The data controller is Digital Workx Ltd (referred to in this policy as “we” or “us”).

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That’s why we’ve developed this privacy and cookies policy (“Policy”), which:

• sets out the types of personal data that we collect
• explains how and why we collect and use your personal data
• explains when and why we will share personal data within our organisation and our partners
• explains the rights and choices you have when it comes to your personal data

We offer a wide range of products and services, so we want you to be clear about what this Policy covers. This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means:

• Ordering digital marketing services over the phone, or online or otherwise using any of the websites (“our Websites”) or mobile applications (“our Mobile Apps”)
• This Policy also applies if you contact us or we contact you about our Services

This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.

When you purchase our Services, you may provide us with:

• Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title
• Your account login details, such as your username and the password that you have chosen for our My Account system

When you browse our Websites or use our Mobile Apps, we may collect:

• Information about your online browsing behaviour on our Websites and Mobile Apps and information about when you click on one of our adverts (including those shown on other organisations’ websites via Facebook or Google advertising)
• Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)

When you contact us or we contact you or you take part in promotions, competitions, surveys or reviews about our Services, we may collect:

• Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post or when you speak with us through social media
• Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
• Your feedback and contributions to customer surveys or reviews

When you visit our offices:

• footage of you may be recorded on our CCTV systems or those owned by third parties for shared office space

Other sources of personal data

We may also use personal data from other sources, such as specialist companies that supply information, online media channels, our Retail Partners and public registers. For example, this other personal data helps us to:

• review and improve the accuracy of the data we hold; and
• improve and measure the effectiveness of our marketing communications, including online advertising.

This section explains in detail how and why we use personal data. We use personal data to:

Make our Services available to you

This means that processing your personal data allows us to:

• Manage the accounts you hold with us, including your online My Account
• Process your orders and refunds

Why do we process your personal data in this way?

We need to process your personal data so that we can manage your customer accounts, provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.

Manage and improve our day-to-day operations

• Manage and improve our Websites and Mobile Apps

Why do we process your personal data in this way?

We use cookies and similar technologies on our Websites and Mobile Apps to improve your customer experience. Some cookies are necessary so you should not disable these if you want to be able to use all the features of our Websites and Mobile Apps. You can disable other cookies but this may affect your customer experience.

• Help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you

Why do we process your personal data in this way?

We rely on the use of personal data to carry out market research and internal research and development, and to improve our information technology systems (including security) and our product range and services. This allows us to serve you better as a customer.

• Detect and prevent fraud or other crime

Why do we process your personal data in this way?

It is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to make sure that you can safely use our Services.

• Personalise your experience

We use your online browsing behaviour to help us better understand you as a customer and provide you with personalised offers and services.

Why do we process your personal data in this way?

Looking at your browsing behaviour allows us to personalise our offers and services for you. This helps us meet your needs as a customer.

Provide you with relevant marketing communications (including by email, post or online advertising), relating to our products and services, and those of our suppliers and partners. As part of this, online advertising may be displayed on websites on other organisations’ websites and online media channels(including, for example, Facebook and Google Adsense). We may also measure the effectiveness of our marketing communications and those of our suppliers and partners.

Why do we process your personal data in this way?

We want to ensure that we provide you with marketing communications, including online advertising, that is relevant to your interests. To achieve this we also measure your responses to marketing communications relating to products and services we offer, which also means we can offer you products and services that better meet your needs as a customer.

You can change your marketing choices, both when you become a customer, and at any time after that.

You also have choices when it comes to online advertising. We set out below your choices when it comes to cookies, and how you can control your online behavioural advertising preferences.

Contact and interact with you

• Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.

Why do we process your personal data in this way?

We want to serve you better as a customer so we use personal data to provide clarification or assistance in response to your communications.

• Manage promotions and competitions you take part in, including those we run with our suppliers and partners.

Why do we process your personal data in this way?

We need to process your personal data so that we can manage the promotions and competitions you choose to enter.

