Who we are
This privacy policy applies between you, the User of the Website and Dalasi Ltd, the owner and provider of this Website. Dalasi Ltd takes the privacy of your information very seriously. This privacy policy applies to how our use of any and all Data collected by us or provided by you in relation to your use of the Website and otherwise.
When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU) 2016/679 (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).
We do not knowingly collect personal information relating to children under the age of 16 and children under the age of 16 should not use the Website.
This privacy policy should be read alongside, and in addition to, the terms and conditions entered into between you and us; or if we have not entered into terms and conditions then our standard Terms and Conditions, which can be found at: [link website terms to be confirmed].
Please read this privacy policy carefully.
Contact Details
Our contact details are: [details]
Definitions and interpretation
- In this privacy policy, the following we use the definitions are used:
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Data |
collectively all information that you submit to Dalasi Ltd or its website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws; |
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Cookies |
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies); |
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Data Protection Laws |
any applicable law relating to the processing of personal Data, including but not limited to UK GDPR and EU GDPR, and any national implementing laws, regulations and secondary legislation; |
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Dalasi Ltd, we or us |
Dalasi Ltd, a company incorporated in England and Wales with registered number 12763907 whose registered office is at 20-22 Wenlock Road, London, England N1 7GU. |
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UK and EU Cookie Law |
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011; |
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User or you |
any third party that accesses the Website and is not either (i) employed by Dalasi Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Dalasi Ltd and accessing the Website in connection with the provision of such services; and |
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Website |
https://www.Dalasi.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions. |
- In this privacy policy, unless the context requires a different interpretation:
- the singular includes the plural and vice versa;
- references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- "including" is understood to mean "including without limitation";
- reference to any statutory provision includes any modification or amendment of it;
- the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
- This privacy policy applies only to the actions of Dalasi Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
- For purposes of the applicable Data Protection Laws, Dalasi Ltd is the "data controller". This means that Dalasi Ltd determines the purposes for which, and the manner in which, your Data is processed.
Data collected[AD1] by us
- Depending on the way you use the Website and services you request we may collect the following Data, which includes personal Data, from you:
- name;
- date of birth;
- gender;
- job title;
- profession and interests;
- contact Information such as email addresses and telephone numbers;
- demographic information such as postcode, preferences and interests;
- financial and billing information such as credit / debit card numbers;
- your professional online presence, eg LinkedIn profile
- your contact history, purchase history and saved items
- information from accounts you link to us (such as Facebook)
- Information about how you use our website, IT, communication and other
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
in each case, in accordance with this privacy policy.
We collect and use this personal data to provide products and services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
How we collect Data
- We collect Data in the following ways:
- data is given to us by you ;
- the way you use the Website and communicate with us;
- data is received from other sources; and
- data is collected automatically.
Data that is given to us by you
- Dalasi Ltd will collect your Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you register with us and set up an account to receive our products or services;
- when you make payments to us, through this Website or otherwise;
- when you elect to receive marketing communications from us;
- when you use our services;
in each case, in accordance with this privacy policy.
Data that is received from third parties
- Dalasi Ltd will receive Data about you from the following third parties:
- credit agencies and other data collection organisations;
- regulatory bodies and law enforcement agencies
- approved third party data providers
Data that is received from publicly available third parties sources
- We will receive Data about you from publicly available third party sources such as professional associations.
Data that is collected automatically
- To the extent that you access the Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
Our use of Data
- Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping and legal/regulatory compliance;
- improvement of our products and services;
- ensuring business policies are adhered to;
- to assess eligibility for products and services;
- ensuring the confidentiality of commercially sensitive information;
- in order to be able to provide a product or service;
- Updating and enhancing customer records
- Statutory returns
- Credit reference checks
- preventing unauthorised access and modifications to systems
- to confirm that a sale has taken place between you and a partner or third party provider;
- transmission by email of marketing materials that may be of interest to you;
- communication of product or service updates or renewal reminders to you;
- to confirm details provided, detect financial crime, including fraud;
- contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this privacy policy.
- We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests (having business or commercial reasons to use your information), to comply with our legal and regulatory obligations, where you have given consent or for the performance of a contract with you or to take steps at your request before entering into a contract. Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws by having your explicit consent;
- If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
- For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
- When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- We may use your Data to show you Dalasi Ltd adverts and other content on other websites. If you do not want us to use your data to show you Dalasi Ltd adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).
Who we share Data with
- We may share your Data with the following groups of people for the following reasons:
- our employees, agents and/or professional advisors - to obtain advice from professional advisers;
- third party service providers who provide services to us which require the processing of personal data - to help third party service providers decide if they can and what products and services may be offered under the switching service;
- third party payment providers who process payments made over the Website - to enable third party payment providers to process user payments and refunds;
- third party data providers;
- regulators and regulatory bodies
in each case, in accordance with this privacy policy.
We may also need to: share personal data with external auditors, eg in relation to ISO accreditation and the audit of our accounts; disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations; share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
Keeping Data secure
- We will use technical and organisational measures to safeguard your Data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your Data on secure servers.
- payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.[AD2]
- Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [to be confirmed].
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Data retention
- Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
- Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes (including to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly and to keep records required by law).
Your rights
- You have the following rights in relation to your Data:
- Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase - the right to request that we delete or remove your Data from our systems.
- Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
- Right to data portability - the right to request that we move, copy or transfer your Data.
- Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
- To make enquiries, make a complaint, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [to be confirmed].
- If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
- It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
- This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
Changes of business ownership and control
- Dalasi Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Dalasi Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.