We are committed to protecting and respecting your privacy. Please read this policy carefully to understand how we will collect, use and share your personal data.
IMPORTANT INFORMATION AND WHO WE ARE
Digital Barriers Services Limited, company number 06883884, is a company established under the laws of England and Wales with its registered office at Milton Gate, 60 Chiswell Street, London, United Kingdom, United Kingdom, EC1Y 4AG.
DBS provide hardware products and a cloud-based software service via our website (together “Products“).
Except as stated otherwise, DBS is an independent controller of your personal data.
Where you purchase our Products directly from us, you will be the controller of personal data processed through the use of our Products and we will process that data only on your documented instruction.
Where you purchase Products via a reseller, the reseller will act as the data processor and we will be a sub-processor of your personal data. In each case we will comply with our responsibilities under the relevant data protection laws.
HOW TO CONTACT US
- Post: Digital Barriers c/o Digital Barriers Services Limited, Milton Gate, 60 Chiswell Street, London, United Kingdom, EC1Y 4AG
- Email: firstname.lastname@example.org
PERSONAL DATA WE MAY COLLECT FROM YOU
We may collect and process the following personal data about you either when you provide it to us, or from information we collect about how you use our services and website. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of Products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences and feedback and any issues you have encountered which you have asked us to fix.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Video and Image Data includes video and images captured through use of our Products.
We also collect, use and share aggregated data such as statistical data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. We may use aggregated data to improve our Products and services.
HOW IS PERSONAL DATA COLLECTED?
- Direct Interactions with you: You may provide us with Identity Data, Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data, Usage Data, Marketing and Communications Data and Audio, Image and Visual Data when:
- corresponding with us e.g. making an enquiry or providing feedback;
- registering as a customer or creating an account;
- making payment to us;
- using a Product;
- subscribing to any of our services;
- when you report a problem with Products.
- Automated technologies or interactions: As you interact with our website and Products, we automatically collect Technical Data, including the type of computer or device you use to access the Products, a unique device identifier, mobile network information, your operating system, the internet protocol address used to connect your computer or device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and information about your session, including the full uniform resource locators clickstream to, through and from our Products (including date and time), response times, errors, interaction information (such as scrolling, clicks, and mouse-overs) and any phone number used to call our customer service number.
- Third parties: We will receive personal data about you from various third parties including Google in respect of Google AdWords and Google Tags.
HOW WE USE PERSONAL DATA
We will use your personal data as set out in the table below.
Please note we may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. You can contact us if you need more specific information where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver the Products including (including where this is through a reseller):
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you for feedback
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our Products, business and this website (including securing / authenticating user accounts, troubleshooting, data analysis, testing and system maintenance, providing technical support, hosting of data, statistical, reporting and survey purposes)||(a) Identity
(d) Video, Image and Audio Data
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To allow you to use our Products and participate in interactive features of our Products and services, when you choose to do so e.g. sending of alerts.||(a) Identity
(e) Video, Image and Audio Data
|Performance of a contract with you.|
|To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, Products, services, marketing, customer relationships and experiences and ensure content is delivered in the most effective way for your computer or device||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
THIRD PARTY SHARING AND DISCLOSURE OF YOUR PERSONAL DATA
We will not share your data with third parties except as follows:
- We may share your personal data with any member of the group of companies of which we are a part where that is necessary for the purpose of providing services to you, such as support services, or where necessary for legal compliance.
- We may disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- in the event that Digital Barriers Services Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or request from law enforcement authority; or
- to protect the rights, property, or safety of Digital Barriers Services Limited, our users or others. This includes exchanging personal data with service providers, external advisers, and other companies and organisations for the purposes of fraud protection and credit risk reduction.
- We may disclose your personal data to third parties:
STORAGE AND TRANSFER OF YOUR PERSONAL DATA
Some of our external third party providers are based outside the UK and the European Economic Area (EEA). This means that the data that we collect from you, or that you provide to us, may be processed and stored by us outside of the UK or EEA.
Whenever we transfer your personal data out of the UK or EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented for example:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
We may use your personal data to form a view on what Services or Products we think you may want or need, or what may be of interest to you. This is how we decide which Products, Services and offers may be relevant for you.
You will receive marketing communications from us if you have given your consent, you have requested information from us or used our Services and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, we will continue to contact you about your agreement.
RETENTION OF 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.
We will retain your personal data for as long as your account is active or as needed to provide you with access to our products and services. If you wish to cancel your account or request that we no longer use your personal data to provide you with access to our Products, you can contact us at email@example.com. We will only retain and use your personal data thereafter as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Video and Audio Data
Audio and video data processed as part of Digital Barriers will be retained for a period of 30 days unless the customer, as the data controller, requests a different retention period.
SECURITY OF YOUR PERSONAL DATA
The security of your personal data is important to us. We comply with accepted industry standards to protect the personal data submitted to us and with our obligations under applicable data protection laws in relation to the security of your personal data, including by having appropriate technical and organisational measures in place to help protect personal data against unauthorised processing and accidental loss, destruction or damage.
Although we use strict procedures and advanced security features to try to prevent unauthorised access, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. Where we have given you (or where you have chosen) a password which enables you to access certain parts of a Product, you are responsible for keeping this password confidential. You are not permitted to share a password with anyone. Our website and Products may, from time to time, contain links to and from the websites of third parties such as our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that we do not accept any responsibility or liability to you in relation to your use of that website. We encourage you to carefully read the privacy notice of any website you visit.
HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS
You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out under “How to contact us” above.
- Access to your personal data: You can contact us to request the information we hold about you, as well as supplementary information such as why we have that information, who has access to the information and where we got the information.
- Withdrawing consent: If you have given us your consent to use your personal data, you can withdraw your consent at any time. In particular, if you have given us consent to send you marketing emails, you can withdraw your consent by clicking the “unsubscribe” link in any marketing email which you receive or by emailing us at firstname.lastname@example.org.
- Correction of your personal data: If the data we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.
- Erasure of your personal data: You can request that we erase the information we hold. When we receive your request, we will confirm whether the information has been deleted or tell you the reason why it cannot be deleted.
- Objection to processing your personal data: You have the right to request that we stop processing your information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue – for example, we may need to continue to hold your information for regulatory or legal reasons.
- Objection to direct marketing: You have the right to request that we stop contacting you with direct marketing.
- Restriction: You can ask us to temporarily limit the use of your personal data – for example, where you have questioned the accuracy of your information or how it is being used, but you do not want us to delete it.
- Portable data: You can ask us to provide you with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred. In some circumstances, you can ask us to share the information with third parties. Once we have received your request, we will comply where it is feasible to do so.
- Automated decision-making: You also have certain right to challenge decisions made about you. Further information in relation to the automated decision-making we carry out is above.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
You can make a complaint to us by contacting us at email@example.com or alternatively to the data protection supervisory authority in the UK, which is the ICO, contactable at https://ico.org.uk/.
If you are still looking for more information then please feel free to contact us.