The Glow XL Group Limited

Data Protection Policy

Data Protection Registration No. Z270857X

Introduction

The Glow XL Group Limited needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the

organisation has a relationship with or may need to contact. This policy describes how this

personal data must be collected, handled and stored to meet the company’s data protection

standards — and to comply with the law.

Why this policy exists

This data protection policy ensures The Glow XL Group:

▪ Complies with data protection law and follow good practice

▪ Protects the rights of staff, customers and partners

▪ Is open about how it stores and processes individuals’ data

▪ Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations — including The Glow XL Group—

must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully

2. Be obtained only for specific, lawful purposes

3. Be adequate, relevant and not excessive

4. Be accurate and kept up to date

5. Not be held for any longer than necessary

6. Processed in accordance with the rights of data subjects

7. Be protected in appropriate ways

8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection


People, risks and responsibilities

Policy scope

This policy applies to:

• The registered office of The Glow XL Group

• The Glow XL Group's administration centre & data centres.

• All employees and contractors of The Glow XL Group

• All contractors, suppliers and other people working on behalf of The Glow XL Group

• All Web sites that The Glow XL Group operates, including www.xltelecom.co.uk and www.phonenumbers.store

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, fill out a form, and in connection with other activities, services, features or resources we make available. It applies to all data that the company collects and holds relating to the personal information of identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. Users may, however, visit our Site anonymously.

Personal data that we may collect includes:

• Names of individuals

• Postal addresses

• Email addresses

• Telephone numbers

• IP addresses

• Banking details (Direct Debate details, etc)

• … plus any other information relating to individuals or companies in relation to the

services provided to them by The Glow XL Group.

We only collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.


What does the Privacy Policy cover?

Our Privacy Policy covers how The Glow XL Group Limited and its Web sites collects and handles your personal information. The policy covers personal information obtained through:

• An enquiry made to obtain information from our website (www.xltelecom.co.uk and www.phonenumbers.store), or by speaking with a Glow XL Group employee;

• Telephone or email contact made to discuss a new service opportunity;

• Telephone or email contact made to discuss an existing service;

• Registering (via a consent form) for more information, having made initial contact at a conference / seminar or exhibition;

• The normal operation of our call management functionality, supported by an

Agreement.

How long do we store your personal information?

We only retain your personal information for the duration necessary to operate the service or the service contract period, or until receipt of a formal request to destroy any or all information or for 12-months whichever is the longest.

We do not store, process or transmit for storage or processing any personal information outside of the UK.

Some data that might be considered personal is retained as required by Regulation, Emergency and Security Services, such as service user’s details, caller and dialled number call details.

How we use collected information

The Glow XL Group through its Web site www.xltelecom.co.uk may collect and use Users personal information for the following purposes:

- To improve customer service

Information you provide helps us respond to your customer service requests and support needs more efficiently.

- To improve our Site

We may use feedback you provide to improve our products and services.

- To send periodic emails

We may use the email address to respond to their inquiries, questions, and/or other requests.

Accurate invoicing

We may use the email address, telephone number, or postal address to communicate if there issues with an invoice.


Investigate disputes

If there is a service or billing dispute, we may use your email address, telephone number, or postal address to contact you.

Your rights

• You may ask us not to process your information for marketing purposes

• You are entitled to a copy of the information we hold about you, and to ask us to correct any inaccuracies.

• You may ask us to stop using your information, and to delete it, although we may maintain a skeleton set of your information for regulation and legal purposes. If you ask us to do this, we will not be able to continue our contract with you.

• We will respond to your request within 30 days.

• You may make a complaint to the Information Commissioner (www.ico.org.uk).

Data protection risks

This policy helps to protect The Glow XL Group from some very real data security risks, including:

Breaches of confidentiality. For instance, information being given out inappropriately.

Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with The Glow XL Group has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The Company Directors are ultimately responsible for ensuring that The Glow XL Group meets its legal obligations.


• The Data Protection Officer, Nick Mutton, is responsible for:

▪ Keeping the directors updated about data protection responsibilities, risks and issues.

▪ Reviewing all data protection procedures and related policies, in line with an agreed schedule.

▪ Arranging data protection training and advice for the people covered by this policy.

▪ Handling data protection questions from staff and anyone else covered by this policy.

▪ Dealing with requests from individuals to see the data The Glow XL Group holds

about them (also called ‘subject access requests’).

▪ Checking and approving any contracts or agreements with third parties that may

handle the company’s sensitive data.

• The Business Manager, Ken Lowe, is responsible for:

▪ Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

▪ Performing regular checks and scans to ensure security hardware and software is functioning properly.

▪ Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

• The management team is responsible for:

▪ Approving any data protection statements attached to communications such as emails and letters.

▪ Addressing any data protection queries from journalists or media outlets like

newspapers.

▪ Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

▪ All the team will need to have constant and continuous access to data in order for them to fulfil their duties. The team must be aware that some data is sensitive and personal, and should therefore be treated as confidential.

▪ Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.

The Glow XL Group will provide training to all employees to help them understand their responsibilities when handling data.

▪ Employees should keep all data secure, by taking sensible precautions and following the guidelines below.


▪ In particular, strong passwords must be used and they should never be shared.

▪ Personal data should not be disclosed to unauthorised people, either within the company or externally.

▪ Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

▪ Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Technical Team.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

▪ When not required, the paper or files should be kept in a locked drawer or filing cabinet.

▪ Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.

Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

▪ Data should be protected by strong passwords that are changed regularly.

▪ If data is stored on removable media (like a USB memory stick or data card), these should be kept locked away securely when not being used.

▪ Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.

▪ Servers containing personal data should be sited in a secure location, away from general office space.

▪ Data should be backed up frequently. Those backups should be tested regularly, in

line with the company’s standard backup procedures.


▪ Unless essential as a temporary measure, data should never be saved directly to

laptops or other mobile devices like tablets or smart phones.

▪ All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to The Glow XL Group unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

• Personal data should not be shared informally.

• Data must be encrypted before being transferred electronically. The Tech Team can explain how to send data to authorised external contacts.

• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires The Glow XL Group to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort The Glow

XL Group should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.

• Staff should take every opportunity to ensure data is updated. For instance, by

confirming a customer’s details when they call.

• The Glow XL Group will make it easy for data subjects to update the information The

Glow XL Group holds about them, for instance, via our Customer Services team.

• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.


• It is the Technical Team’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by The Glow XL Group are entitled to:

• Ask what information the company holds about them and why.

• Ask how to gain access to it.

• Be informed how to keep it up to date.

• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the Data Protection Officer. The DPO can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 (inc VAT) per subject access request. The DPO will aim to provide the relevant data within 14 days.

The DPO will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

We will only share your information when formally requested to do so by:

• Regulatory agencies – e.g. OFCOM;

• Emergency Services – e.g. Police, Fire & Rescue, Ambulance and Trading Standards, related to the detection of crime, the apprehension or prosecution of offenders or related to emergency situations either historical or active;

• Other Government Authorities

• Agencies tasked with safeguarding national security.

We do not share your information with any commercial organisations.


Under these circumstances, The Glow XL Group will disclose requested data. However, the

data controller will ensure the request is legitimate, seeking assistance from the Directors

and from the company’s legal advisers where necessary.