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Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to applicable privacy laws in the countries in which we sell goods, including the UK General Data Protection Regulation (UK GDPR) and EU General Data Protection Regulation (EU GDPR).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our |
Globus Group is made up of different legal entities. This privacy policy is issued on behalf of the Globus Group so when we mention Globus or the Globus Group, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Globus Group responsible for processing your data. Globus (Shetland) Limited is the controller and responsible for this website. Details of the Globus Group companies processing your data will be made available if you contact us using the details in the ‘How to contact us’ section. |
Personal data |
Any information relating to an identified or identifiable individual |
Special category personal data |
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
Data subject |
The individual who the personal data relates to |
Personal data we collect about you
The personal data we collect about you depends on the particular products we provide to you. We will collect and use the following personal data about you:
- your name and contact information, including work email address and telephone number and details of the company you represent
- information to check and verify your identity, e.g. your date of birth
- your gender, if you choose to give this to us
- your billing information, transaction and payment card information
- your personal or professional interests
- your professional online presence, eg LinkedIn profile
- your work contact history, and purchase history
- information from accounts you link to us, eg Facebook or LinkedIn
- information to enable us to undertake credit or other financial checks on you or the company you represent
- Information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products to you or the company you represent.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or HM Land Registry;
- directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- customer due diligence providers, including marketing agencies who verify that publicly available information is up to date;
- from a third party with your consent, e.g. from your employer or company you represent as a director;
- from cookies on our website—for more information on our use of cookies, please see our cookie policy.
- via our IT systems, eg:
- from door entry systems and reception or warehouse logs;
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your personal data for |
Our reasons |
Providing products or services to you or someone you are representing e.g. your employer |
For our legitimate interest and those of our customers or suppliers i.e. to operate our business |
Preventing and detecting fraud against the business you represent or us |
For our legitimate interest, i.e. to minimise fraud that could be damaging us, our customers or our suppliers |
Conducting checks to identify our customers or suppliers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. under health and safety law |
Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, i.e. to protect our business, interests and rights |
To enforce legal rights or defend or undertake legal proceedings |
Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e. to protect our business, interests and rights |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, eg policies covering ethical trading, security and internet use |
For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to our customers |
Operational reasons, such as improving efficiency, training and quality control |
For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to customers at the best price |
Ensuring the confidentiality of commercially sensitive information |
Depending on the circumstances: —for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information; —to comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures |
For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to our customers at the best price |
Preventing unauthorised access and modifications to systems |
Depending on the circumstances: —for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging to our customers, suppliers and/or us; —to comply with our legal and regulatory obligations |
Protecting the security of systems and data used to provide the goods and services |
Depending on the circumstances: -to comply with our legal and regulatory obligations; -for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging to us, our customers and/or our suppliers |
Updating and enhancing customer records |
—for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
Ensuring safe working practices, staff administration and assessments |
Depending on the circumstances: —to comply with our legal and regulatory obligations; —for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to our customers |
Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. |
For our legitimate interests, i.e. to promote our business to existing and former customers |
Credit reference checks via external credit reference agencies |
For our legitimate interests, i.e. to ensure our customers are likely to be able to pay for our products and services |
External audits and quality checks, and the audit of our accounts |
Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards, and/or to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to our customers; —to comply with our legal and regulatory obligations |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases, information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets |
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. Globus Group uses data concerning health, in particular, optician prescriptions, and facial measurements where Globus Group makes and supplies prescription protective eyewear for an individual to the individual’s employer.
Where we process special category personal data, we will only do so on behalf of your employer in the course of them providing you with personal protective equipment. Globus Group does not process this type of data as a data controller.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, telephone or post) about our products or services, including exclusive offers, promotions or new products or services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at marketing@globus.co.uk; or
- using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products or services in the future, or if there are changes in the law, regulation, or structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the Globus Group for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- companies within the Globus Group;
- third parties we use to help deliver our products to you e.g. warehouses and delivery companies;
- other third parties we use to help us run our business, e.g. marketing agencies and IT infrastructure providers, or website hosts;
- third parties approved by you, e.g. social media sites you choose to link your account to;
- credit reference agencies;
- our insurers and brokers;
- our banks.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
- our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
We will not share your personal data with any other third party.
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third-party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
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 with 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, identity information, and financial and transaction data for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Transferring your personal data out of the UK and EEA
The EEA, the UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We may transfer your personal data to:
- our service providers that are located outside the UK and EEA in which our Globus Group Companies operate, including where we source goods;
- as we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to the UK GDPR. If we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to the EU GDPR. If we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Your rights
You have the following rights, which you can exercise free of charge:
Access |
The right to be provided with a copy of your personal data |
Rectification |
The right to require us to correct any mistakes in your personal data |
Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data—in certain situations |
Restriction of processing |
The right to require us to restrict the processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
To object |
The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
Not to be subject to automated individual decision making |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
The right to withdraw consents |
If you have provided us with consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us at marketing@globus.co.uk Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, address and our customer or supplier’s name and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK. and
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-comp... or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Changes to this privacy policy
This privacy notice was published in July 2023 and last updated in February 2022.
We may change this privacy notice from time to time—when we do we will inform you via our website.
How to contact us
Individuals in the UK
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details |
Marketing, Globus Group, T2 Twining Road, Manchester, M17 1SH marketing@globus.co.uk +44 (0)161 877 4747 |
Individuals in the EEA
We have appointed our group company, ENHA GMBH to be our data protection representative within the EEA. Their contact details are
Customer Service Department ENHA Kunststoffverarbeitungs-GmbH, Kasteler Straße 11, 66620 Nonnweiler, Germany +49 (0)6873 91067 |
Individuals within the EEA can contact us direct (see above) or contact our European representative.