4. Marketing

4.1 Direct Marketing

When subscribing to our e-newsletter, when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from DLT via e-mail. 

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

4.2 Third-Party Marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

4.3 Opting out of Marketing

You have the right to opt out of receiving marketing communications at any time by:

• contacting us using our contact form on our Website 
• using the ‘unsubscribe’ link in emails

 

5. How do we share your personal data?

In delivering our Services to you, we may share your personal data with:

• Third parties in order to undertake various activities or services on our behalf in supporting our Services. This includes: 
  • website and application support (e.g. Google Analytics), and 
  • hosting and backend infrastructure (e.g. Firebase & Google Cloud);
  • analytics and search engine providers (e.g. Google Analytics); and
  • providers for the delivery of promotional, digital advertising, co-marketing, or other communications. 
• If our business enters into a joint venture, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, new business partners, owners or their advisors. 
• We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation, or to enforce the relevant terms of service and any other agreement, or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organisations such as credit agencies, law enforcement, government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection or in legal proceedings.

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.

6. Analytics and Online Tracking

We work with certain other parties (including analytics companies) to provide us with information regarding traffic on and use of the Services. Some of these parties collect information when you visit the Services or other online websites and services. These other parties set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your IP address or other unique identifiers, log information, and related information about you. These tracking technologies, including the Google Analytics User ID feature, may be used to assist in providing analytics, marketing, and for other purposes. We also use Google services to provide you with in-site search functionality. Both we and Google may collect, receive, and use your information as a consequence of your use of Google services. Google’s data practices are set out in its privacy policy available at https://policies.google.com/privacy.

We do not control the information collection, use, or sharing practices of such parties, and we encourage you to consult their online policies. Some other parties may collect information about your online activities over time and across different websites when you use the Services.

7. How long do we keep your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 (six) further months, after which point we will delete your information.

E-Newsletter or e-mail marketing: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not “unsubscribe”) or if we decide to cancel our e-newsletter service, whichever comes earlier.

8. How do we keep your information safe?

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible; 
• using secure servers to store your information; verifying the identity of any individual who requests access to information before granting them access to information; 
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our Website; and
• pseudonymisation of passwords.

However, despite our efforts to secure your information, no electronic transmission over the Internet or information storage technology can guarantee 100% security. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or unauthorised third parties will not be able to bypass our security measures and access, steal, modify, or collect your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. It is essential that you only access our Services within a secure environment.

9. Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website. We use cookies and web beacons, action tags and single-pixel gifs on our Website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies and any similar technologies (e.g. web beacons, action tags and single-pixel gifs), our use of ‘cookies’ and/or to relevant similar technologies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

10. How do we communicate with you?

We may contact you through email. support@dlthubdemo.com 

11. What are your rights?

You have several rights which you can access free of charge. In certain circumstances, we reserve the right to charge a reasonable fee if your requests are unfounded or excessive. You have the right:

 

• Right to access: You have the right to request a copy of your personal data which you can obtain by sending a message to us using our contact form on our Website. When doing so we will provide you with a copy in a machine-readable format that you can easily transmit to another controller (Right to data portability).

• Right to rectification: You can ask us to change or complete any personal data we hold about you which is inaccurate or incomplete by sending a message using our contact form on our Website. 

• Right to be forgotten/erasure: You have a right, under certain circumstances to ask us to delete any personal data we hold out you. Please note that there may be situations where we must retain your personal data after a request for erasure where we have a lawful basis for doing so.

• Right to restrict the processing of your personal data: You can request us to restrict our use of your personal data if you do not believe your data is accurate, you believe the data processing is unlawful but you do not want us to delete the data, we no longer need the data for its intended purpose but you require it for the establishment, exercise or defence of a legal claim, or you have objected to our use of your personal data and want us to restrict its use until we have decided your objection.  

• Right to object to processing of your personal data: If we process your personal data based on our, or someone else’s, legitimate interest you can object to us using your personal data for that purpose. Please provide us with any information that you can based on which you believe your interest overrides ours.  If you do, we shall reassess our legitimate interest based on the new facts that you have provided and if granted will stop using your personal data for this purpose. When objecting to our use of your personal data for direct marketing purposes we shall stop using your data for such purposes. 

• Right to object to automated decision-making and profiling: You have the right to be informed about the existence of any automated decision-making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.  

• Withdrawal of Consent: Whenever you have given your consent to the processing of your personal data, you can withdraw that consent at any time, doing so is free of charge. You can withdraw your consent directly in your account settings or otherwise at the bottom of any marketing communication that we send you. Please note that you can also withdraw consent for each communication channel separately, including email allowing you to manage your preferences with precision.

12. How can you submit a query or a complaint?

We are always happy to answer your queries regarding privacy. Please contact us using our contact form on our Website

If you have a complaint, please get in touch with us so that we can resolve any concerns. 

If you are located in the UK, you also have a right to lodge a complaint with the Information Commissioners Office if you believe your personal data has been processed in a way which does not comply with the applicable law. You may call the ICO helpline on 0303 123 1113 or visit their website here.

If you are located in the EEA and you believe we are unlawfully processing your personal information, you may also complain to your Member State data protection authority. 

13. Contact Details

If you have any general questions about the Website or the information we collect about you and how we use it, you can contact us directly by using our contact form on our Website.

14. Our Policy Towards Children

We respect the privacy of children and encourage parents and guardians to take an active role in managing their children’s online activities. If you are under 18, please make sure you have consent from your parent and/or guardian before using the Services. We do not knowingly collect personal information from children in connection with those Services. This Policy is written for adults and assumes age-appropriate information will be made available for younger users.

If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us using our contact form on our Website.

Please note that children and their parents or guardians have rights regarding the personal information we hold, including the right to access, correct, and delete this information. We provide clear instructions on how you can exercise these rights.

15. Links to third-party websites

Our Services may contain links to other external websites. We aren’t responsible for the practices, policies or content of such websites and suggest that you check their privacy policies to ensure that you are happy to continue browsing. We do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services or applications. 

We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties including other websites, services, or applications that may be linked to or from Services. You should review the policies of such third parties and contact them directly to respond to your questions. 

16. Changes to our Policy

We update and amend our Policy from time to time.

Minor changes to our Policy

Where we make minor changes to our Policy, we will update our Policy with a new effective date stated at the end of it. Our processing of your information will be governed by the practices set out in that new version of the Policy from its effective date onwards.

Major changes to our Policy or the purposes for which we process your information

Where we make major changes to our Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible). 

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.