Privacy notice

1 - Introduction and defined terms

We at Glow Financial Services Limited (the ”Company”, ”Glow”, ”we”, ”us” or ”our”) are committed to protecting the privacy and security of your personal information and ensure that all personal data handled by us is done so in accordance with the applicable data protection laws and regulations and guidance laid out by the Information Commissioner’s Office (”ICO”).

This Privacy Notice (”Notice”) explains how we collect, use, and disclose personal information about you when you apply for financing for products, services and/or subscriptions from EE Limited (”EE”). Glow operates as EE Finance under brand licence from EE Limited.

This Notice explains how we obtain, process and share personal data about customers and relates to the finance of EE products, services and/or subscriptions.

For the purpose of applicable data protection law, including the Data Protection Act 2018 and UK GDPR (together, ”DP Law”), Glow is the Data Controller of your personal information that we collect, hold, and process.

This Notice was last updated February 2024. For a summary of all updates to this Notice, please refer to Section 12 ‘Changes to this Notice’.

2 - About us

Glow is a company registered in England with Company No. 09127663.

Our contact details are:

Company name: Glow Financial Services Limited
Registered Address: 71 Queen Victoria Street London EC4 4AY
Phone Number: +44 (0)207 126 8167
E-mail: dataprotection@glowgfs.com

We are authorised and regulated by the Financial Conduct Authority (Reference Number: 751308). Find out more about us on https://www.glowfinsvs.com/.

3 - What personal information do we collect about you?

By personal information, we mean all personal information about you that we collect, use, share and store. This may include any of the following:

Contact information
  • Your name, surname, and title
  • Your date of birth
  • Your contact details such as your email address, telephone number(s), and home address
  • Your residential status and address details for the last three (3) years
  • Your delivery address.
Financial information
  • Your occupation and annual income
  • Your employment status
  • Your employer’s details
  • Your bank details, including: your bank name and address, sort code and account number.
Information relating to your identity
  • A copy of your photo identification documents (such as a valid passport or current driving licence)
  • Selfie – as defined by the ICO, this is biometric data used for identity verification purposes and is therefore processed according to special category information requirements. Read more about this on the ICO website.
Information relating to your access and use of our services (including your IP address, your location, and the device being used)
Information relating to your access and use of our services, including but not limited to:
  • Your IP address
  • Your location
  • Device type
  • Software used.
Loan Information
  • Information about your loan (including your payment history)
  • Information which allows us to create your user account and your unique agreement number
  • Your password
  • Information about the products or services being purchased.

Section 4 of this Notice goes into details on what information we collect, what and how we collect, who we share it with, where it is stored, why we collect it and how long it is stored for (Retention Period) during various stages of our data handling processes. The data type headings in Section 3 outlines the nature of the information included when using such terms.

4 - How we process your information and why
4.1 - Processing your information for the loan application
4.2 - Processing for fraud prevention
4.3 - Processing for validating your identity
4.4 - Processing for verifying your credit score
4.5 - Supporting and servicing your loan
4.6 - Information that could help improve your experience
4.7 - Information to process a complaint
4.8 - Information required to improve our products and services
5 - How we market Glow and EE’s products and services

We do not send you any marketing or promotional material without obtaining your prior consent (which may be provided by you to EE, its authorised resellers or franchisees). There may be exceptions where we can inform you about other products or services where we are allowed to do so under DP Law.

6 - How we use automated decision-making

As part of our processing of your personal information, we may take decisions by automated means. You may be automatically considered to pose a fraud risk if our processing suggests fraudulent activity which may mean you are found to not be eligible for a loan or financing for EE ’s products, services and/or subscription, resulting in your application being rejected.

The logic involves data matching which compares sets of data, such as your phone number against other records held by the same or another body to see if they match. The data is usually personal information. The data matching allows potentially fraudulent applications to be identified and for your application to be potentially declined. It also allows us to identify non-fraudulent activity. You have rights in relation to automated decision making (refer to section 10: ‘Your legal rights in relation to your information’).

7 - Where we process your information

Glow processes all your information in the United Kingdom (UK) but may need to transfer your information outside the UK to service providers, agents, or subcontractors, and to carry out the fraud prevention services and for the provision of the EE Finance services.

In some cases, data protection laws outside of the UK may not provide the same level of protection as those in the UK, such as in the US. Where we share your personal information with service providers, agents or subcontractors located in a country that has not been approved by the authorities as having a suitably high standard of data protection law, we will use specific contracts (known as Standard Contractual Clauses) approved for use in the UK, and if necessary additional supplementary measures, which give personal data the same protection it has in the UK.

Financial information, contact information, information relating to your identity and information relating to your access and use of our services (including your IP address, your location, and the device being used) may be processed in Ireland, the Netherlands and Germany.

Please contact our data protection team at dataprotection@glowgfs.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8 - How long we hold your information for

We will retain information for no longer than is necessary (see section titled “Why we need the information and what we use it for”). This means that we may continue to hold some information for a maximum of seven (7) years after your EE Finance loan is repaid. Where the loan does not proceed, and is not related to a fraud event, Glow will hold your personal information submitted during the loan application process for a two (2) year period.

If you would like any further information about how long we hold your information, please contact our data protection team by email at dataprotection@glowgfs.com.

9 - Keeping you up to date

We keep this Notice under regular review. We may change this Notice from time to time by updating it to reflect changes in the law and/or our privacy practices. The date at the top of this Notice will be updated accordingly and we encourage you to check this from time to time for any updates or changes. We may also contact you to let you know that we have updated the Notice. We may also take that opportunity to ask you if you would like to update your marketing preferences.

11 - Contacting us

If you have any questions regarding our Privacy Notice, please email us at dataprotection@glowgfs.com.

12 - Changes to this Notice

Feb 2024:

This is the first version of the EE Finance Privacy Notice.

Glow Financial Services Limited (“Glow”), 71 Queen Victoria Street London EC4V 4BE. Registered in England No. 09127663. Glow is authorised and regulated by the Financial Conduct Authority (Reference No. 751308). The register can be accessed through www.fca.org.uk. Glow acts as EE Finance under brand licence from EE.

© (2024) Glow Financial Services Limited. All rights reserved.