Glasgow Software

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GDPR - Privacy Statement

PRIVACY STATEMENT
Effective 22 May 2018
Introduction
Glasgow Software holds itself to high standards in handling and processing personal information. The statement outlined below establishes the boundaries of what Glasgow Software processes and what you, as our customer and the data subject ("users"), are entitled to. This Privacy Statement applies when you use our features and services. Your Personal Data
Personal data refers to identifying information that relates to an individual.  Identification can be by the data alone or in conjunction with any other data in the data controller's possession or likely to come into such possession. Glasgow Software collects information only to provide you with services that you opted into. In order to provide you with our products or services, including responding to your enquiries, we may ask for your personal information. If you choose not to provide the requested information, we may be unable to deliver the desired services. Most of Glasgow Software's services are provided under a Glasgow Software Account, and if you no longer require the service or wish to have your data removed, you may delete your Glasgow Software Account.
Examples of data we collect and store include:

  • Your e-mail address, which is used as identification for our services and as the primary communication method.
  • Your name, address, phone number, and additional contact information are used to provide registration, and billing verification services.
  • Your IP address and unique device identifiers are used for fraud prevention, security purposes, for warranty registration, support services, and for transactions.

Other information that you provide to us through digital or physical means may be stored on a case-by-case basis depending on the reason it was provided.
For more specific information on the data collected and ways they are stored, please refer to the Services section.
Non-Personal Data
Glasgow Software may collect additional information that, by itself, cannot be used to identify any specific individual. This information is used to help facilitate our business operations. For example:

  • Device analytics are opt-in and used to understand how our users interact with our products and services. Information collected cannot be used to identify our users nor the data that they store on their devices. Refer to the Services section for more information.
  • We collect single-session information from our users when they browse our website, including help articles, to understand which topics are more important and if the content is relevant to our users or potential customers. Read our Cookie Policy.

Lawful Bases and Other Usage
Glasgow Software only collects and processes personal data for which you give consent when it is necessary for the performance of a contract with you to provide a specific service, or in certain "legitimate interests" cases, that do not outweigh your rights and freedoms.
Situations necessitating such actions may include -  to protect you, us, or others from security threats, to comply with laws we are subjected to, and to perform auditing.
Glasgow Software may share your information with third parties only with your consent or for performance of contract. Glasgow Software does not share your personal information with third parties for the purpose of direct marketing.
Data Controllers, Contracting Parties, Transfer of Data
We use the term "Designated Countries" to refer to countries that are in the European Union (EU), European Economic Area (EEA), and Switzerland.
If you reside in Designated Countries, Glasgow Software Limited will be the controller of your personal data. Glasgow Software would be responsible for collecting, and processing data per our services, which will be covered by the Terms of Service of the relevant service.
Glasgow Software's services include providing technical support, device replacement, payment services, event registration, as well as the transfer of data based on users' decisions, around the world. The nature of these services require us to be able to transfer data into and out of the European Union (EU) to Glasgow Software subsidiaries, affiliates, authorized repair and support centres, authorized logistics companies, communications infrastructure, and other entities deemed necessary to carry out providing these services. Glasgow Software safeguards EU personal data when transferred out by adopting European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers to locations the European Commission have not deemed to have an adequate level of data protection.
Your Rights to your Personal Data
Glasgow Software's services are generally provided on an opt-in basis, with required and collected information differing on a per service basis. Unless subject to an exemption, you will have the following rights with respect to your personal data:

  • The right to delete data: You can ask us to delete data for which we no longer need in order to provide service to you.
  • The right to correct or change data: You can modify your contact information through your Glasgow Software Account. You can also ask us to change, update, or fix data that are incorrectly presented and unable to be changed by yourself.
  • The right to object or restrict use of data: You can ask us to stop or limit the usage of some or all of your personal data that we no longer need, in order to provide service to you, or have legal rights to retain.
  • Right to access: You may request a copy of your personal data that we have at the time.

