The real life person bit
We want you to use our website safe in the knowledge that nothing dodgy is happening. We solve this problem by not doing anything dodgy! Our full policy is below, but in summary:
Any data you provide will only be used by us, although we may (legalese for will) use third party providers to store and process that data. It won’t be sold, transferred, gifted or left on anyone’s doorsteps. We’ll also ensure it is protected to a reasonable standard and won’t leave it anywhere that a hacker could easily obtain it.
We’ll have your details for one of two reasons: we have a business relationship with you, or we want one. There’s literally no point in us collecting your data otherwise; it would cost us money to store and we’re not going to sell it, so your info is worthless to us.
If we have a relationship with you, then we’ll be using your data to ‘perform a contract’ (ie, do the business, whether you’re a customer or supplier). This includes any pre-contract communications (such as if you submit an enquiry about one of our services). We won’t automatically add you to a marketing list, although we may suggest you join ours if it contains some relevant goodies.
If we want a relationship with you, we’ll cunningly (and politely) ask for your details in return for some form of goodies. We’ll then use your information to send you stuff that we assume, having submitted your info to a digital marketing agency, you’re going to be interested in. Like digital marketing stuff.
Having already requested some of our good stuff, we believe it’s in our legitimate interests to send you some more to help you become even more knowledgeable about digital business practices. If we’re wrong (and we often are), there’ll be an unsubscribe link which will put the kibosh on our emails, or you can email us at email@example.com. It’d be great if you could tell us where we’ve got it wrong so we can improve, but you don’t have to.
The legal bit
We are DumDum Digital, a trading name of Shortlancer Ltd. Our Data Protection Lead can be contacted at firstname.lastname@example.org.
We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”).
What are your rights?
When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:
• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to withdraw consent at any time, by emailing email@example.com;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.
Who is the Data Controller?
As we have collected your personal data directly from you for our own purposes, we are the Data Controller.
Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:
a) ‘your consent’;
b) ‘performance of a contract’;
c) ‘compliance with a legal obligation’;
d) ‘protection of your, or another’s vital interests’;
e) ‘public interest/official authority’; and
f) ‘our legitimate interests’.
About our Processing of Your Data
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 follows:
Includes Full Name
Includes Address, Phone, Email Address
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.
Examples of Cookies we use:
• Session Cookies. We use Session Cookies to operate our Service. (e.g wordpress_logged_in wordpress_sec_ wordpress_test_cookie)
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Special Categories of Personal Data
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.
Our use of Service Providers:
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
How Long will Your Personal Data be Kept?
DumDum Digital holds personal data whilst engaged in a digital marketing project with yourself and, upon your consent, for a maximum period of 1 year in order to make further projects more efficient.
We will retain your data so long as both the purpose for which it was collected, and your consent, are still valid. We review the status of your consent every twelve (12) months and treat non-response to our requests for renewal of consent as if they were your request to withdraw consent. Occasionally, we might identify a legitimate interest in retaining some of your personal data that has been obtained by consent. If we do, we will inform you that we intend to retain it under these conditions and identify the interest specifically.
All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, as determined by reference to the Limitations Act 1980, for the purposes of exercising or defending legal claims.
Transfer Of Data
Your information, including Personal Data, may be transferred to our suppliers (E.G Digital Agencies / Website Hosts) and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Disclosure Of Data
DumDum Digital may disclose your Personal Data in the good faith belief that such action is necessary to:
• To comply with a legal obligation
• To protect and defend the rights or property of DumDum Digital
• To prevent or investigate possible wrongdoing in connection with the website
• To protect against legal liability
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this
Who can you Complain to?
In addition to sending us your complaints directly to firstname.lastname@example.org you can send complaints to the Information Commissioner’s Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting https://ico.org.uk/concerns/ .