DDCAP LIMITED, DD&CO LIMITED AND DDGI LIMITED
DDCAP Limited, DD&Co Limited and DDGI Limited (collectively referred to hereinafter as “DDCAP”, “we” or “us”) understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.ddcap.co.uk (“Website”), and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
INFORMATION ABOUT DDCAP
DDCAP Limited is a private limited company incorporated and registered in England under company number 05493658, whose registered address is 8-10 Grosvenor Gardens London SW1W 0DH.
DD&Co Limited is a private limited company incorporated and registered in England under company number 00228785, whose registered address is 8-10 Grosvenor Gardens London SW1W 0DH.
DDGI Limited is a private limited company incorporated and registered in England under company number 03393586, whose registered address is 8-10 Grosvenor Gardens London SW1W 0DH.
The person responsible for data protection and privacy at DDCAP is Martin Harris, and he can be contacted by email at firstname.lastname@example.org, by telephone on +44 (0)20 7863 1250, or by post at DDCAP Limited, 8-10 Grosvenor Gardens London SW1W 0DH.
DDCAP Limited owns and operates the Website.
1. WHAT IS PERSONAL DATA?
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a data subject) and an ‘identifiable natural person’ is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
2. WHAT DOES THIS POLICY COVER?
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
3. WHAT DATA DO WE COLLECT?
Depending upon your relationship with us and/or your use of our Website, we may collect some or all of the following personal and non-personal data from you:
In order to deliver services to you and to comply with our regulatory requirements, we may collect some or all of the information listed below. The following list is not exhaustive:
The data we collect about suppliers is limited. We simply need to make sure that our relationship with you runs smoothly. We’ll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We’ll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.
If you contact us via the Website, we will collect any information that you provide to us. The Website does not automatically collect data from visitors.it.
4. HOW DO WE COLLECT YOUR DATA?
Clients and Suppliers
Personal data that you give to us. For example, where you contact us proactively by phone or by email or where we contact you, either directly or as a result of our business development activities more generally.
Personal data that we receive from elsewhere. Where appropriate and in accordance with any local laws and requirements, we may seek more information from other sources by way of due diligence or other market intelligence.
Personal data we collect automatically. Where you read or click on a link in an email from us, where appropriate and in accordance with any local laws, we may automatically collect certain information such as your IP address.
Personal data that you give to us. For example, where you contact us through the Website.
5. HOW DO WE USE YOUR DATA?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on data security, see section 6 below.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests.
We’ve listed below the various ways in which we may use your data in order to establish and maintain our relationship with clients:
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address. However, where you are an individual, we may need your consent for the marketing aspects of these activities which are not covered by our legitimate interests and we’ll ask for this via an explicit opt-in.
If you are not happy about how we are using your data, in certain circumstances you have the right to object (see sections 9, 10 and 11).
We’ve listed below the various ways in which we may use your data in order to establish and maintain our relationship with suppliers:
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
If you are not happy about how we are using your data, in certain circumstances you have the right to object and/or opt out (as appropriate) (see sections 9, 10 and 11).
We use your data to respond to any request or enquiry that you have sent to us via the Website.
6. HOW AND WHERE DO WE STORE YOUR DATA?
Data security is very important to us and we have taken suitable measures to safeguard and secure data collected directly from you or through our Website.
Steps we take to secure and protect your data include (but are not limited to):
We will periodically review our security policies and implement changes from time to time. However, the Internet is not a risk-free place for communication and for that reason, we cannot and do not guarantee complete security, as it does not exist on the Internet. It is your responsibility to ensure that you have adequate and up-to-date anti-virus software and firewalls installed on your device.
7. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
We only keep your personal data for as long as we need to in order to use it as described above and/or for as long as we have your permission to keep it.
We will delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for seven years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
When we refer to “meaningful contact“, we mean, for example, communication between us (either oral or written), or where you are actively engaging with our services. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
8. DO WE SHARE YOUR DATA?
We may share your data with other companies in our group who are based in the UK. From time to time, we may also have to transfer your personal data from the European Economic Area (EEA) to an affiliate of DDCAP or a third party outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your personal data is treated in a manner that is consistent with, and respects, EU and other applicable laws and regulations on data protection.
We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under applicable laws and regulations.
We may compile statistics about the use of our Website. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
In certain circumstances, we may be legally required to share certain data, which may include your personal data, for example, where we are involved in legal proceedings or where we are complying with legal requirements, a court order or a request from a government authority.
9. YOUR RIGHTS
If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us are set out in section 13. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
10. HOW CAN YOU ACCESS YOUR DATA?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. However, we may charge a reasonable fee if your request to exercise your rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
You may exercise your right to access your personal information and right to rectify it by sending us an email at the following address: email@example.com We may need to verify your identity prior to disclosing any personal information in order to ensure that we are not disclosing personal information to, or about, the wrong person.
11. HOW CAN YOU CONTROL YOUR DATA?
In addition to your rights under the GDPR, set out in section 9, when you submit personal data via our Website, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK. These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. CONTACTING US
By post, at:
8-10 Grosvenor Gardens
London United Kingdom
Tel.: +44 (0)20 7863 1250
Last updated: May 2018