You may make these requests by submitting an email request to service@glasgowsoftware.com or by writing to us at our registered office of 5 Woodyett Park, Busby, East Renfrewshire G76 8SJ
Upon receipt, we will evaluate your request and inform you how we intend to proceed. Under certain circumstances, and according to applicable European Union or European Union state laws and regulations, we may withhold access to your data, or decline to modify, erase, port, or restrict the processing of your data. Glasgow Software will respond to your request within thirty days after receiving it.
Services
This Privacy Statement applies to Glasgow Software-provided services offered on Glasgow Software.com, Glasgow Software-branded applications, services provided from physical Glasgow Software products ("Glasgow Software Devices"), and digital or physical services directly offered by Glasgow Software unless stated otherwise. A list below details the characteristics of Services provided.
Glasgow Software Account
By creating an account, you can gain access to multiple Glasgow Software services, such as Domain Control, DDNS, Webmail and Technical Support. We collect basic information from you to help facilitate communications and provide services to you.
Glasgow Software does not use this information for any other purpose.
Glasgow Software does not share this information unless otherwise specified for the particular service.
Information about specific functionalities is listed below.
You may delete your Glasgow Software Account at any time. However, we may be unable to provide you certain services afterwards. Account deletions, including all the associated data with the specified account, are irreversible. Glasgow Software may retain certain data in order to fulfil our legal obligations, which differ on a per service basis.
Package Centre
Glasgow Software collects package download information from your Glasgow Software device in order to help us understand how we can better improve our devices and software. The data we collect does not contain information that can identify you, the user. When a Glasgow Software device issues a download request to Package Center, Glasgow Software's database will record the action with a unique ID. This ID is used only to identify download activity in Package Center. None of this information contains any of your personal information or metadata pertaining to your files. Package Center does not track or record your device's serial number, MAC address, or IP addresses for uses that do not require additional licenses.
Licensing
Purchasing package licenses, whether a single purchase, subscription-based, or in-app purchase, requires a Glasgow Software Account. We will collect certain information from your Glasgow Software device for licensing purposes, including product serial number, IP address, MAC address, and registered Glasgow Software Account. We store this information to verify your license when it is applied to a Glasgow Software device.
Activating and updating packages will usually require an Internet connection to our servers. We identify your Glasgow Software device with a unique device ID.
For record keeping and future troubleshooting, we may keep track of information such as whether the update was successful or not. We may use the information collected through activation or updates to validate your license status.
Glasgow Software only shares aggregated statistics that does not contain personal information to our partners, licensors, and licensees.
Third-Party Packages
Glasgow Software Package Center is a platform that enables other developers to publish their applications for use on Glasgow Software devices. Packages distributed or published by third-parties may collect additional information regarding you or your device. Glasgow Software requires third-party developers to be transparent about all practices. However, Glasgow Software does not control or have the capability to completely verify claims, nor is Glasgow Software responsible for any practices performed by third-party packages. When you install third-party packages, you should read and understand the end user license agreements (EULA), privacy statements/policies/notices, and terms of use/service that may be presented to you.
Users should contact the third party directly for any questions or problems you have in using third-party packages.
Third-party packages may include their own subscription or payment services that are not controlled by Glasgow Software.
Glasgow Software only shares aggregated statistics that do not contain personal information to third-party developers.
Payment
Data we collect
To make a purchase, Glasgow Software will collect information you provide, including your name, billing address, phone number, IP address, client user-agent, VAT, and payment method to process the transaction.
Glasgow Software does not directly handle your payment method, such as your credit card number and CVC.
How we use your data
Glasgow Software uses third party processors (SagePay) (Online Banking) to securely handle your payment method and to calculate and report taxes. Glasgow Software only uses information we collect from the payment process to complete transactions, generate receipts, report taxes, and for financial and legal auditing purposes. We do not share or use this information for any other purpose.

