IMPORTANT INFORMATION AND WHO WE ARE
We are the controller and are responsible for your personal data.
- Name of DPO: Chris Marsh
- Email address of DPO: email@example.com
- Full name of company: Dexerto Limited
- Email address: firstname.lastname@example.org
- Postal address: 3rd floor, 86-90 Paul Street, London, EC2A 4NE
- Telephone number: +44 (0)20 3371 7226
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, and date of birth.
- Contact Data includes billing address, email address, and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services and subscription(s) you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
- Profile Data includes your username and password, purchases or orders made by you, preferences, and feedback.
- Usage Data includes information about how you use our Website, products, and subscriptions.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We generally do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. However, we may collect this type of data if you voluntarily provide it to us through surveys, sign-up forms, or other methods. Any Special Category data provided will be used solely for the purpose stated at the time of collection and will be stored and processed in accordance with applicable data protection laws and our privacy principles.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. This could impact services or subscriptions. If this is the case, we will notify you.
HOW IS YOUR PERSONAL DATA COLLECTED?
We collect data from and about you through:
- Direct interactions: This includes Identity, Contact, and Financial Data that you may provide by filling in forms, corresponding with us by post, phone, email, or otherwise. This may occur when you apply for our services or subscriptions, create an account on our Website, request marketing materials, enter a competition, participate in a survey, or give us feedback or contact us.
HOW WE USE YOUR PERSONAL DATA
We only use your personal data when the law allows us to. We most commonly use your personal data:
- To perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Please note that we don’t typically rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. Remember, you have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have provided a table below that outlines all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage, and Profile Data to determine what we think you may want or need, or what may interest you. This is how we decide which products, services, and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services or subscriptions from us, and have not opted out of receiving marketing materials.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website and adjusting your marketing preferences, following the opt-out links on any marketing message sent to you, or by contacting us at any time.
Please note that opting out of receiving marketing messages will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above:
- External Third Parties as set out in the Glossary.
- Specific third parties listed in the table, ‘purposes for which we will use your personal data’ above.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
Please note that we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data with staff operating outside the UK, involving transferring your data outside the UK. By submitting your personal data, you agree to this transfer, storing, or processing.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
- We may transfer your personal data to countries that the UK has deemed to provide an adequate level of protection for personal data.
- We may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK.
Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
DATA BREACH PROCEDURES
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
You can ask us to delete your data in some circumstances. We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request restriction of processing your personal data.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us.
Note: We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. We try to respond to all legitimate requests within one month.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/subscription and the most secure experience.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties means Service providers acting as processors who provide IT and system administration services; professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services; and HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Last updated: July 2023.