Privacy Policy

INTRODUCTION

Welcome to Dexerto Limited’s (“we”, “us”, “our”) privacy policy.

We respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Website (https://www.dexerto.com/) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you create an account, purchase any service or subscription, and/or take part in a competition.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

We are the controller and are responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

  • Name of DPO: Chris Marsh
  • Email address of DPO: chris@dexerto.com
  • Full name of company: Dexerto Limited
  • Email address: privacy@dexerto.com
  • Postal address: 3rd floor, 86-90 Paul Street, London, EC2A 4NE
  • Telephone number: +44 (0)20 3371 7226

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (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.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, and date of birth.
  • Contact Data includes billing address, email address, and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services and subscription(s) you have purchased from us.
  • Technical Data includes 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 this Website.
  • Profile Data includes your username and password, purchases or orders made by you, preferences, and feedback.
  • Usage Data includes information about how you use our Website, products, and subscriptions.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We generally 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, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. However, we may collect this type of data if you voluntarily provide it to us through surveys, sign-up forms, or other methods. Any Special Category data provided will be used solely for the purpose stated at the time of collection and will be stored and processed in accordance with applicable data protection laws and our privacy principles.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. This could impact services or subscriptions. If this is the case, we will notify you.

HOW IS YOUR PERSONAL DATA COLLECTED?

We collect data from and about you through:

  • Direct interactions: This includes Identity, Contact, and Financial Data that you may provide by filling in forms, corresponding with us by post, phone, email, or otherwise. This may occur when you apply for our services or subscriptions, create an account on our Website, request marketing materials, enter a competition, participate in a survey, or give us feedback or contact us.
  • Automated technologies or interactions: As you interact with our Website, we automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites using our cookies. For further details, please see our cookie policy here.

HOW WE USE YOUR PERSONAL DATA

We only use your personal data when the law allows us to. We most commonly use your personal data:

  • To perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Please note that we don’t typically rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. Remember, you have the right to withdraw consent to marketing at any time by contacting us.

LEGITIMATE INTERESTS IMPACT ASSESSMENTS (LIA)

In certain circumstances, we may rely on legitimate interests as the lawful basis for processing your personal data. To ensure that our legitimate interests do not infringe upon your rights and freedoms, we perform a Legitimate Interests Impact Assessment (LIA) for each relevant processing activity.

The LIA involves:

  • Identifying our legitimate interest and ensuring it is lawful and appropriate.
  • Assessing whether the processing is necessary to achieve this interest.
  • Conducting a balancing test to evaluate the potential impact on your rights and freedoms.
  • Implementing appropriate safeguards to mitigate any risks to your privacy.

You have the right to object to the processing of your personal data on the basis of legitimate interests. If you would like more information about the LIA we have conducted for any specific processing activity, please contact our Data Protection Officer (DPO) using the details provided in this policy.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have provided a table below that outlines all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.

We use your personal data in various ways, depending on the specific purpose for which it was collected. The following table outlines the types of personal data we process, the purpose of processing, and the legal basis we rely on, including where legitimate interests apply.

Purpose of Processing

Type of Data

Legal Basis

User Registration and Account Management

Identity Data, Contact Data, Profile Data

Contractual Necessity

Content Recommendation & Personalisation

Identity Data, Technical Data, Usage Data, Profile Data

Legitimate Interests

Conducting Surveys for Market Research, Audience Insights, and Profiling

Identity Data, Usage Data, Survey Responses

Legitimate Interests

Measuring the Delivery and Effectiveness of Advertising

Technical Data, Usage Data, Profile Data

Legitimate Interests

Audience Segmentation and Profiling

Identity Data, Usage Data, Profile Data, Technical Data

Legitimate Interests

Lookalike Audiences

Identity Data, Usage Data, Profile Data

Legitimate Interests

Retargeting and Remarketing

Technical Data, Usage Data, Profile Data

Legitimate Interests

Advertising Personalisation aka Online Behavioural Advertising (OBA) / Interest-Based Advertising (IBA)

Identity Data, Technical Data, Usage Data, Profile Data

Legitimate Interests

Data Sharing with Advertisers and Partners

Aggregated Data, Identity Data, Technical Data, Usage Data

Legitimate Interests

Social Media Advertising

Identity Data, Technical Data, Usage Data

Legitimate Interests

Data Matching and Enrichment

Identity Data, Technical Data, Usage Data

Legitimate Interests

Cross-Device Tracking

Technical Data, Usage Data

Legitimate Interests

To Identify Your Geographical Location and Deliver Relevant Advertising

Technical Data (such as IP address), Usage Data

Legitimate Interests

A/B Testing and Personalization Experiments

Usage Data, Profile Data, Technical Data

Legitimate Interests

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 data. Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage, and Profile Data to determine what we think you may want or need, or what may interest you. This is how we decide which products, services, and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services or subscriptions from us, and have not opted out of receiving marketing materials.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website and adjusting your marketing preferences, following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Please note that opting out of receiving marketing messages will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see here.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above:

  • External Third Parties as set out in the Glossary.
  • Specific third parties listed in the table, ‘purposes for which we will use your personal data’ above.
  • Third parties to 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.

Please note that 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We share your personal data with staff operating outside the UK, involving transferring your data outside the UK. By submitting your personal data, you agree to this transfer, storing, or processing.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

  • We may transfer your personal data to countries that the UK has deemed to provide an adequate level of protection for personal data.
  • We may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK.

Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

DATA BREACH PROCEDURES

We have put in place procedures 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.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

You can ask us to delete your data in some circumstances. We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request restriction of processing your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

Note: We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. We try to respond to all legitimate requests within one month.

GLOSSARY

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/subscription and the most secure experience.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

  • Service Providers: Companies that provide essential services to help us operate and improve our website. These include IT infrastructure providers, hosting services, and content delivery networks that ensure our website is fast and reliable.
  • Content Recommendation and Personalization Providers: Services that help us deliver personalized content and recommendations to our users based on their browsing behavior and preferences. This includes recommendation engines and personalization platforms.
  • Payment Processors: If applicable, companies that securely process payments for subscriptions, donations, or any other transactions that may occur on our website.
  • Professional Advisers: Legal, financial, and insurance professionals who provide us with consultancy, auditing, and advisory services. These advisers may need access to your data to perform their duties.
  • Advertising and Marketing Partners: Third parties that assist us in delivering, targeting, and measuring the effectiveness of advertising on our website. This includes ad networks, demand-side platforms (DSPs), social media platforms, and analytics providers. These partners help us show relevant ads to our users and understand the performance of our ad campaigns.
  • Regulatory and Government Authorities: HM Revenue & Customs, regulators, and other authorities who may require us to disclose personal data in certain circumstances, such as compliance with legal obligations or responding to lawful requests.
  • Cloud Service Providers: Companies that offer cloud storage and hosting solutions, enabling us to store your data securely and efficiently manage our website’s infrastructure.
  • Data Analytics and Research Providers: Third parties that help us analyze user behavior, improve our content, and conduct market research. These providers help us understand how our website is used and how we can improve our services.

Last updated: September 2024.