WHAT ARE COOKIES?
Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers.
What types of cookies do we use on our marketing website?
Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our website and using its features.
These cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use the website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the website.
HOW TO DELETE COOKIES?
If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. Alternatively, you can visit www.internetcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device.
Digital Innk Ltd respects your privacy and is committed to protecting the security of your personal data. This Privacy Notice describes how Digital INNK Ltd and its subsidiaries, affiliates, and related entities (collectively, “we,” or “us”) collect and process personal data about you.
Digital Innk Ltd takes all reasonable steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes. It is important that you read this privacy notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
PLEASE NOTE: Our services including our app and website(s) are not intended for use by anyone under the age of 17 (driver age) and we do not knowingly collect data relating to children.
THE TYPE OF PERSONAL INFORMATION WE COLLECT
We currently collect and process the following information from your use of our website:
- Identity Data which includes your name and email address as supplied by using any of our contact forms.
Technical Data which includes internet protocol (IP) address, your login data, browser type and version, browser use, time zone setting and location, the length of time of your visit, the pages you looked at on our site, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data which includes information about how you use our website, products, and services.
Marketing and Communications Data which includes 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.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you, including 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.
HOW WE GET THE PERSONAL INFORMATION AND WHY WE HAVE IT
Most of the personal information we process is provided to us directly by you if you use the forms on our website in order to make contact with us.
We may also receive personal information indirectly, from the following sources in the following scenarios:
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers, such as Google, which may be based outside the EU.
PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
We will only use your personal data when the law allows us. Most commonly, we will use your personal data in the following circumstances:
- To enable us to deal with your online enquiry and to register your interest in our products and services.
- To manage our relationship with you and provide you with effective customer support
Which will include:
- Training and consulting
- New feature announcements
- Asking you to leave a review or take a survey
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
- To make suggestions and recommendations to you about goods or services that may be of interest to you
- To comply with applicable law
We may also process your personal data:
• To prevent fraud.
• To administer IT services, ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
We will not share your information with any third-party for the purposes of unsolicited mail and/or contact.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
Your consent. You are able to remove your consent at any time. You can do this by contacting DPO@digitalinnk.com
YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at DPO@digitalinnk.com if you wish to make a request.
We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We will only process your personal data without your knowledge or consent where required by applicable law or regulation.
THIRD PARTY SOURCES
We have integrated Google Analytics (with anonymisation function) on this website.
Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website a data subject has come to a website from (so-called referrers), which subpages of the website were accessed or how often and for which period of time a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
As IP anonymization is activated on our website, your IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by a Google server in the USA. On behalf of the operator of the website, Google will use this information to evaluate your use of the website, compile reports on website activity and to provide further services related to website and internet use to us. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.
In addition, this website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data.
You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible.
In addition, you may prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en
In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.
Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/ The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/.
Our website also uses Google Analytics performance reports relating to demographics and interests and reports on Google Display Network impressions. You can disable Google Analytics for display advertising and customize the ads on the Google Display Network by visiting the ad settings at this link: https://adssettings.google.com
HOW WE MAY SHARE YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out above:
Internal/External Third Parties such as:
- Vendors and service providers acting as processors who provide IT and system administration services.
- Professional advisers and other agents and representatives acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors or joint controllers based in the European Union who require reporting of processing activities in certain circumstances.
- With other related subscribers to our services, including but not limited to, automotive dealerships, automotive manufacturers, repair facilities, parts suppliers, and insurance companies in order to facilitate transactions; or Third-parties that conduct customer satisfaction surveys on behalf of Digital Innk Ltd. Third-parties are used to ensure anonymity of survey respondents.
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our service contract with you.
- As part of our regular reporting activities to other members of our group of companies.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
- To protect the rights and property of Digital Innk Ltd.
- During emergency situations.
- Where the personal data is publicly available.
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
- For additional purposes with your consent where such consent is required by law.
Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary to perform our service contract with you and for the purposes set out in this Privacy Notice.
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.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- 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; or
where we transfer your personal data between the Digital Innk Ltd Group of companies, we have implemented adequate safeguards in the form of an Intra Group International Transfer Agreement, including the Standard Contractual Clauses for processors approved by European Commission Decision C(2010)593, among all of the Digital Innk Ltd Group of companies to secure the transfer of your personal data to the United States and other jurisdictions.
Please contact us at DPO@digitalinnk.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
WHERE WE STORE YOUR DATA
We store your data within a database located with a secure cloud service provider with whom we contract directly. The primary servers containing your data are hosted in the United Kingdom. Additionally your details may be held securely within our centralised database of contacts which is also based in the United Kingdom.
We additionally utilise analytics service providers such as Google to improve our website, products/services, marketing, customer relationships and experiences.
HOW DO WE ENSURE THE SECURITY OF YOUR DATA?
Digital Innk Ltd has 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 further require all our third-party service providers to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We take all reasonable measures to ensure that our third-party service providers do not 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.
We have also 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.
HOW LONG WE WILL USE YOUR PERSONAL DATA?
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 or as necessary to resolve disputes. Unless required for specific legal purposes e.g. for storage of accounting background, personal data will not be held for any longer than 1 year past the live usage of that data. Your data will be permanently removed from the live versions of our system but may be held in backup also for 1 year from the live usage of that data.
In circumstances where we 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.
YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
If you wish to exercise any of the rights set out above, please contact us at DPO@digitalinnk.com
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. Reasonable access to your personal information will normally be provided at no cost.
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.
If for some reason access is denied, we will provide an explanation as to why access has been denied.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this Privacy Notice at any time. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.
If you have any questions or concerns about our processing of your personal data or would like to make an access or other request, please contact us at:
OR VIA MAIL AT:
Data Protection Officer,
Digital Innk Ltd,
3c Manor Drive,
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO Website: https://www.ico.org.uk
Effective Date: December 14, 2020