This is the privacy statement of Direct Software Limited (“us”, “we”, “our” and “DSL”) and applies to your use of the DSL’s automated email authority monitoring and improvement system, which can be referred to as ‘NeverSpam’ during set up. This statement explains:
• What types of personal information we collect [Reference 1.]
• How we use your personal information [Reference 2.]
• How you can withdraw your consent, where we process on the basis of consent [Reference 3.]
• Where we collect your personal information from [Reference 4.]
• Who we share your personal information with [Reference 5.]
• How we use your information to make automated decisions [Reference 6.]
• What happens if you do not provide your personal information [Reference 7.]
• How long we retain your personal information [Reference 8.]
• Where we hold your personal information internationally [Reference 9.]
• Your rights [Reference 10.]
• Changes to this statement [Reference 11.]
• Who to contact for further information [Reference 12.]
• How to make a complaint [Reference 13.]
We may collect, use and store different types of personal information about you, which we have grouped together as follows:
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.
The table below explains how we use your personal information and the reasons that we rely on in doing so. Where these reasons include legitimate interests, we explain what these legitimate interests are.
Consent can be withdrawn at any time by emailing email@example.com stating you would like to withdraw your consent. Please specify which activity you would like to withdraw consent for.
We may collect personal information about you (or your business) from the following sources:
• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms, or by corresponding with us (for example, by email or chat). It includes information you provide when you register or create an account, download or register an app, subscribe to any of our services, search for an app or service, and when you report a problem with an app, our services, or any of our sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of our sites or use one of our apps we will automatically collect personal data including Content and Usage Data. We collect this data using analytics code in our software.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.
• Identity and Contact Data from data brokers or aggregators and researchers.
• Identity and Contact Data from publicly available sources such as Companies House based inside the EU and your company website or social media.
We may share your personal information with the following third parties:
• Amazon Web Services via AWS (Elastic compute cloud) EU (London). This is where your data and information is hosted therefore it is shared to this provider.
• Stripe (for payment processing). This processing takes place outside the EU only in data centres which have a certified EU-US privacy shield.
We do take any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.
If you choose not to give your personal information this may delay or prevent us from meeting our obligations to you as a user. This may also mean the software cannot function as intended and therefore lead to us cancelling the service you have with us.
We will keep your personal information for the period of your licence or agreement with us. At the end of this period, you can ask us to delete any personal information we hold about you. You can do this by emailing us at firstname.lastname@example.org. If you do not contact us regarding deleting your personal information and data we will delete this independently within 6 months of your licence ending.
Your personal information is hosted and stored in the cloud via AWS (Elastic compute cloud) EU (London). Some of your personal information will also be stored locally on the premises of DSL, access to all information is controlled by physical barrier to entry and password protection.
Access to your information – You have the right to request a copy of the personal information about you that we hold.
Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information – You have the right to ask us to delete personal information about you where:
• You consider that we no longer require the information for the purposes for which it was obtained
• We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information below
• You have validly objected to our use of your personal information – see Objecting to how we may use your information below
• Our use of your personal information is contrary to law or our other legal obligations.
Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don't want us to delete the data. Where this right to validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Portability – if we process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine readable format. Where technically feasible, you also have the right to have that personal information transmitted directly to another controller.
Automated processing – if we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you
Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.
We keep this privacy statement under regular review and will place any updates on this website. Paper copies of the privacy statement may also be obtained on request to 53 Bothwell Street, Glasgow, Scotland, United Kingdom, G2 6TS.
This privacy statement was last updated on 1/08/2020
If you have any questions about this privacy statement, or how we process your personal information, please contact DSL’s data protection officer (DPO), Ruari Baker, who can be contacted by email at email@example.com. Please put the word “Compliance” in your email subject line so the request is dealt with correctly.
We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office:
By phone: 0303 123 1113
By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF