Welcome to the DPO Adviser privacy notice.
DPO Adviser respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how DPO Adviser collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter OR purchase a product or service.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.
DPO Adviser is the controller and responsible for your personal data (collectively referred to as [“COMPANY”], “we,” “us” or “our” in this privacy notice).
If you have any questions about this privacy notice or our privacy practices, please contact us at [email protected]. We will use reasonable efforts to determine and remedy your problem promptly.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy notice under regular review. This version was last updated on June 13, 2019. 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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any data that can be used directly or indirectly to identify an individual. 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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
- Contact Data includes [billing address, delivery 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 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, your interests, preferences, feedback and survey responses].
- Usage Data includes [information about how you use our website, products and services].
- Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used under this privacy notice.
We do not 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, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We have put in place appropriate technical, organizational, and administrative security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those 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 they are subject to a duty of confidentiality.
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 use different methods to collect data from and about you including through:
- Direct interactions.You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie notice [LINK] for further details.
- Third parties or publicly available sources.We will receive personal data about you from various third parties [and public sources] as set out below
Technical Data from the following parties:
- analytics providers [such as Google based outside the EU];
- advertising networks [such as [NAME] based [inside OR outside] the EU]; and
- search information providers [such as [NAME] based [inside OR outside] the EU].
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as [NAME] based [inside OR outside] the EU].
- Identity and Contact Data from data brokers or aggregators [such as [NAME] based [inside OR outside] the EU].
- Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the EU].
- [ANY OTHER WAYS YOU COLLECT PERSONAL DATA].
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
- Internal Third Parties as set out in the [Glossary].
- 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 OR such as [SPECIFIC THIRD PARTIES]].]
- 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. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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 will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need 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.
Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not 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. 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 set out below, in a table format, a description of 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 what our legitimate interests are where appropriate.
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. Please 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 below.
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Type of Data
Lawful basis for processing including the basis of legitimate interestTo register you as a new customer. a. Identity b. Contact Performance of a contract with you. To process and deliver your order including: a. Manage payments, fees and charges b. Collect and recover money owed to us a. Identity b. Contact c. Financial d. Transaction e. Marketing and Communications a. Performance of a contract with you b. Necessary for our legitimate interests (to recover debts due to us) To manage our relationship with you which will include: a. Notifying you about changes to our terms or privacy notice b. Asking you to leave a review or take a survey a. Identity b. Contact c. Financial d. Transaction e. Marketing and Communications a. Performance of a contract with you b. Necessary to comply with a legal obligation c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To enable you to partake in a prize draw,
competition or complete a survey a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications a. Performance of a contract with you b. Necessary for our legitimate interests (to study how customers use our products/ services, to develop them and grow our business) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). a. Identity b. Contact c. Technical a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) b. Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the
advertising we serve you a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications f. Technical