Privacy Policy
Introduction
The Glued Team Ltd, trading as Glued, is a company registered in England and Wales (company number 15987850) with a registered address of [Highbury Cottage North Lane, South Harting, Petersfield, England, GU31 5PY] ('we', 'our', 'us' in this privacy statement).
Glued is responsible for collecting, processing, storing and safe-keeping personal and other information as part of providing our fractional EA matching service and carrying out our regular business activities.
Any questions regarding our processing of personal data should be directed to us via annalli@glued.ltd
Data processing principles
We take protecting online privacy and data security seriously. Please read the whole of this statement carefully as it sets out our approach to processing personal data including what information we may collect from you, how we may use it, store it and protect it, and your rights as a data subject.
Our Privacy Statement outlines our approach to any kind of data processing where we are acting as a data controller or co-controller (including collection, use, transfer, storage and deletion) of personally identifiable information (any information that may be used to identify a physical person, and any other information associated therewith) about natural persons. This statement applies to our processing of data collected through any means, actively as well as passively, from persons located anywhere in the world.
We are guided by the following principles when processing data:
We will only collect data for specific and specified purposes. We will not collect data beyond what is necessary to accomplish those purposes; we will minimise the amount of information we collect from you to what we need to deliver our matching and EA support services. We will collect and use your personal information only if we have sensible business reasons for doing so, such as matching you with an EA or client, or delivering our services. We will not use your data for purposes other than those for which it was collected, accepted as stated within our policy, or with your prior consent. We will seek to verify and/or update your data periodically and we will accept requests from you for amendment of the data held. We will apply high technical standards to make our processing of data secure. Except otherwise stated, we will not store data in identifiable form longer than is necessary to accomplish its purpose or as required by law.
How we collect and use personal data
Most personal information is provided directly and voluntarily by you when you engage with us in order to enquire about, or use, our services. We will collect information from you when:
You enquire about our EA matching service or an EA placement. You sign up to The Glued Edit newsletter or mailing list. You take part in our personality or communication style profiling as part of the matching process. You book a discovery call with us. You work with us as an EA or as a client in a commercial capacity. You contact us for information via our website or social media channels, by phone or email. You post on our social media channels, website or blog.
We collect this information in order to make available to you our matching and EA support services and to communicate with you in relation to those services. We may use the information collected to:
Match EAs and clients based on working style, communication preferences and business needs. Create a profile for you on our client or EA database. Process a booking or placement. Send you The Glued Edit and other communications you have consented to receive. Respond to enquiries you make about our services. Ask you to take part in surveys or feedback requests. Ensure content from our site is presented effectively for you and your device. Notify you about changes to our services. Manage HR, payroll and ongoing support for placed EAs, where applicable.
We will not sell or lend your personal data to third parties, or share your personal data for marketing purposes without your express consent. We will only share your personal data with third party service providers where it is necessary for the delivery of our services, and only where we are confident that such third party service providers have appropriate data protection systems and measures in place that are compliant with UK Data Protection Legislation.
As part of the matching process, relevant personal and personality profiling information about an EA may be shared with a prospective client, and relevant information about a client's working style and requirements may be shared with a prospective EA, solely for the purpose of establishing a suitable match. This information is limited to what is necessary for that purpose.
We will not give consent to third party service providers or platforms to use your information for purposes other than those for which it was collected and which are necessary for the delivery of our services.
We will not give consent for your information to be used by third party service providers for the training and development of AI modelling software, or similar purposes.
What information we collect
In accordance with Data Protection Legislation we only collect and process information which we require to meet the specific purposes stated above. The information we may collect about you could include, but is not limited to:
Contact details. Personal details and identifiers. Bank details and financial information (for EAs and contractors, and for invoicing purposes). Details about your occupation, business and working style. Personality and communication style profiling information used for matching. Details about how you use our website, including technical data such as IP address.
Occasionally we may ask for special category data if necessary for delivery of a particular service, such as health information relevant to a placement. Any such special category data will only be collected with your express consent and will be handled in line with ICO best practice guidelines for special category data. As per our Data Processing Principles we will only ask for information necessary to deliver our services, and we encourage you not to provide us with personal data or special category data which we do not ask for.
