Ahead of the introduction of GDPR in May 2018 the Duuzra team engaged internally and externally to comply with the introduction of the new regulations. The following is a summary of the key actions taken to ensure compliance:
- Training: Data privacy and security training for all company personnel and clarification of updates to security policies, procedures, and their respective responsibilities
- Data hosting: All data is hosted within the EU with our secure Amazon Web Services hosting provider
- Security: Evaluation of the effectiveness of data security measures and data breach notification policy
- Privacy by design approach
Duuzra Event Software Limited (Duuzra, we, us or our) is committed to protecting the privacy and security of your personal data. This Website Privacy Notice describes how we collect, use and look after your personal data when you visit our website (regardless of where you visit it from), including when you contact us or sign up for our newsletter or request a demonstration. It also tells you about your rights and how the law protects you.
This Website Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.
The data we collect about you
How personal data is collected
How we use your personal data
Disclosure of personal data
Your legal rights
Our website is not intended for children and we do not knowingly collect data relating to children. If you become aware that we have collected data from children under age 13, please contact us using the contact information provided below.
Duuzra is the controller and responsible for your personal data.
To assist you further in understanding this Website Privacy Notice, set out in the Schedule is a glossary of terms used in this Website Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
If you have any questions about this Website Privacy Notice, including any requests to exercise your legal rights, please contact our Chief Technical Officer in writing, either by email to: firstname.lastname@example.org; or by post to Station House, Stamford New Road, Altrincham, Cheshire, WA15 1EP.
You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
We may change this Website Privacy Notice at any time by updating this page. Please check this notice from time to time to ensure you are aware of any changes. This Website Privacy Notice as last updated on 6 June 2018.
Your duty to inform us of changes
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Our website includes links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should also read their privacy notices to understand what personal data they collect about you and how they use it
We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
We do not collect any special categories of personal data or any information about criminal convictions and offences.
Failure to provide personal data
If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into or perform the contract with you and we may have to cancel a product or service. We will notify you of this at the relevant time
We collect personal data in the following ways:
|directly||you may provide personal data when you complete an online enquiry form, request products/services (including demos of our software), join our mailing list, enter competitions, promotions or surveys or otherwise or correspond with us (by post, phone or email)|
|publicly available sources||we may collect personal data from publicly availably sources such as Companies House and the Electoral Register and credit reference agencies, based inside the EU|
|third parties||we may receive personal data from: (a) analytics providers based outside the EU (such as Google) (b) advertising networks; (c) search information providers such as Node based outside the EU; (d) our suppliers such as payment providers, delivery services, website hosting, support and maintenance providers; (e) data brokers or aggregators; (f) third party plugin service providers based inside and outside the EEA (such as Olark).|
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
- to perform the contract we may enter into or have entered into with you;
- to comply with a legal obligation; and
- where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
We generally only rely on consent as a legal basis for processing your personal data to send email marketing communications and you have the right to withdraw your consent at any time by contacting us.
Please 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 information.
We may analyse your personal data to form a view on what products and/or services we think may be of interest to you. You will only receive marketing communications from us if:
(i) you have purchased products and/or services from us and you have not opted out of receiving that marketing;
(ii) you have provided us with your consent to receive marketing from us and you have not subsequently opted out or withdrawn your consent.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
How to opt out
You can opt out of email marketing by clicking the unsubscribe button within the particular marketing email. You can also withdraw your consent to marketing at any time by contacting email@example.com.
Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
Change of purpose
We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
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 use your personal data in this manner.
We may process your personal data (without your knowledge or consent) where this is required or permitted by law
We may need to share your personal data with third parties, further details of which are set out in Part 4 of Schedule 1. 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. They can only process your personal data for specified purposes and in accordance with our instructions
We share your personal data within the Duuzra group of companies. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
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 use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers;
- we may transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
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 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. We also limit access to your personal data to those directors, employees, agents, contractors and other third parties who have a business need to know such information and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
We have procedures in place 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.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you
You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact firstname.lastname@example.org.
You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
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.