• Invite you to take part in and manage customer surveys, reviews, and other market research activities carried out by Digital Workx and by other organisations on our behalf.

Why do we process your personal data in this way?

We carry out market research to improve our Services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our Services or your My Account.

Claims

• In order to resolve legal claims or disputes involving you or us.

Why do we process your personal data in this way?

For example, if there is a problem with one of your services that causes downtime or loss of service.

CCTV

To monitor the safety of our offices and shared office space in order to prevent and detect crime.

Why do we process your personal data in this way?

In order to protect our business, the local community, customers and colleagues.

To help us to better understand you as a customer and to be able to provide you with services and marketing communications, including online advertising, that is relevant to your interests we also combine personal data we collect when you order services with personal data collected from our Websites, Mobile Apps and other sources.

In relation to the headings mentioned in the section above (“how and why we use your personal data”), our legal basis for processing your personal data is:

Make our Services available to you

Legal Basis:

• Contractual Necessity – at the time we collect it:
• Purchase & transaction data;
• Contact details;
• Profile details;
• Usernames/Passwords for services;
• Access to third-party services under your control;

We will not be able to provide you with your products or services if you do not provide us with this data.

• Legitimate Interests – following fulfillment of your order for the other personal data in that section.Manage and improve our day-to-day operations

Legal Basis:

• Legitimate Interests.

Personalise your experience

Legal Basis:

• Legitimate Interests

Contact and interact with you

Legal Basis:

• Legitimate Interests.

Claims

Legal Basis:

• Bringing or Defending Legal Claims.

CCTV

Legal Basis:

• Legitimate Interests.

Where we have mentioned above our use of your personal data is based on our “legitimate interests”, these are:

• to service our customers’ needs, including delivering our products and services;
• to promote and market our products and services;
• to service your account (such as your My Account), manage complaints and resolve any disputes;
• to understand our customers including their patterns, behaviours as well as their likes and dislikes;
• to protect and support our business, colleagues and customers;
• to prevent and detect anti-social behaviour, fraud and other crime;
• to test and develop new products and services as well as improve existing ones.

This section explains how and why we share personal data with Partners and Service Providers.

When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes.

Partners and Service Providers

We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing, combining and analyzing data, processing payments, provide us with legal or other professional services as well as delivering orders. We only share personal data that enable our Service Providers to provide their services.

Some of the Service Providers we work with operate online media channels, and they place relevant online advertising for our products and services, as well as those of our suppliers and our Partners, on those online media channels on our behalf. For example, you may see an advert for our products and services as you use a particular social media site or watch television through your pay TV account.

Examples of our Service Providers include Facebook, Google, and Stripe.

This section explains how and why we share personal data with other organisations.

We may share personal data with other organisations in the following circumstances:

• if the law or a public authority says we must share the personal data or for the administration of justice;
• if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud);
• where we restructure, sell or transfer our business (or a part of it). For example in connection with a takeover or merger.

We will not keep your personal data longer than we need to, how long this is depends on several factors, including:

• Why we collected it in the first place;
• How old it is;
• Whether there is a legal/regulatory reason for us to keep it;
• Whether we need it to protect you or us.

This section explains the choices you have when it comes to receiving marketing communications and taking part in market research.

We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices at anytime online, over the phone or in writing.

We also like to hear your views to help us to improve our Services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.

We and our partners use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalise and improve your customer experience as you use our Websites and Mobile Apps and to provide you with relevant online advertising. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies.

How we use Cookies

Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you are using a particular website or mobile app. They can be used only for the duration of your visit or they can be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our Websites and Mobile Apps, and to improve your customer experience.

When you consent to Cookies on our Services, these may be used to do the following:

Improve the way our Websites and Mobile Apps work

Cookies allow us to improve the way our Websites and Mobile Apps work so that we can personalise your experience and allow you to use many of their useful features.

For example, we use Cookies so we can remember your preferences and the searches you’ve made when you return to our Websites and Mobile Apps.