How we store your information
We have in place appropriate technical and organisational measures to ensure the security, confidentiality, integrity and availability of personal data we control. Your information is securely stored on [platform, e.g. Notion, Airtable, whichever Glued actually uses], which is not publicly accessible and is password protected. Your information may also be stored on our email marketing platform, Beehiiv. Our third-party providers have their own privacy policies, which you can view on their websites.
We may store or process your data on cloud based platforms or service providers whose servers are based outside of the UK. We will only use such third party service providers where we are confident that appropriate safeguards are in place to ensure any personal data is subject to an equivalent level of security and protection as required under UK Data Protection Legislation.
We have appropriate procedures in place to handle any potential Personal Data Breaches, in accordance with Data Protection Legislation. Any such breaches will be reported to the relevant supervisory authority and notified to affected data subjects where we are legally required to do so.
We will only keep your personal data for as long as necessary to meet the requirements for which it was collected. This will vary depending on the nature of the processing, but apart from exceptional circumstances where longer retention is necessary, we will only retain your personal data for 6 years in line with our insurance and contractual obligations. After this period we will delete your personal data unless there is a legitimate business reason to retain all or parts of the data we hold.
Legal basis for processing your data
UK GDPR provides that processing of your data shall only be lawful if and to the extent that at least one of the following applies: you have consented; it is necessary for the performance of a contract; it is necessary for compliance with a legal obligation; it is necessary to protect vital interests; it is necessary for a task in the public interest; or it is necessary for legitimate interests pursued by us or a third party.
We collect data for the purposes set out above. All personal data is managed to ensure it is either erased from our system when no longer required for the purpose for which it was collected, retained for legal reasons, or minimised and retained.
Any special category data collected from you has special protection and is limited to that permissible by law. In all instances where special category data is collected we will obtain your express consent.
Links from our website
Our site contains links to and from other websites which are operated by individuals and companies over which we have no direct control. If you follow a link to any of these websites, please note they have their own privacy and terms of use policies. We do not accept any responsibility or liability for these policies. We advise you to check the policies for third party sites before you submit any personal data.
Marketing emails
We may send you marketing emails and communications when you have opted in or otherwise given consent for us to do so. We will make it as easy as possible for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the primary service you have requested.
If you wish to unsubscribe from any marketing emails, you can do so by emailing annalli@glued.ltd or clicking the unsubscribe link on the email. It may take 24 hours for this to become effective.
Website analytics
We use website analytics to provide the best user experience and to evaluate and improve our site. We use third party data analytics providers such as Google Analytics to monitor website browsing behaviour and navigation.
These third-party providers collect this information using cookies on our behalf, in accordance with our instructions and their own privacy policies. Data collected may include: number of visitors to our site; pages visited and time spent per page; page interaction information such as scrolling and clicks; source location and where users go when they leave the site; page response times and any download errors; technical information relating to end user devices, such as IP address or browser plug-in.
Your right to make a complaint
If you have any questions or concerns regarding our data protection or privacy policies, please contact us at annalli@glued.ltd.
If you would like to make a complaint because you believe we have infringed data protection legislation in the way we have handled your personal information, you have a legal right to complain to us directly. Please email annalli@glued.ltd using the subject line "Data Complaint".
It may be necessary for us to obtain additional information from you, so please ensure you provide and maintain up-to-date contact information.
We will acknowledge your complaint within 30 days of receipt and aim to provide a full response without undue delay. Throughout the course of our investigation we will update you periodically on progress. Once concluded, we will provide you with the outcome. If you are unhappy with the outcome, you can ask us to provide more information or clarification.
You have the right to complain directly to the Information Commissioner's Office (ICO) at any point. There is no requirement to wait for our review before doing so.
Changes to our policy
This Privacy Notice was last updated in [month, year] and is reviewed every 6 months, or upon changes to relevant Data Protection Legislation, whichever is sooner.
We do not intend to process your personal information except for the reasons stated within this Privacy Notice. We reserve the right to update this Privacy Notice from time to time. Where appropriate, we will contact you to notify you of any material changes. You should also refer to our website periodically to access our updated Privacy Notice.
Should you still have concerns about how we manage your personal data, you can complain directly to us as outlined above, or contact the Information Commissioner's Office, the relevant supervisory authority in the UK.