Part 1: Types of personal data
|contact data||email address|
|identity data||first name, last name|
|marketing and communication data||your preferences in receiving marketing our newsletter and our third parties and your communication preferences|
|technical data||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 our website|
The lawful basis upon which we may rely on to process your personal data are:
|consent||you have given your express consent for us to process your personal data for a specific purpose|
|contract||the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you|
|legal obligation||the processing is necessary for us to comply with a legal or regulatory obligation|
|legitimate interests||the processing is necessary for our or a third party’s legitimate interest, e.g. for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest|
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
|Purpose/Activity||Type of data||Lawful basis for processing|
|to register you as a potential new user||identity & contact||(i) to perform our contract with you or take steps to enter into a contract with you|
|to manage our relationship with you, notifying you about changes to our Terms or Website Privacy Notice and ask you to leave a review or take a survey||identity, contact, marketing & communications||(i) to perform our contract with you
(ii) as necessary to comply with any legal obligations
(iii) as necessary for our legitimate interests in keeping our records updated and analysing how our products/services are being used
|to enable you to partake in prize draws, competitions or complete surveys||identity, contact, marketing & communications||(i) to perform our contract with you
(ii) as necessary for our legitimate interests in analysing how our products/services are used, to develop them and grow our business
|to administer and protect our business, website and app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||identity, contact & technical||(i) as necessary for our legitimate interests in 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
(ii) as necessary to comply with any legal obligations
|to deliver relevant event and website content/advertisements to you and measure or understand the effectiveness of our advertising||identity, contact, marketing & communications & technical||as necessary for our legitimate interests in studying how our products/services are used, to develop them, to grow our business and to inform our marketing strategy|
|to use data analytics to improve our website, app, and other products/services, marketing, user relationships and experiences||technical||as necessary for our legitimate interests to define types of users for our products and/or services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|to make suggestions and recommendations to you about products/services that may be of interest to you, including promotional offers||identity, contact & technical||as necessary for our legitimate interests to develop our products/services and grow our business|
Part 3: Your legal rights
You have the following legal rights in relation to your personal data:
|access your data||you can ask for access to and a copy of your personal data and can check we are lawfully processing it|
|correction||you can ask us to correct any incomplete or inaccurate personal data we hold about you|
|erasure||you can ask us to delete or remove your personal data where:
(a) there is no good reason for us continuing to process it;
(b) you have successfully exercised your right to object (see below);
(c) we may have processed your information unlawfully; or
(d) we are required to erase your personal data to comply with local law.
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request
|object||you can object to the processing of your personal data where:
(a) we are relying on our legitimate interests (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms; or
(b) 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, and, in such circumstances, we can continue to process your personal data for such purposes
|restrict processing||you can ask us to us to suspend or restrict the processing of your personal data, if:
(a) you want us to establish the accuracy of your personal data;
(b) our use of your personal data is unlawful, but you do not want us to erase it;
(c) you need us to hold your personal data (where 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 personal data, but we need to verify whether we have overriding legitimate grounds to use it
|request a transfer||you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format|
|withdraw your consent||you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent|
Part 4: Third Parties
|group companies||other companies in the Duuzra group of companies acting as joint controllers or processors and who are based in the United States of America, the European Union, Dubai and Norway and provide marketing, IT administration and support services|
|service providers||acting as processors based in inside and outside the EEA who provide website hosting services (currently Amazon AWS), analytics services (currently Google) and plugin services (currently Olark)|
|professional advisors||acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United States of America, the European Union, Dubai and Norway who provide consultancy, banking, legal, insurance and accounting services|
|HM Revenue & Customs, regulators and other authorities||acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances|
|third parties||third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Website Privacy Notice|
Part 5: Glossary
|aggregated data||information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject|
|controller||a body that determines the purposes and means of processing personal data|
|data subject||an individual living person identified by personal data (this will generally be you)|
|personal data||information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data|
|processor||a body that is responsible for processing personal data on behalf of a controller.|
|special categories of personal data||information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.|
|ICO||Information Commissioner’s Office, the UK supervisory authority for data protection issues.|