How we store your data
Your purchase history, even if refunded or cancelled, will be stored for a minimum of four years per legal requirements imposed on Glasgow Software and its subsidiaries. Glasgow Software will retain this history, including your billing information, for an indefinite period in the following situations; If the order contains a perpetual license, a license renewal, a physical item, extended support, or is needed for financial or legal purposes. Our payment processors and tax reporting providers may additionally be subjected to other legal obligations.
Glasgow Software generates an invoice that is made available on your Glasgow Software Account for each transaction.
By deleting your Glasgow Software Account, you will be forfeiting all purchased licenses. Glasgow Software will remove your transaction history after the minimum storage period based on our legal obligations.
Technical Support
Data we collect
You may request Glasgow Software Technical Support assistance through our website, live chat, or by phone. Submitting a Technical Support form requires a Glasgow Software Account. Glasgow Software collects and stores information that is needed to investigate, respond to, and resolve your technical support request.
When you make a phone request to Glasgow Software's Technical Support hotline, our technical support agent will ask for your consent on phone recording at the beginning of the conversation. Your personal information, including name, email, telephone number, and detail on your Glasgow Software product will be recorded in our systems.
In some cases, you may be requested to provide remote access information. Glasgow Software technical support agents together in some cases with Glasgow Software software engineers may utilize the credentials provided to directly access your device.
When a device replacement or spare part is requested, you will be required to provide a valid shipping address. In certain cases, you may be asked to provide payment for support services, shipping charges, or spare parts.
How we use your data
When you submit a Technical Support form in your Glasgow Software Account, you are required to provide the essential product information that is needed to investigate, respond to, and resolve your technical support request. During the investigation, Glasgow Software may request additional information that is required to resolve the matter. Depending on the complexity and the severity of the request, the support ticket may be escalated to parties within Glasgow Software to investigate, respond to, and resolve your request. The information revealed to involved parties is strictly limited. Glasgow Software restricts access to both the raw and aggregated data by specific employee roles.
Glasgow Software only uses information we obtain from technical support requests to resolve your issue. After removing your personal information, we may use some of the technical details to generate bug reports if the problem was previously unknown to implement a solution for our products.
If shipping is required, your shipping address and contact information may be passed to third-party logistics partners.
How we store your data
Glasgow Software restricts access to both the raw and aggregated data by specific employee roles.
When you upload files for your support ticket, Glasgow Software will retain them for up to 90 days after the ticket has been resolved.
When you provide remote access information, Glasgow Software will retain it until the ticket has been resolved.
Glasgow Software keeps communication records and survey records for a minimum of three years for internal auditing and statistical purposes. If you wish to remove your personal information from our systems, you may choose to delete your Glasgow Software Account. We may choose to retain technical details of the problem, such as steps to reproduce it, the technical details of the environment, and what steps were taken to resolve it.
Glasgow Software will keep all shipping records for internal auditing and inventory control purposes indefinitely.

Security
Glasgow Software employs multiple methods of data protection in order to minimize the risk of misuse, unauthorized access and disclosure, and loss of access. Some of these safeguards include the use of pseudonymization, data encryption, data hashing, and other technologies and permission control methods. When our employees directly handle, or access your personal information, we do so on secured networks and through fine-grained permission control to limit who can access your information. Data you provide to us is encrypted and stored on both third-party storage and on Glasgow Software managed devices, depending on the service.
Glasgow Software logs and stores IP addresses of both users to our web services solely for security purposes. This log is archived and then removed at irregular intervals depending on ongoing or existing security threats or investigations. If Glasgow Software has overwhelming evidence that certain IP addresses, users, or devices may be purposely damaging or hindering our operations or service quality, we may deny further services and/or report such behaviour to the relevant authorities.
Glasgow Software removes data that is no longer required to provide services based on each service.
Changes to Statement
Glasgow Software may make amendments to this document when needed to reflect statement updates, customer feedback, as well as new products or services. We will provide a brief overview of the changes, and if the terms modify the way we process or handle your data or affect your rights, we will notify you through direct message or by posting notices if we are unable to directly reach you. We encourage that you regularly review this Privacy Statement to understand how your data is handled.
Data from Children
Glasgow Software's products and services are targeted at professionals and are not designed nor intended to be used by children under 13 years of age. Glasgow Software does not collect date of birth information as it is not used by Glasgow Software. If children under the minimum age of the relevant jurisdiction must use Glasgow Software's products and services, explicit parental consent must be provided and verified. If Glasgow Software is notified or discovers that data collected is from a child under the minimum age, we will take procedures to delete the information as soon as possible.
Do Not Track
Glasgow Software does not track users to provide targeted advertising and therefore will not respond to Do Not Track (DNT) signals.
Notice to End Users
Certain Glasgow Software products or services may be managed or administered to you by organizations or other users. Your use of these managed Glasgow Software products or services will be affected by the terms or policies that are provided and dictated by the organization or service provider. Please direct inquiries in these instances to the administrator of the device or service. Glasgow Software will not be responsible for the privacy or security practices, including the lawfulness of practices for our customers as they may manage or implement our products and services in a manner that is no longer determined by Glasgow Software's policies or agreements.
Contact Information
You can directly contact us by phone on 07745 874947   You have options to exercise your rights as detailed in the previous Your Rights to your Personal Data section. Glasgow Software will respond to your requests within thirty days after receiving it.
You may also contact Glasgow Software through the following address


Data Controller - David Hunter

Glasgow Software Limited
5 Woodyett Park
Busby
East Renfrewshire G76 8SJ
United Kingdom

 

© Glasgow Software 2018