Privacy Policy

1. Introduction

Gloging Pvt Ltd ("Gloging", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you interact with our website, services, and communications.

This policy applies to all individuals who visit our website, enquire about our services, or engage us as clients. It is designed to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and Pakistan's Prevention of Electronic Crimes Act (PECA) 2016.

Gloging Pvt Ltd acts as the data controller for the personal data described in this policy. Please read this policy carefully to understand our practices regarding your personal data.

2. Information We Collect

We may collect and process the following categories of personal data:

a) Personal Data You Provide Directly:

• Full name, job title, and company name.
• Email address, telephone number, and postal address.
• Payment and billing information (processed securely through third-party payment providers).
• Project-related content and materials you provide to us.
• Communications and correspondence between you and Gloging.

b) Usage Data (Collected Automatically):

• IP address, browser type and version, and operating system.
• Pages visited, time spent on pages, and navigation paths.
• Referring website or source, and search terms used.
• Device information including screen resolution and device type.

c) Cookie Data:

We use cookies and similar tracking technologies to enhance your browsing experience. For detailed information, please refer to Section 8 (Cookies Policy) of this document.

3. How We Use Your Information

We use the personal data we collect for the following purposes:

• To provide, manage, and deliver our digital agency services as agreed in project contracts.
• To communicate with you regarding project updates, proposals, invoices, and support.
• To respond to your enquiries, requests, and feedback.
• To process payments and manage our financial records.
• To improve our website, services, and user experience through analytics.
• To send marketing communications where you have provided consent (you may opt out at any time).
• To comply with legal obligations and protect our legitimate business interests.
• To detect, prevent, and address fraud, security issues, or technical problems.

4. Legal Basis for Processing (GDPR Article 6)

Under the UK GDPR, we process your personal data on the following legal bases:

• Contractual Necessity (Article 6(1)(b)): Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract.
• Legitimate Interests (Article 6(1)(f)): Processing is necessary for our legitimate business interests, such as improving our services, marketing, and fraud prevention, provided these interests are not overridden by your rights and freedoms.
• Consent (Article 6(1)(a)): Where you have given clear consent for us to process your personal data for specific purposes, such as receiving marketing communications.
• Legal Obligation (Article 6(1)(c)): Processing is necessary to comply with a legal obligation to which we are subject, such as tax and accounting requirements.

For processing activities under Pakistan's PECA 2016, we ensure that all data handling complies with the provisions relating to the protection of personal information and the prevention of unauthorised access to data.

5. Data Sharing & Third Parties

We do not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of recipients only as necessary:

• Service Providers: Trusted third-party providers who assist us in delivering our services, including hosting providers, payment processors, analytics platforms, and email service providers. These providers are contractually bound to process data only on our instructions and in compliance with applicable data protection laws.
• Professional Advisors: Accountants, lawyers, and auditors who require access to data in the course of providing professional services to Gloging.
• Legal Requirements: Where we are required to disclose data by law, regulation, legal process, or enforceable governmental request.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction. We will notify you of any such change and ensure your data remains protected.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

• Client Project Data: Retained for the duration of the project and for a period of six (6) years thereafter to comply with legal and accounting obligations.
• Marketing Data: Retained until you withdraw your consent or unsubscribe from our communications.
• Website Analytics Data: Retained for up to twenty-six (26) months in anonymised or aggregated form.
• Enquiry Data: Retained for up to two (2) years from the date of your last communication with us.

When data is no longer required, it will be securely deleted or anonymised in accordance with our data retention procedures.

7. Your Rights

Under the UK GDPR and applicable data protection legislation, you have the following rights regarding your personal data:

• Right of Access (Article 15): You have the right to request a copy of the personal data we hold about you.
• Right to Rectification (Article 16): You have the right to request correction of any inaccurate or incomplete personal data.
• Right to Erasure (Article 17): You have the right to request deletion of your personal data where there is no compelling reason for its continued processing ("right to be forgotten").
• Right to Restriction of Processing (Article 18): You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
• Right to Object (Article 21): You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one (1) month of receipt.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the United Kingdom at ico.org.uk.

8. Cookies Policy

Our website uses cookies to distinguish you from other users and to provide a better browsing experience. Cookies are small text files placed on your device by our website.

We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the operation of our website. These include cookies that enable you to navigate the site and use its features.
• Analytical/Performance Cookies: Allow us to recognise and count visitors and understand how visitors navigate our website. This helps us improve the way our website works.
• Functionality Cookies: Used to recognise you when you return to our website, enabling us to personalise content and remember your preferences (e.g., dark/light mode).
• Targeting/Advertising Cookies: Record your visit to our website, the pages you have visited, and the links you have followed. We may use this information to make our website and advertising more relevant to your interests.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

9. Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using SSL/TLS protocols.
• Secure access controls and authentication mechanisms for our systems.
• Regular security assessments and vulnerability testing.
• Staff training on data protection and information security best practices.
• Secure disposal of data that is no longer required.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining the highest practicable standards.

10. International Data Transfers

As Gloging operates in both Pakistan and the United Kingdom, your personal data may be transferred between these jurisdictions. We may also use service providers located in other countries.

Where personal data is transferred outside the United Kingdom, we ensure that appropriate safeguards are in place in accordance with UK GDPR requirements, including:

• Transfers to countries recognised by the UK Secretary of State as providing an adequate level of data protection.
• Use of Standard Contractual Clauses (SCCs) approved by the Information Commissioner's Office.
• Implementation of supplementary measures where necessary to ensure an equivalent level of protection.

For further information about the safeguards we have in place, please contact us at [email protected].

11. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child under 18, we will take immediate steps to delete such data from our records.

If you are a parent or guardian and believe that your child has provided us with personal data, please contact us at [email protected] so that we can take appropriate action.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any changes will be posted on this page with an updated "Last Updated" date.

Where changes are significant, we will make reasonable efforts to notify you directly, such as by email or through a prominent notice on our website.

We encourage you to review this policy periodically to stay informed about how we protect your data.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us: