Privacy Policy

This policy explains what personal data Gleni Newsletter ("we", "us", "our") collects through this website and platform (the "Service"), why we collect it, how we use it, and the rights you have over it. It's written to meet the requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Who We Are

Gleni Newsletter is the data controller for account data collected through this site — that's the information we collect directly from you when you register and use the Service. Where a Team uses the Service to send newsletters to its own subscribers, the Team is the data controller for its subscribers' data and we act as a data processor on the Team's behalf. If you have any questions about this policy, or want to use any of the rights below, please get in touch with us.

What Personal Data We Collect

We only collect personal data that you or your Team choose to give us, or that's automatically generated by using the Service:

• Account data: your name, email address, and a securely hashed password, when you register for an account.
• Team and subscriber data: subscriber lists (names, email addresses, and stated preferences), newsletter content, and branding assets that a Team uploads or enters. This belongs to the Team and is only used to operate the Service on that Team's behalf.
• Technical data: standard information such as your IP address, browser type, and pages visited, collected automatically as part of running the site securely — for example, to prevent abuse and diagnose faults.
• Email engagement data: opens and clicks on newsletters sent through the Service, used to give Teams analytics on their own sends.

We don't use Google Analytics, advertising, or social media tracking scripts on this site, and we don't collect any special category data (such as health or financial information).

Cookies

This site uses a small number of cookies, all of them strictly necessary to run the Service — we don't use advertising or analytics cookies.

Because every cookie we use is strictly necessary to sign in and keep your account secure, they don't require separate consent under UK cookie law. If you create an account, you accept our use of the cookies described above as an unavoidable part of providing the Service to you.

Why We Use Your Data, and Our Lawful Basis

• Providing your account and the Service: we use your account data to authenticate you and operate the Service. This is necessary to perform our contract with you.
• Sending newsletters on a Team's behalf: we process subscriber data as a processor, under contract with the Team, who determines their own lawful basis (typically consent or legitimate interest) for holding their subscribers.
• Keeping the site secure and working properly: technical data and strictly necessary cookies are used for our legitimate interest in running, securing, and troubleshooting the Service.

Who We Share Your Data With

We don't sell or share your personal data with third parties for their own marketing purposes. Your data may be processed by:

• Amazon Web Services (AWS SES): used to deliver newsletters. Each Team may configure its own AWS SES credentials, in which case recipient data is processed through that Team's own AWS account.
• Our hosting and infrastructure providers: who store the Service's data on our behalf, only on our instructions.
• Legal authorities: if required to do so by law or in response to valid requests by public authorities.

How Long We Keep Your Data

We keep account data for as long as your account is active, and for a reasonable period afterwards in case of follow-up queries — typically no longer than 24 months after closure, unless we're legally required to keep it for longer or you ask us to delete it sooner. Subscriber data is kept until a subscriber unsubscribes or the Team deletes it. Server and technical logs are kept for up to 12 months.

Your Rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Erase your data (the right to be forgotten), where there's no good reason for us to keep it.
• Restrict how we use your data.
• Object to us processing your data.
• Request a copy of your data in a portable format (data portability).
• Withdraw consent at any time, where we're relying on consent to use your data.

Subscribers to a Team's newsletter can unsubscribe at any time using the link included in every email, without needing to contact us directly. To use any of the rights above, please get in touch with us. We'll respond within one month.