFERS
Your personal data may be transferred and processed outside the UK and/or European Economic Area (EEA) to our trusted services providers, including payment processors, cloud hosting providers, and compliance verification systems that carry out certain functions on our behalf and may operate or store data outside the United Kingdom and the European Economic Area (EEA).
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers, or we may use third party providers who are subject to the UK Extension to the EU-U.S. Data Privacy Framework (where applicable).
All third parties that receive personal data are carefully selected and bound by contract to process information only for the purposes described in this Privacy Policy. They are also bound by contract to maintain strict confidentiality and to apply suitably technical and organizational measures to safeguard your data.
(9) ESSENTIAL AND OPTIONAL PERSONAL DATA
Certain personal data is required for the functionality and availability of our services. Failure to provide mandatory (essential) information may limit your access to some features. Optional information can be provided in line with your preferences, as well as managed via account settings. Whenever provision of data is mandatory, special marking will be added to make sure you are informed accordingly.
(10) DATA SECURITY
Ensuring the safety of your data is our top priority. We implement multiple measures to protect your personal information, including:
- Encryption: Advanced encryption methods are used to secure your data during transmission and storage, preventing unauthorized access.
- Access Controls: Strict access restrictions are enforced, including role-based permissions and multi-factor authentication, allowing only authorized personnel to access your data.
- Regular Training: Our team undergoes ongoing training on data protection and privacy best practices to ensure they understand their responsibilities.
- Security Audits: We perform regular security audits and assessments to identify and address vulnerabilities in our systems and processes.
- Data Minimization: We only collect the information necessary for our purposes and retain it only as long as needed.
- Incident Response: A comprehensive incident response plan is in place to quickly address and mitigate any data breaches or security incidents.
You can further enhance the security of your personal information by following these best practices:
- Use Strong Passwords: Create unique, complex passwords for your accounts and update them regularly.
- Enable Two-Factor Authentication (2FA): Add an extra layer of protection wherever possible.
- Keep Software Updated: Regularly update devices and applications to protect against vulnerabilities.
- Install Security Software: Use reputable antivirus and anti-malware programs to safeguard your devices.
- Use Secure Networks: Avoid public Wi-Fi for sensitive transactions; consider a VPN if necessary.
- Monitor Your Accounts: Regularly check online and financial accounts for unusual activity and report discrepancies immediately.
- Be Vigilant: Stay alert to phishing attempts and avoid sharing passwords or personal information with untrusted sources.
- Backup Your Data: Regularly back up important data to secure, separate locations.
- Be Cautious with Sharing Information: Limit personal information shared online, especially on social media and public platforms.
- Educate Yourself: Stay informed about the latest security threats and best practices for protecting your data.
By following these guidelines, you can significantly enhance the security of your personal information and reduce the risk of data breaches.
(11) DATA SUBJECT RIGHTS
You have the following rights regarding your personal data:
- Access: Request access to your personal data and obtain a copy of it.
- Rectification: Correct any inaccurate or incomplete information.
- Erasure: Under certain circumstances, request the deletion of your personal data.
- Restriction: Request that we limit the processing of your data in specific situations.
- Objection: Object to certain types of processing, such as direct marketing.
- Portability: Receive your data in a commonly used, machine-readable format and transfer it to another controller.
- Withdrawal of Consent: Revoke any consent you have previously given for data processing at any time.
Important notes:
- These rights are not absolute and may be subject to legal conditions.
- For your privacy and security, we may need to verify your identity before fulfilling a request.
- To exercise any of these rights, please contact us using the contact information provided in this Policy.
(12) AUTOMATED DECISIONS AND PROFILING
We do not engage in automated decision-making processes that have legal effects or significantly impact you. This means that any decisions regarding your personal data that could affect your legal rights or significantly influence your experience with us are always made by a human. However, we may use profiling techniques to enhance and personalize your experience. Profiling involves analyzing certain aspects of your personal data, such as your preferences, interests, and behavior, to offer you more relevant content and services. For example, this may include suggesting products or services that match your interests or customizing our communications to better suit your needs. We ensure that any profiling conducted is transparent, fair, and respects your privacy rights.
(13) USE OF COOKIES AND ANALYTICS TOOLS
Our website uses cookies and analytics tools to ensure smooth operation, enhance your user experience, and understand how visitors interact with the platform. These tools help us remember your preferences, monitor performance, and identify potential issues to improve the website’s functionality, security, and overall usability.
Where required by law, we request your consent for non-essential cookies, such as analytics or marketing tools, through a cookie consent banner displayed on your first visit. You can manage or withdraw your consent at any time via the platform settings.
You can also manage or disable cookies directly through your browser settings. Please note that certain features of the platform may not function properly if cookies are disabled. For more information about the types of cookies we use and how we process your data, please read our Cookie Policy.
(14) DATA OF MINORS
Our Services and Website are not intended for use by individuals under the age of 18 (the “Minor”). We do not knowingly collect, process, or store personal data from minors. In the event that we become aware of the inadvertent collection of personal data from a minor, we will take prompt and appropriate measures to delete such data from our records. If you are a parent or guardian and have reason to believe that your child under the age of 18 has provided us with personal data, we urge you to contact us immediately so that we can address the issue and ensure the removal of any such data from our systems.
By using our services and website, you represent and warrant that you are not a Minor as of the date of first access to our services and website.
(15) COMPLAINTS
If you have any complaints or concerns regarding how we handle your personal data, please do not hesitate to reach out to us. We value your feedback and are committed to addressing and resolving any issues promptly and to your satisfaction. Our team is dedicated to ensuring that your privacy rights are respected and that any concerns you have are thoroughly investigated and appropriately resolved.
However, if you feel that we have not adequately addressed your concerns, or if you prefer to report your complaint directly, you also have the right to file a complaint with your local data protection authority. In England, this is the Information Commissioner's Office (ICO).
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
(16) UPDATES TO THIS POLICY
We may update this Policy periodically to reflect changes in our practices, legal requirements, or for regulatory reasons. We encourage you to revisit this Policy regularly to stay informed about how we are protecting your information. When we make significant changes to this Policy, we will communicate these changes in a clear and timely manner. This may include notifications on our website, direct emails, or other appropriate means of communication. By continuing to use our services after these changes have been posted, you agree to the updated terms of this Policy.
(17) CONTACT INFORMATION
For questions about the protection of personal data in our Company, as well as for the consideration of your complaint/submission, please contact us via [email protected].
Last updated: 10 April 2026
