(Last Updated 16th May 2018)
DueDil is committed to the protection of personal data and the fundamental rights of data subjects, in compliance with relevant laws such as the General Data Protection Regulation (GDPR) and any data protection, electronic communications or e-privacy laws, rules or guidance that are in force in the UK from time to time, including the Data Protection Act 1998 or 2018 or any successor legislation.
In order to support a robust approach to personal data protection and information security in general, DueDil has adopted recommendations by supervisory authorities and industry best practices, including the following international standards where applicable:
- ISO/IEC 27001:2013 Information technology -- Security techniques -- Information security management systems -- Requirements
- ISO/IEC 27002:2013 Information technology -- Security techniques -- Code of practice for information security controls
- ISO/IEC 29134:2017 Information technology -- Security techniques -- Guidelines for privacy impact assessment
- ISO/IEC 29151:2017 Information technology -- Security techniques -- Code of practice for personally identifiable information protection
This website and our services are not intended for children and we do not knowingly collect data relating to children.
In this document, we adopt the same definitions as the GDPR, in particular:
Personal data ‘means any information relating to an identified or identifiable natural personal (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as 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’.
Processing ‘means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction’.
Controller ‘means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law’.
Data Subject ‘means a natural person whose personal data is processed by a controller or processor’.
Processor ‘means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing’.
Personal data breach ‘means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed’.
Definitions from ISO/IEC 29134:2017 also apply, in particular:
Data protection impact assessment (DPIA), also known as privacy impact assessment, means an ‘overall process of identifying, analysing, evaluating, consulting, communicating and planning the treatment of potential privacy impacts with regard to the processing of personally identifiable information, framed within an organization’s broader risk management framework’.
Roles and responsibilities
When DueDil responsible for your personal data and makes all the decisions about how your data is processed, we are acting as the controller. DueDil is also responsible for this website. However, when we are processing your personal data on behalf of a third party in accordance with their strict instructions, we are acting as a data processor.
Full name of legal entity: DueDil Limited
Email address: firstname.lastname@example.org
Registered office: 10 Queen Street Place, London, United Kingdom, EC4R 1AG
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
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. The type of data we collect about you depends on your relationship with us. For example, if you are a company officer or shareholder with details in our product, if you are a visitor to our website or a subscriber to our services. In all cases, we have grouped together the different kinds of data we may or are likely to collect from you:
- Transaction Data which may include details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data which may include 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 and our product.
- Profile Data which may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data which may include information about how you use our website, products and services.
- Marketing and Communications Data which may include your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
From time to time, we may collect some Special Categories of Personal Data about you (for example, if you are an executive contained in our product, or if you are one of our employees) (which may include 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), as well as information about criminal convictions and offences.
Should a case arise for lawful processing Special Categories of Personal Data as set out above, we ensure that all of the appropriate safeguards are in place, including the completion of a Data Protection Impact Assessment (DPIA), the introduction of any additional organisational or technical measures to reduce the associated privacy risk to an acceptable level as well as an appropriate lawful basis for processing. In respect of DPIAs, DueDil has adopted detailed procedures for conducting a DPIA and its reporting structure, in line with ISO/IEC 29134:2017.
If you are unable to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
How your personal data is collected will depend on your relationship with us, for example, if you are a company executive with details in our product, if you are a visitor to our website or a subscriber to our services. We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion o survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, especially concerning company executives or other individuals contained in our product, but also from subscribers and visitors to our site, as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google;
(b) advertising networks; and
(c) search information and other data providers.
- Technical Data from the following parties:
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity, Contact, Special Category Data or Criminal Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside and the EU.
Where we obtain personal data from third party suppliers, we always ensure that these suppliers are bound to respect data protection laws and your privacy rights pursuant to their contract with us.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or with other third parties.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data including in relation to sending direct marketing communications to you via email. You have the right to opt out of marketing or ask any questions about how we process your personal data by contacting us at any time.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data 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 legitmate interest|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To process and deliver your order including:|
(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 to leave a review or take a survey
(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 enable you to partake in a prize draw, competition or complete a survey||
(e) Marketing and Communications
(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(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 ensure that we are able to provide a product to our customers which allows them to comply with their legal and professional obligations and to make informed investment or credit decisions.||
(d) Special Category Data and/or Criminal Data
|Necessary for our legitimate interests and those of our customers and in the public interest (to provide a service to our users to enable them to comply with legal obligations and make informed decisions about their investment or credit decisions). Individual privacy rights are never outweighed by our legitimate interests, since the processing of such data allows for a stable lending, investment and credit system in the UK and assists for the purposes of the prevention or detection of an unlawful act which is in the public interest (for example, protecting the public against dishonesty).|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or 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, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
External Third Parties including:
(a) Service providers acting as processors who provide IT and system administration services
(b) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
(c) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers and who may require reporting of processing activities in certain circumstances
(d) Our customers or clients (for product personal data) and for all personal data, other third parties from time to time which may include market researchers or fraud prevention agencies.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. A list of our third-party processors is available on request.
Personal data breaches
DueDil has established a personal data breach response procedure, adopting recommendations from ISO/IEC 29134:2017 and addressing privacy law requirements related to notification of personal data breaches.
International transfers of personal data
From time to time, we may share your personal data which involves transferring it to third parties who may be established outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax and legal purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DueDil shall keep records of data personal data processing activities and develop appropriate procedures to ensure it can satisfy your rights as a data subject where applicable, namely:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. The right to erasure enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
What we might need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you are not satisfied
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Our number is Z2796684.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.