1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and the personnel of our suppliers, prospective customers, customers and other business partners.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of these persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 In this policy, “we”, “us” and “our” refer to Digicube Ltd. For more information about us, see Section 13.

2. The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, your email address, your telephone number, your postal address, the name of your business or employer, and your job title or role. The source of the contact data is you and/or your employer.

2.3 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.4 We may process information relating to transactions, including purchases of services, that you enter into with us (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

2.5 We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

2.6 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.

3.3 Relationships and communications – We may process contact data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS and/or post and/or telephone, and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, suppliers, prospective customers, customers and other business partners; the maintenance of our relationships; enabling the use of our services; and the proper administration of our website, services and business.

3.4 Direct marketing – We may process contact data and/or communication data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. We may seek your consent to such processing (in which case the legal basis for the processing will of course be consent). In other cases, the legal basis for this processing will be our legitimate interests in marketing and promoting our business and services.

3.5 Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

3.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

3.7 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.8 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.9 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.10 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

4. Providing your personal data to others

4.1 We may disclose your personal data to our suppliers identified on the services providers data processing page.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.3 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 We may transfer your personal data to our suppliers outside the UK and the EU as detailed on our services providers page referenced in Section 4.1 above. We will ensure that all such transfers are protected by appropriate safeguards as required by applicable UK and EU data protection laws.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

1. (a) contact data and communication data will be retained for a maximum period of 7 years following: (i) if you represent a supplier, customer, prospective customer or other business partner of ours, the date of the last communication between us and that person; or or (ii) otherwise, the date of the last communication between you and us;
2. (b) transaction data will be retained for a maximum period of 7 years following the date of the relevant transaction; and
3. (c) usage data will be retained for 36 months following the date of collection.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Security of personal data

7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3 Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

7.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

1. (a) the right to access – you can ask for copies of your personal data;
2. (b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
3. (c) the right to erasure – you can ask us to erase your personal data;
4. (d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
5. (e) the right to object to processing – you can object to the processing of your personal data;
6. (f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
7. (g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
8. (h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

1. (a) consent; or
2. (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, you should do so in the UK.

8.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Updating information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. Acting as a data processor

11.1 In respect of personal data stored in customer databases to which we have access, and personal data relating to support queries that we handle in the course of the provision of our services, we do not act as a data controller; instead, we act as a data processor.

11.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

12. Amendments

12.1 We may update this policy from time to time by publishing a new version on our website.

12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

13. Our details

13.1 This website is owned and operated by Digicube Ltd.

13.2 We are registered in England and Wales under registration number 06553296, and our registered office is at Castle Way, Fairfield Industrial Estate, Louth, Lincolnshire LN11 0YZ.

13.3 You can contact us:

1. (a) by post, to the postal address given above;
2. (b) using our website contact form;
3. (c) by telephone, on the contact number published on our website; or
4. (d) by email, using the email address published on our website.

14. Data protection registration

14.1 We are registered as a data controller with the UK Information Commissioner’s Office.

14.2 Our data protection registration number is ZA316018.