This is the privacy statement of Direct Software Limited (“us”, “we”, “our” and “DSL”) and applies to your use of the DSL’s automated marketing system, which can be referred to as ‘Email Marketing’ during set up. This statement explains:
We may collect, use and store different types of personal information about you, which we have grouped together as follows:
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 offences.
The table below explains how we use your personal information and the reasons that we rely on in doing so. Where these reasons include legitimate interests, we explain what these legitimate interests are.
Consent can be withdrawn at any time by emailing firstname.lastname@example.org stating you would like to withdraw your consent. Please specify which activity you would like to withdraw consent for.
We may collect personal information about you (or your business) from the following sources:
We may share your personal information with the following third parties:
We do take any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.
If you choose not to give your personal information this may delay or prevent us from meeting our obligations to you as a user. This may also mean the software cannot function as intended and therefore lead to us cancelling the service you have with us.
We will keep your personal information for the period of your licence or agreement with us. At the end of this period, you can ask us to delete any personal information we hold about you. You can do this by emailing us at email@example.com. If you do not contact us regarding deleting your personal information and data we will delete this independently within 6 months of your licence ending.
Your personal information is hosted and stored in the cloud via AWS (Elastic compute cloud) EU (London). Some of your personal information will also be stored locally on the premises of DSL, access to all information is controlled by physical barrier to entry and password protection.
Access to your information – You have the right to request a copy of the personal information about you that we hold.
Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information – You have the right to ask us to delete personal information about you where:
Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don't want us to delete the data. Where this right to validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Portability – if we process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine readable format. Where technically feasible, you also have the right to have that personal information transmitted directly to another controller.
Automated processing – if we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you
Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.
We keep this privacy statement under regular review and will place any updates on this website. Paper copies of the privacy statement may also be obtained on request to Bailie Greine, Faucheldean, Broxburn United Kingdom EH52 6PS.
This privacy statement was last updated on 08/02/2019.
If you have any questions about this privacy statement, or how we process your personal information, please contact DSL’s data protection officer (DPO), Ruari Baker, who can be contacted by email at firstname.lastname@example.org. Please put the word “Compliance” in your email subject line so the request is dealt with correctly.
We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office:
By phone: 0303 123 1113
By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF