Privacy Policy — iGlowly Managed Website Service

    Last updated: 25/09/2026

    1. Purpose

    This policy explains how iGlowly processes personal data in connection with the ordering, creation, hosting and management of a website for a clinic or another professional Client.

    It concerns the relationship between iGlowly and its Clients. The clinic must have its own privacy policy for visitors and patients using its website.

    2. Data Controller

    For the commercial and administrative management of the service, the data controller is:

    iGlowly LLC
    1207 Delaware Ave #3674
    Wilmington, DE 19806
    United States
    Wyoming entity ID: 2026-002091569

    3. Client Data We Process

    As part of its relationship with the Client, iGlowly may process:

    • the name and contact details of the Client and its team members;
    • the clinic’s name and professional information;
    • the billing address and VAT number;
    • information relating to the order and subscription;
    • communications, support requests and website update requests;
    • content, documents and files provided to create the website;
    • information about practitioners intended for publication;
    • technical access details required to migrate or configure the website;
    • technical and security data required to operate the service.

    iGlowly does not ask the Client to provide patient records or personal data relating to its patients.

    4. Purposes and Legal Bases

    This data is used to:

    • process orders and payments;
    • prepare, publish, host and maintain the website;
    • migrate content and connect the domain;
    • respond to support and website update requests;
    • manage the contractual relationship;
    • maintain security and prevent misuse;
    • comply with accounting, tax and legal obligations.

    The principal legal bases for processing are:

    • performance of the contract;
    • compliance with legal obligations;
    • iGlowly’s legitimate interests in securing, administering and improving the service.

    5. Data Relating to Visitors to the Clinic’s Website

    The clinic determines the purposes and means of processing the data collected from visitors to its website. It therefore generally acts as the data controller.

    Depending on the chosen configuration, the website may use forms, analytics tools, booking systems, payment services, widgets or other third-party modules.

    When data is sent directly to a service chosen by the clinic, that service processes it under its own terms. The clinic is responsible for its configuration, the applicable legal basis, the information provided to visitors and, where required, obtaining consent.

    iGlowly does not use the clinic’s visitor data for its own advertising campaigns and does not sell their personal data.

    6. Hosting and Technical Logs

    Websites are hosted using cloud infrastructure and a content delivery network, including Cloudflare.

    As with any hosting service, this infrastructure may temporarily process technical information such as:

    • the IP address;
    • the date and time of the request;
    • the requested page;
    • the browser and device type;
    • security and operational logs.

    This data is used to deliver the website, prevent misuse, detect incidents and maintain security. Its retention depends on the technical configuration and the infrastructure provider’s practices.

    7. Cookies, Analytics and External Modules

    The standard website may include a basic consent banner and a standard Google Analytics or Google Tag Manager configuration when requested by the Client.

    If the clinic uses marketing tools, trackers or platforms requiring more advanced consent management, it may subscribe to a third-party service such as a cookie consent management platform. iGlowly may integrate this service, but the subscription and compliance of its configuration remain the clinic’s responsibility.

    Booking, payment, mapping, messaging, social media and other external tools may collect data in accordance with their own privacy policies.

    8. Service Providers

    iGlowly may use service providers to deliver the service, including:

    • Cloudflare for website hosting and delivery;
    • Stripe for payment processing;
    • email services for administrative communications;
    • project management and support tools;
    • providers expressly chosen by the Client for its domain, analytics, booking system or other integrations.

    These providers receive only the information necessary to perform their function.

    9. International Transfers

    iGlowly LLC is established in the United States. In connection with the provision of the service, certain personal data relating to the Client may therefore be processed in, or accessed from, the United States. Some technical service providers may also process data outside the European Economic Area.

    Where required by applicable law, these transfers are based on a recognised mechanism, such as an adequacy decision, Standard Contractual Clauses or another appropriate legal safeguard.

    10. Retention

    Data is retained only for as long as necessary for the relevant purposes:

    • information related to the contract for the duration of the commercial relationship;
    • accounting documents for the applicable statutory period;
    • support communications for as long as necessary for follow-up;
    • technical access details only for as long as they are required;
    • technical logs for a limited period related to security and operation.

    At the end of the service, data is deleted, returned, anonymised or archived where required by law.

    11. Security

    iGlowly applies reasonable measures intended to protect data, including:

    • encryption of communications using HTTPS;
    • access restrictions;
    • protection of accounts and technical environments;
    • backups and hosting-related security measures;
    • limiting the sharing of credentials and technical access details.

    However, no system can guarantee absolute security.

    12. The Clinic’s Responsibilities

    The clinic is responsible for:

    • the data it chooses to collect from its visitors;
    • its privacy policy and legal notices;
    • the configuration of its forms and external tools;
    • handling requests received from its patients or visitors;
    • protecting its accounts and credentials;
    • complying with rules relating to medical or sensitive data;
    • entering into any necessary agreements with its own service providers.

    The Client must not send iGlowly patient records, identifiable medical data or other sensitive data that is not necessary for the creation of the website.

    13. Individual Rights

    Depending on the applicable legislation, an individual may request:

    • access to their personal data;
    • correction of inaccurate data;
    • deletion of their data;
    • restriction of processing;
    • data portability, where applicable;
    • objection to certain processing;
    • withdrawal of consent where processing is based on consent.

    Requests concerning administrative data processed directly by iGlowly may be sent to privacy@iglowly.com.

    Requests concerning data collected by a clinic through its website should normally be addressed directly to that clinic.

    A complaint may also be submitted to the competent data protection authority in accordance with applicable law.

    14. Changes

    This policy may be updated to reflect changes to the service, infrastructure or legal obligations. The published version will always indicate the date on which it was last updated.