DIGITAL BACK OFFICE LTD, together with its subsidiaries (“DBO”) has created this Privacy Policy in line with DBO’s commitment to your privacy on DBO websites and marketing initiatives. The following discloses DBO’s information gathering, dissemination and protection practices.
Compliance
If you do not agree to the terms of this Privacy Policy, please do not access or use DBO websites. If you wish to stop receiving DBO marketing materials then please click on the Unsubscribe button within the marketing email you have received from us.
Collection of information
DBO collects information to provide better services to its users and to better understand the visitors to its websites and what content is of interest to them. DBO collects information in the following ways:
- information you affirmatively choose to submit to us (such as your name, email address, company name, title, country) for the purpose of accessing various downloads, viewing specific content, subscribing to DBO newsletters, registering for events and your preferences in receiving marketing from DBO and its third party partners and your communication preferences, etc. Information we have obtained about you from publicly available sources such as social media, marketing platforms or on events, you attended. You will receive marketing communications from DBO if you have requested information from DBO or you or your employer has purchased services from DBO;
- information DBO receives from your use of DBO websites, such as the IP address, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks, domain name and country/state of all visitors to DBO’s websites; location information when you use DBO’s websites as DBO may collect and process information about your location. DBO use various technologies and tools to determine location;
- information that is considered aggregated data such as statistical or demographic data which DBO may use for any purpose. Aggregated data may be derived from your personal information but is not considered personal information in law as it does not directly or indirectly reveal your identity, unless DBO combines or connects aggregated data with your personal information so that it can directly or indirectly identify you; and
- DBO collects technical data from various third parties and public sources as, such as:
- analytics providers
- dvertising networks
- search information providers
Other than as required by law, DBO websites do not collect any special categories of personal information 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). DBO will not collect any information about criminal convictions and offences.
DBO will only use your personal information for the purposes for which it was collected, unless it reasonably considers that it needs to use it for another reason that is compatible with the original purpose. If DBO needs to use your personal information for an unrelated purpose, DBO will notify you and explain the legal basis which allows DBO to do so.
Sharing of Information
DBO may disclose your personal information to the following categories of recipients:
- to its group companies, professional advisers, third party services providers and partners who provide data processing services to DBO (for example, to support the delivery of, provide functionality on, or help to enhance the security of DBO websites), or who otherwise process personal information for purposes that are described in Privacy Notices or notified to you when DBO collects your personal information. A list of DBO’s current group companies is available upon request.
- to any competent law enforcement body, regulatory, government agency, court or other third party where DBO believes disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish or defend its legal rights, or (c) to protect your vital interests or those of any other person.
- to any other person with your consent to the disclosure.
Legal Basis of Processing
If your personal information is protected by EU data protection law, DBO’s legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which DBO collects it.
However, DBO will normally collect personal information from you only (a) where it needs the personal information to perform a contract with you, (b) where the processing is in its legitimate interests and is not overridden by your rights, or (c) where it has your consent to do so. In some cases, DBO may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If you have questions about or need further information concerning the legal basis on which DBO collects and uses your personal information, please contact DBO using the contact details provided under the “Contact Details” heading below and in the right-hand side column.
Use of Information
Any information collected by DBO will be done in accordance with this Privacy Policy for the purposes of making better business decisions, supporting the activities you choose to engage in, and providing higher quality solutions and services to DBO’s customers. DBO uses your location information to tailor your experience with DBO websites. It may also use any non-personal information collected to enhance DBO websites, and your IP address for website diagnostics and administration. DBO will only retain your personal information for as long as necessary to fulfil the purposes it was collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, DBO considers the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which DBO processes your personal information and whether it can achieve those purposes through other means, and the applicable legal requirements.
International Transfers
DBO processes information on servers in many countries around the world and you consent to your personal information being processed on a server located outside the country in which you reside. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, DBO has taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy, including, utilizing the European Commission’s Standard Contractual Clauses for transfers of personal information between its group companies, which requires all group companies to protect personal information being processed from the European Economic Area to an equivalent standard to that required under European Union data protection law.
Information Security
DBO protects your personal information in the same way that it protects its other confidential information, such as storing it on secure servers that only select DBO personnel have access to, and by encrypting it to help prevent access by any unauthorized parties. DBO has put in place procedures to deal with any personal information breach and will notify you and any applicable regulator of a breach when legally required to do so.
Your Data Protection Rights
If your personal information is protected by EU data protection law, you have the following data protection rights which you may be able to exercise by contacting DBO using the contact details provided under the “Contact Details” heading below and in the right-hand side column:
- If you wish to delete, access, correct, update your personal information, you can do so at any time by contacting DBO.
- In addition, you can object to processing of your personal information, ask DBO to restrict processing of your personal information or request portability of your personal information by contacting DBO.
- You have the right to opt-out of marketing communications that DBO sends you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails DBO sends you or by using the relevant opt-out mechanism for non-email based marketing.
- Similarly, if DBO has collected and processes your personal information based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing DBO conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about DBO’s collection and use of your personal information. For more information, please contact your local data protection authority.
- You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, DBO may charge a reasonable fee or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive. DBO tries to respond to all legitimate requests within one month. Occasionally, it may take longer if your request is particularly complex or you have made a number of requests. In this case, DBO will notify you and keep you updated.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies some parts of DBO websites may become inaccessible or not function properly. For more information about the cookies that DBO uses, please see DBO’s Cookie Policy.
Information Security
DBO protects your personal information in the same way that it protects its other confidential information, such as storing it on secure servers that only select DBO personnel have access to, and by encrypting it to help prevent access by any unauthorized parties. DBO has put in place procedures to deal with any personal information breach and will notify you and any applicable regulator of a breach when legally required to do so.
Changes to the Policy
DBO reserves the right to modify or amend this Privacy Policy at its own discretion from time to time. The changes can be viewed here or elsewhere on DBO websites. Your continued use of DBO websites constitutes your acceptance of those changes.
This version was last updated on 06 July 2018 and historic versions can be obtained by contacting DBO.
Contact Details
It is important that the personal information DBO holds about you is accurate and current. Please keep DBO informed if your personal information changes during your relationship with DBO. Additionally, if you have any questions about this Privacy Policy, the practices of DBO websites or your interaction with DBO via DBO websites, please contact: privacy@digitalbackoffice.co.uk