Data Processing Compliance Statement

PECR and UK GDPR compliance framework for B2B data processing and supply by LOXA CAPITAL LTD, trading as GLOWBAR LDN.

Contact Compliance Team

Introduction

This compliance statement sets out the lawful basis upon which LOXA CAPITAL LTD, trading as GLOWBAR LDN, processes and supplies B2B data in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR) and the UK General Data Protection Regulation (UK GDPR).

Registered Address

Office 7 (Ground Floor), Siddeley House, 50 Canbury Park Road, Kingston upon Thames, KT2 6LX, United Kingdom.

GLOWBAR LDN is committed to data protection, transparency, and accountability. This statement outlines our compliance practices and includes safeguarding clauses to ensure legal resilience under evolving data privacy requirements.

PECR Compliance and Direct Marketing Practices

2.1

Telephone and Direct Marketing

Under PECR, direct marketing to private individuals (including sole traders and certain partnerships) via electronic communications requires prior explicit consent. We do not process or market to such individuals without valid opt-in consent.

2.2

B2B Marketing Exemptions

PECR permits marketing communications to corporate entities, including limited companies and LLPs, using business contact details (e.g. [email protected]), provided such communications are relevant and not intrusive.

It is lawful to contact employees of corporate entities at their business addresses, provided:

  • There is a clear opt-out mechanism;
  • Communications are limited to professional matters;
  • There has been no objection to previous communications.

Where consent is legally required, GLOWBAR LDN ensures such consent is properly obtained and recorded.

UK GDPR Compliance and Lawful Processing

3.1

Principles of Lawful Processing

All personal data is processed lawfully, fairly, and transparently, with a valid legal basis established under Article 6 of the UK GDPR. These bases include:

Consent (Article 6(1)(a))
Legitimate interests (Article 6(1)(f))
3.2

Our Reliance on Legitimate Interest

We rely on "legitimate interest" as the lawful basis for processing personal data contained within B2B datasets. This includes names, business telephone numbers, and corporate email addresses of individuals acting in a professional capacity.

This basis is justified because:

  • The data subjects are representatives of incorporated organisations.
  • The data is used strictly for professional B2B marketing.
  • The use of business contact details has minimal privacy impact.
  • The recipients reasonably expect such communications.

A Legitimate Interests Assessment (LIA) is maintained to balance our interests with the rights of data subjects.

3.3

Transparency and Individual Rights

We comply with the UK GDPR principles of transparency, purpose limitation, and data minimisation. Every marketing message contains:

The identity and contact details of GLOWBAR LDN
A clear and functional unsubscribe mechanism
An explanation of why the recipient is being contacted

Unsubscribe requests are honoured promptly, and the associated data suppressed in all future activity.

Nature, Source and Use of Data

4.1

Lawful Composition of B2B Lists

Our data lists are curated from publicly accessible sources, business directories, regulatory filings, or licensed databases. We do not include contacts who have opted out or who are identifiable as private individuals without proper consent.

4.2

Screening and Due Diligence

We regularly audit our databases to exclude sole traders and partnerships unless appropriate consent has been secured. Data integrity and source transparency are essential to our operations.

4.3

Buyer Responsibility

All purchasers of our data are bound by our terms of use, which include:

Prohibitions on use for unlawful or consumer targeting

Responsibility to comply with applicable data protection laws

Requirement to honour opt-outs and unsubscribe requests

Data Subject Rights

5.1

Right to Object and Withdraw Consent

Any data subject contacted through our platform has the right to object to processing and to withdraw consent at any time. Such objections will result in immediate suppression from all future communications.

5.2

Data Subject Access and Control

We honour all data subject rights under the UK GDPR, including:

Right to access
Right to rectification
Right to erasure
Right to restriction
Right to lodge complaint with ICO

Limitation of Liability and Catch-All Safeguards

6.1

Legal Disclaimer

While GLOWBAR LDN exercises utmost diligence in compiling, screening, and supplying B2B data, we do not guarantee the legal compliance of third parties who purchase or use such data. Buyers are independently responsible for ensuring lawful usage within their respective jurisdictions.

6.2

No Warranties

All data is provided "as is" and "as available," without warranties of any kind, either express or implied. GLOWBAR LDN disclaims all liability for any loss, damage, or regulatory action resulting from improper or unlawful use of the data.

6.3

Evolving Regulatory Frameworks

This document is subject to change in light of evolving legal and regulatory frameworks. We reserve the right to update our policies and disclaimers to ensure continued compliance.

Contact Us

Questions about our compliance practices?

For any questions, data access requests, or concerns regarding our processing activities, please contact:

LOXA CAPITAL LTD t/a GLOWBAR LDN
Office 7 (Ground Floor)
Siddeley House
50 Canbury Park Road
Kingston upon Thames
KT2 6LX
United Kingdom
[email protected]

Our Commitment to Compliance

GLOWBAR LDN is committed to maintaining the highest standards of data protection and regulatory compliance. This statement reflects our ongoing dedication to transparency and accountability in all data processing activities.