1. Introduction
   1. We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
   2. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

2. How we use your personal data
   1. In this Section 2 we have set out:
      1. (a) The general categories of personal data that we may process;
      2. (b) The purposes for which we may process personal data; and
      3. (c) The legal bases of the processing.
   2. We may process [data about your use of our website and services] (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed [for the purposes of analysing the use of the website and services]. The legal basis for this processing is [consent] OR [our legitimate interests], namely [monitoring and improving our website and services].
   3. We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or is necessary for a contract we have with you, or because they have asked you to take specific steps before entering into a contract.
   4. We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent or is necessary for a contract we have with you, or because they have asked you to take specific steps before entering into a contract.
   5. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent or is necessary for a contract we have with you, or because they have asked you to take specific steps before entering into a contract
   6. We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. 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 and our legitimate interests, namely our interest in the proper administration of our website and business.
   7. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or is necessary for a contract we have with you, or because they have asked you to take specific steps before entering into a contract.
   8. We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
   9. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
   10. We may process any of your personal data identified in this policy where necessary for obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
   11. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process [any of your personal data] where such processing is necessary[ for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

3. Providing your personal data to others
   1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
   2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
   3. We may disclose your persona data to our subcontractors insofar as reasonably necessary for the supply and goods/services requested by you.
   4. Financial transactions relating to www.d-techshop.com are handled by our payment services providers, Worldpay. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.worldpay.com/uk
   5. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. Retaining and deleting personal data. Data Retention Policy Information: This Section 4 sets out our data retention policies and procedure. Under ICO guidelines, we only hold personal data for the following purposes and retention periods:
   1. Necessary for Performance of Contract: 12 months after the ceasing of our contract with the customer. For the personal data of existing customers, held under the purpose of “Necessary for Performance of Contract”, we hold the personal data of necessary customer contacts for the lifespan of their products or service contracts, plus an additional 12 months thereafter to ensure we are able to contact any customer in the unlikely event of an emergency, such as a product recall.
   2. Consent: 12 months after the ceasing of contract with the customer OR 12 months after the last engagement with D-Tech. For the personal data of those who have given us consent to contact them, held under the purpose of “Consent”, we hold personal data for 12 months after the person’s last engagement with D-Tech or, should they become a D-Tech customer, for 12 months after the ceasing of our customer contract, as stated above.
   3. Legitimate Interests: 12 months after last engagement D-Tech OR after six unanswered communications. For the personal data of those we contact due to a legitimate interest in our products and services, held under the purpose of “Legitimate Interests”, we hold personal data for 12 months after the person’s last engagement with D-Tech, or following the person’s failure to engage with six consecutive marketing communications – whichever is sooner.
   4. Anonymised Data: Indefinitely. For statistical purposes, and to assist us in improving our products and services, we hold customer review and feedback review indefinitely in an anonymised form.
   5. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
   6. We review this data every 12 months. Should you wish us to remove any of your personal data held under these purposes, you have the right to make requests regarding your data under the Data Rights of Individuals. This policy does not apply to data exempt from GDPR, such as publicly available information.

5. Amendments
   1. We may update this policy from time to time by publishing a new version on our website.
   2. You should check this page occasionally to ensure you are happy with any changes to this policy.
   3. We may notify you of changes to this policy by email
6. Your rights. D-Tech’s Policy in Terms of Data Rights of Individuals: Under the GDPR, you have the stated rights regarding your personal data held by D-Tech – as stated by the ICO: ICO Guide to Individual Data Rights. D-Tech International is committed to protecting your privacy, the security of your data, and your right to access, amend or delete the personal information held by us. Our commitment to your privacy, the security of your personal information, and your right to access, change or remove your personal information, extends fully to any data shared with us by our clients in our role as an external vendor. If you have any data requests, or queries about the data held by D-Tech, please contact our Data Protection Officer James Breakell at: Tel: 01394 420077 Email: james.breakell@d-techinternational.com. Under your individual data rights, we will provide your personal data free of charge, in a structured, commonly used and machine-readable format, such as CSV or XML files, within 1 month of your request. We reserve the right to extend this period for a further 2 months if your request(s) are complex or numerous. We will make every effort to ensure all data is delivered securely.
   1. The right to be informed
   2. The right of access
   3. The right to rectification
   4. The right to erasure
   5. The right to restrict processing
   6. The right to data portability
   7. The right to object
   8. Rights in relation to automated decision making and profiling

7. Third party websites
   1. Our website includes hyperlinks to, and details of, third party websites.
   2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
8. Personal data of children
   1. Our website and services are targeted at persons over the age of 18.
   2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
9. About cookies 
   1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
   2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
   3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. We use cookies for the following purposes:
    1. authentication – we use cookies to identify you when you visit our website and as you navigate our website
    2. status – we use cookies to help us to determine if you are logged into our website
    3. shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website
    4. personalisation – we use cookies to store information about your preferences and to personalise our website for you
    5. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
    6. analysis – we use cookies to help us to analyse the use and performance of our website and services
    7. advertising and re-marketing – we use these cookies for the purposes of re-marketing our own services. We do not use these cookies to collect information to sell to third parties
11. Cookies used by our service providers
    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy
    3. We use Leadoo’s tracking service to follow what users are doing on the site and combine this behavioural data with other data we can gather from e.g. chat interactions. Leadoo uses ETag tracking in order to hook together the same user’s behaviour over several sessions. Please check out Leadoo Marketing Technologies Ltd’s Privacy Policy (https://leadoo.com/privacy-policy/) for more information on what is tracked and what your rights are. Leadoo works as the Processor and we work as the Controller for the data in terms of GDPR. You can stop the tracking by emptying your browser’s cache after the visit. For more on how Leadoo works as a GDPR compliant processor, see https://leadoo.com/privacy-policy-processor/
12. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
       1. (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
       2. (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
       3. (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
       4. (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
       5. (e) https://support.apple.com/kb/PH21411 (Safari);
       6. (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
13. Our details
    1. This website is owned and operated by D-Tech International Ltd.
    2. We are registered in England under registration number 4436097, and our registered office is at Building 136 Bentwaters Parks, Rendlesham, Woodbridge, Suffolk, IP12 2TW.
    3. Our principal place of business is at Building 136 Bentwaters Parks, Rendlesham, Woodbridge, Suffolk, IP12 2TW
    4. You can contact us:
       1. (a) by post, to the postal address given above;
       2. (b) using our website contact form;
       3. (c) by telephone, on the contact number published on our website from time to time:
       4. (d) by email, using the email address published on our website from time to time.
14. Representative within the European Union
    1. Our representative within the European Union with respect to our obligations under data protection law is James Breakell and you can contact our representative by using our contact form via our website.
    2. Personal data held by D-Tech UK is never transferred outside of the EEA.
15. Data protection officer
    1. Our data protection officer’s contact details are:

James Breakell
Managing Director / Data Protection Officer

D-Tech International Ltd
Building 136 Bentwaters Parks
Rendlesham
Nr Woodbridge
Suffolk
IP12 2TW

Email: james.breakell@d-techinternational.com
Tel: 01394 420077

 

If you have any concerns about the way we handle your personal data, you have the right to make a formal complaint to the ICO (Information Commissioner’s Office).   More details on how to go about this can be found on the ICO website at: https://ico.org.uk/concerns/