Last updated: 05/12/22
This Policy may be updated from time to time. We will notify you of any material changes by posting the updated Policy on the website. We recommend consulting this Policy regularly for any changes. These notices may supplement or clarify DX Digital Ltd’s privacy practices or may provide you with additional choices about how DX Digital Ltd processes your personal information.
We will not rent, sell, or share your Personal Information except in accordance with this Policy. If you do not feel comfortable with any part of this Policy, you should cease using our Websites and Services.
1. Policy Scope
DX Digital Ltd is committed to protecting the privacy of individuals who interact with us. This Policy applies to the personal information we collect and use for our own purposes (i.e., as a “data controller”). We provide this Policy to explain the ways in which we collect, use, and share personal information about individuals who:
- visit or interact with our websites, including www.dxdigital.co.uk and the other websites that DX Digital Ltd operates and that link to this Policy (collectively, “Websites”) (“Website Visitors”);
- subscribe to any of our plans located on any of the Websites (our “Services”) through a Subscription Account (“Users”); and
For purposes of this Policy “Websites”, shall refer collectively to www.dxdigital.co.uk, and the other websites that DX Digital Ltd operates and that link to this Policy, the term “Services” shall refer to any of our plans located on any of the Websites. The term “Subscriber” refers to an individual or legal entity that has agreed to an applicable agreement between you and any member of DX Digital Ltd relating to access and use of our Services (“Services Agreement”), including an individual representing the Subscribing company. The term “Account” refers to a DX Digital Ltd account or instance created by or on behalf of a Subscriber within the Services. The term “Users” shall refer to the individuals authorised to use our Services through a Subscriber’s Account.
2. Personal Information You Provide
In this Policy, “personal information” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, including by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.
Account and Registration Information. If you are Subscriber, we must process certain personal information about you such as name, date of birth, place of birth, taxpayer identification number, address, phone number, email address, and name or alias for each of your Users. We may authenticate it against third-party databases. By voluntarily providing us with this information, you represent that you are the owner of such personal information or are otherwise authorised to provide it to us, specifically, if you as a Subscriber provide us information related to the User, you represent that the User has not objected to such processing. We use a third-party intermediary to manage credit card processing.
User Information. We collect certain information automatically from Users through cookies and other tracking technologies when they use a Subscriber’s Account, subject to the applicable law’s consent requirements. We use this information to improve our services. In relation to all of the information that Users voluntarily provide when working in a Subscriber’s Account, the Subscriber is the data controller and we are a data processor.
3. Personal Information Automatically Collected
Logs. As is true with most websites and services delivered over the internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to other information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy. In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this type of information in order to increase our Websites' functionality and user experience and to detect suspicious activity. These third-party service providers have their own privacy policies addressing how they use such information.
Do Not Track. Some Internet browsers, like Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since DX Digital Ltd does not track Users over time and across third-party websites to provide targeted advertising, we therefore do not respond to DNT signals. Third parties cannot collect any other personally identifiable information from DX Digital Ltd unless you provide it to them directly.
We Do Not Request Unsolicited Personal Information. To safeguard against the identity theft practice known as ”phishing”, we do not, and will not, at any time, request your credit card information, account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. We advise you to promptly report any email or telephone communication purporting to be from us in which such information is attempting to be collected. For more information about phishing, visit the Federal Trade Commissionʼs website at https://www.consumer.ftc.gov/articles/how-recognize-and-avoid-phishing-scams
4. Personal Information We Collect From Other Sources
5. Why We Process Your Personal Information
We process your personal information to:
- provide, operate, maintain and improve the Websites and Services;
- enable you to access and use the Services;
- process and complete transactions, and send you related information, including invoices;
- send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
- send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, and events; and provide other news or information about our partners and us;
- monitor and analyse trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
- investigate and prevent unauthorised access to the Services, and other illegal activities;
- personalise the Websites and Services; and
- comply with our legal obligations, including our obligations related to personal data protection.
6. Legal Basis for Processing Personal Information
For individuals who are located in the European Economic Area, the United Kingdom or Switzerland, Japan or Brazil, at the time their personal information is collected, our legal basis for processing your information under the applicable laws will depend on the personal information at issue, the specific context in the which the personal information is collected and the purposes for which it is used. We generally only process your personal information where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms, or where we have obtained your consent to do so. In some rare instances, we may need to process your personal information to protect your vital interests or those of another person.
We process your information for the purposes described in this Policy, based on the following legal grounds:
When we are pursuing legitimate interests. We process your personal information for our legitimate interests and those of third parties. This means that we process your information for things like: providing, operating; maintaining, and improving our Services; enabling you to access and use the Services; promoting the Services; sending promotional communications, including through the use of tools or services that may provide us with personal contact information for potential job applicants or business contact information for prospective customers; monitoring and analysing trends, usage, and activities in connection with the Websites and Services (subject to applicable law); investigating and preventing fraudulent transactions, unauthorised access to the Services, and other illegal activities; personalising the Websites and Services.
When we are providing a service pursuant to a contract. We process your personal information to provide you with our Services pursuant to the Service Agreement or other contract between you and us. This means that we process your personal information to: enable you to access and use the Services; process transactions, and send you related information; provide customer service and support.
When we are complying with legal obligations. We process your personal information when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable governmental request.
With your consent. In certain situations, we may request your consent to process your personal information for specific purposes and you have the right to withdraw your consent at any time.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at [email protected].
7. Why We Share Your Personal Information
We take care to allow your personal information to be accessed only by those who really need access in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We may share personal information about you with third parties in the following circumstances.
Third-Party Service Providers. We share your personal information with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose other than in connection with the services they provide to us.
Our current list of Third-Party Service Providers is as follows:
Amazon Web Services Inc., 410 Terry Avenue North Seattle, WA 98109,USA
Mailgun Technologies, Inc., 112 E Pecan St #1135, San Antonio, TX 78205, USA
Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
Digital Network Solutions Ltd, 102 Hellesdon Park Rd, Norwich NR6 5DR, UK
Civic, 12 South Charlotte Street, Edinburgh, Scotland, EH2 4AX, UK
Testimonials. From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial after giving your consent, you can contact us at [email protected].
Interactive Areas. The Websites may offer feedback forms, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it, in particular to Users who initiated the particular Interactive Area. To request the removal of your personal information from an Interactive Area, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
DX Digital Ltd Sharing. We may share information, including personal information, with any member of DX Digital Ltd.
With Your Consent. We may also share personal information with third parties other than the third parties mentioned in the above sections when we have your consent to do so.
8. Security & Confidentiality
We maintain (and require service providers to maintain) generally accepted, reasonable, and appropriate standards to protect your personal information, both during transmission and once it is received. For example, we employ physical access controls, encryption, Internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing. In deciding what is reasonable and appropriate, we take into account the risks involved and the nature of the information. However, no security procedures or protocols are ever guaranteed to be 100% secure. In the event that we are required by law to inform you of a breach of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
If you have any questions about the security of your personal information, you can contact us at [email protected].
9. Retention of Your Personal Information
10. International Transfer of Personal Information
We primarily store personal information about Website Visitors and Subscribers within the European Economic Area (the “EEA”) and in the United States. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which DX Digital Ltd has operations. If and when transferring your personal data from the EEA, United Kingdom or Switzerland, or via an onward transfer, we rely on the Standard Contractual Clauses adopted by the relevant authority as appropriate safeguards.
We will protect your personal information in accordance with this Policy wherever it is processed and will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws.
11. Your Privacy Rights and Choices
Marketing Communications. If you do not want to receive marketing email communications from us, you can opt-out by clicking on the “unsubscribe” link located at the bottom of our marketing emails or you may send a request to [email protected].
Right to Correct or Update Your Information. You may request that we correct or update any inaccurate or incomplete personal information by contacting [email protected]. Subscribers to our Services may update or change their Account Information at any time by editing their profile or organisation record or by contacting [email protected] for more detailed instructions.
Additional Rights for Certain Territories: If you reside in certain territories (such as the European Economic Area, Switzerland, the United Kingdom, Japan or Brazil), you may have the right to exercise certain privacy rights available to you under applicable law. If any of the rights listed below are not provided under law for your jurisdiction, we have the absolute discretion in providing you with those rights.
Your personal information rights are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorised by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
Right not to provide consent or to withdraw consent: We may seek to rely on your consent in order to process certain personal information. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
Right of access and/or portability: You may have the right to access the personal information that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or port that data to another provider.
Right of erasure: In certain circumstances, you may have the right to the erasure of personal information that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected).
Right to object to processing: You may have the right to request that we stop processing your personal information and/or stop sending you marketing communications.
Right to rectification: You may have the right to require us to correct any inaccurate or incomplete personal information.
Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).
Right to lodge a complaint to your local Data Protection Authority: You may have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.
To assert your privacy rights, please email [email protected]. Please note that to protect your privacy and security, we must be able to verify your identity before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may conduct the verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship with us. You may also use an authorised agent to submit a request to opt out on your behalf if you provide the authorised agent signed written permission to do so.
Rights and Choices where DX Digital Ltd Acts as a Processor: An individual who seeks access to, or who seeks to correct, amend, or delete inaccuracies in personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller)
- LinkedIn by LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland: https://www.linkedin.com/legal/privacy-policy
- Twitter by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, www.twitter.com/en/privacy
The social network providers collect your usage information to provide us with usage statistics.
12. Children’s Personal Information
We do not knowingly collect any personal information from children under the age of 16. If you are under the age of 16, please do not use or submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without parental permission. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Websites or Services, please contact us at [email protected], and we will use commercially reasonable efforts to delete that information.
13. Contact Us
If you have questions regarding this Policy or about the privacy practices of DX Digital Ltd, please contact us by email at [email protected].