Improve the performance of our Websites and Mobile Apps

Cookies can help us to understand how our Websites and Mobile Apps are being used, for example, by telling us if you get an error messages as you browse.

These Cookies collect data that is mostly aggregated and anonymous.

Deliver relevant online advertising, including via social media

We use Cookies to help us deliver online advertising that we believe is most relevant to you on our Websites and other organisations’ websites and using social media. Cookies used for this purpose are often placed on our Websites by specialist organisations.

Cookies used for this purpose are often placed on our Websites by organisations providing specialist services to us. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.

To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected.

Measuring the effectiveness of our marketing communications, including online advertising

Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you.

Our key partners are listed below with information about the services they provide to us. This list is not exhaustive but it does include those partners with whom we have an established relationship and whose cookie technologies are most frequently deployed through our Services.

Measurement & Personalisation

To analyse how our services are used, including to test different content versions. This data may also be used to enable us to personalise our services and the marketing of our services.

• Adobe
• Optimizely
• Google

Online marketing

To personalise adverts shown to you our websites based on your interactions with us. For example, by using data about your transactions with Digital Workx and what services you have.

• Bing
• Google (Pay Per Click)

Social media

To market to you via social media platforms and to enable social sharing and engagement on our websites. These companies may use your data for their own purposes, including to profile and target you with other advertising.

• Facebook
• Twitter
• LinkedIn

Web browser cookies

You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or another device. You can find more detailed information about how you can manage Cookies through your browser’s help function.

If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

You can also manage advertising related Cookies used on our Services by opting-out through the Service Providers listed in the table above or by visiting the YourOnlineChoices website. Where we display personalised adverts on other organisations’ websites, the AdChoices icon will usually be displayed. Clicking on this icon will provide you with specific guidance on how to control your online advertising preferences. More information is available on the YourAdChoices website.

Mobile Apps

Cookies work differently on Mobile Apps as they are coded into the App itself and will use a unique identifier created by your mobile device for use for advertising activities. You can turn off or reset this advertising identifier through your mobile device’s privacy settings.

You have the right to see the personal data we hold about you. This is called a Subject Access Request.

If you would like a copy of the personal data we hold about you, please write to:

Data Protection Officer

Digital Workx
20-22 Wenlock Road, London, England, N1 7GU

You can also email us at subjectaccess.request@digital-workx.co.uk

In relation to your personal data, you also have the right to:

1. have inaccurate information corrected:Summary of the right: if you believe we hold inaccurate or missing information, please let us know and we will correct it.
2. object to our use of it:Summary of the right:general objection – We will then consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it (see section 3 below) or delete it (see section 4 below).objectionin relation to direct marketing – If you make such an objection, we will stop using your personal data for direct marketing purposes.
3. restrict our use of it:Summary of the right:There are several situations when you can restrict our use of your personal data, this includes (but is not limited to):- you have successfully made a general objection (listed in section 2 above).– you are challenging the accuracy of the personal data we hold.– we have used your personal data unlawfully, but you do not want us to delete it.
4. have us delete it:Summary of the right:There are several situations when you can have us delete your personal data, this includes (but is not limited to):we no longer need to keep your personal data;you have successfully made a general objection (listed in section 2 above);you have withdrawn your consent to us using your personal data (and we do not have any other grounds to use it);we have unlawfully processed your personal data.
5. have us transfer or “port” a copy of it:Summary of the right:Data portability is your right to obtain and reuse the personal information that you have provided to us for your own purposes across different services.
6. complain to the data protection regulator:We’d like the chance to resolve any complaints you have, however you also have the right to complain to the UK data protection regulator (the “ICO”) about how we have used your personal data.Their website is https://ico.org.uk/for-the-public/raising-concerns.Their website also contains useful information about your privacy rights https://ico.org.uk/for-organisations/resources-and-support/your-data-matters

More Information on your Data Protection Rights

The ICO website also contains more detail on the data protection rights mentioned above, or if you would like to speak to us about these rights in more detail, see the “how to contact us” section below.