Effective date: May 17, 2018
1. OUR APPROACH TO PRIVACY
1.2 DITR resells cloud-based information management solutions available via our website (our “Website“) located at https://www.ditr.tech/ and software professional services that we make available (the “DITR Service”).
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
2.1 Information you give to us. We collect personal information about you when you voluntarily submit information directly to us by filling in forms on our Website or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our Website, subscribe to the DITR Service, participate in any discussion boards, forums or other social media functions on our site or enter a competition, promotion or survey and when you report a problem with our Website, or use some other feature of the DITR Service as available from time to time.
2.2 If you choose not to provide personal information, we may not be able to provide the DITR Service to you or respond to your other requests.
2.3 Information we receive from other sources. We may receive personal information about you from individuals or corporate entities which are subscribers to the DITR Service (“Subscribers“) where you are to be designated a user of the DITR Service. We may receive personal information about you if you use any of the other websites we operate or the other services we provide from time to time. We also work closely with third parties (including, for example, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them, subject to your agreements with them.
2.4 The table at Annex 1 sets out the categories of personal information you provide to us and that we receive from other sources and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.
2.5 We also automatically collect personal information about you indirectly about how you access and use the DITR Service and information about the device you use to access the DITR Service.
2.6 The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.
2.7 We may link or combine the personal information we collect and/or receive about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
2.8 We may anonymise and aggregate any of the personal information we collect (so that it does not identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the DITR Service and developing new products and features. We may also share such anonymised information with others.
3. DISCLOSURE OF YOUR PERSONAL INFORMATION
3.2 In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet law enforcement requirements.
3.3 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of service (www.ditr.tech/privacy-notice) and other agreements; or to protect the rights, property, or safety of DITR, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
3.4 Publicly accessible blogs. Our Website includes publicly accessible blogs or community forums. Any information you provide in these areas may be read, collected and used by others who access them. This includes information posted on our public social media accounts. To request removal of your personal information from our blog or community forum, contact us at [email protected] In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
3.5 Testimonials. With consent, we may display personal testimonials of satisfied customers on our site, along with other endorsements. If you wish to update or delete your testimonial, you can contact us at [email protected] .
4. MARKETING AND ADVERTISING
4.1 From time to time we may contact you with relevant information about the DITR Service and our other products and services. Most messages will be sent electronically. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.
4.2 If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can also change your marketing preferences at any time unsubscribe link at the bottom of our emails.
5. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
5.1 Security. All information you provide to us is stored on secure servers in a controlled environment with limited access. Any payment transactions will be encrypted in transit using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Service, you are responsible for keeping this password confidential. Subscribers should not share their password with anyone.
5.2 While no transmission of information via the internet is completely secure, we take reasonable measures to protect your personal information. We cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
6. RETAINING YOUR INFORMATION
6.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
6.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
7. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
7.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
8. COOKIES AND SIMILAR TECHNOLOGIES
8.2 We use the following types of cookies:
8.4 We partner with a third party to either display advertising on our Website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used to serve you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
8.5 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site.
9. LINKS TO THIRD PARTY SITES
9.1 The DITR Service may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
9.2 Some of the pages on our Website may utilize framing techniques to serve content to/from our partners while preserving the look and feel of our Website. Please be aware that you are providing your personal information to these third parties and not to DITR.
10. OUR POLICY TOWARDS CHILDREN
11. CHANGES TO THIS POLICY
12. NOTICE TO YOU
13. CONTACTING US
ANNEX 1 – PERSONAL INFORMATION WE COLLECT
|Category of personal information||How we use it||Legal basis for the processing|
|Contact information and basic personal details. Such as your name, phone number, address, location, IP address, e-mail address and where applicable, professional details such as your bar membership number.||We use this information to communicate with you, including sending statements, news, alerts and marketing communications.||The processing is necessary for our legitimate interests, namely for marketing purposes, and for communicating with you effectively and responding to your queries.|
|We use this information to deal with enquiries and other requests made by or about you, including customer service issues, relating to the DITR Service.|
|We use this information to operate, maintain and provide to you the features and functionality of the DITR Service.||The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms of Service).|
|Email account username and password.||Where you have chosen to import contacts from your Outlook or other email account address book to invite them to become members of our Website, we collect the username and password for the email account you wish to import your contacts from.||The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms of Service).|
|Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, or when you interact with customer service, we will record your comments and opinions.||To address your questions, issues and concerns and resolve your customer service issues.||The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues.|
Details such as your credit card or other financial information including credit scores obtained from credit reference agencies.
|We use this information to facilitate payment for use of the DITR Service, to assess your credit score and to detect and prevent fraud.||The processing for assessing your credit score and facilitating payment is necessary for the performance of our contract with you (namely our Terms of Service).|
The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.
|Recruiting details. Contact information and basic personal details (as set out above); professional details and employment information such as resume, references, LinkedIn profile.||We use this information to facilitate recruiting.||The processing is necessary for our legitimate interests, namely assessing your suitability for a role with DITR.|
|All personal information set out above.||We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the DITR Service, to monitor and improve the DITR Service, our Website and business, for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to keep the Website safe and secure and to help us develop new products and services.||The processing is necessary for our legitimate interest, namely to administer and improve the DITR Service, our business and develop new services.|
ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY
|Category of personal information||How we use it||Legal basis for the processing|
|Information about how you access and use the DITR Service. For example, the website from which you came and the website to which you are going when you leave our Website, your social media profiles, how frequently you access the DITR Service, the time you access the DITR Service and how long you use it for, whether you open emails or click the links contained in emails, whether you access the DITR Service from multiple devices, and other actions you take on the DITR Service. We also gather information, which may include Internet protocol (IP) addresses,\ browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.||We use this information to: conduct market analysis, monitor the DITR Service and how it is used in order to and improve our business and help us develop new products and services; Generate marketing leads and determine news, alerts and other products and services that may be of interest to you for marketing purposes.||The processing is necessary for our legitimate interests, namely: to conduct relevant analysis to improve the DITR Service generally and for marketing purposes.|
|Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the DITR Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the DITR Service through the device, your Internet service provider or mobile network, your IP address.||We use this information to: enable the DITR Service to be presented to you on your device; and operate, maintain and provide to you the features and functionality of the DITR Service. We use this information to monitor and improve the DITR Service and business, and to help us develop new products and services.||The processing is necessary for the performance of a contract and (namely our Terms of Service). The processing is necessary for our legitimate interests, namely: to tailor the DITR Service to the user and to improve the DITR Service generally|