PRIVACY NOTICE

Version: 1.2

Revision Date: 2019-11-01 

 

1. INTRODUCTION

We appreciate the trust you place in us when sharing your personal data. The privacy and security of that personal data is very important to us.

In this document, we will explain how we collect, use and protect your personal data. We will also explain what rights you have with regards to your personal data and how you can exercise those rights.

2. WHO WE ARE

Data Privacy Trust is a trading name of Navian Consulting Ltd, a UK based private company doing business in the Netherlands and the UK. Data Privacy Trust is associated with a list of related domains and web addresses (as listed in section 3).

As a data controller, Data Privacy Trust determines which data is collected, how this data is going to be used, how this data is protected, and whether this data is shared with any 3rd parties.

 

Our registered office address is:

Data Privacy Trust

71-75 Shelton Street
London WC2H 9JQ

United Kingdom

Navian Consulting Ltd is registered in United Kingdom as a private limited company with registration number 11673456.

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at dataprotection@dataprivacytrust.com.

 

3. COMPANIES AND WEBSITES WITHIN SCOPE

The following companies and websites are within scope for this Privacy Notice:

 

Global: https://www.dataprivacytrust.com/

Belgium: https://www.dataprivacytrust.be/

Netherlands: https://www.dataprivacytrust.nl/

Sweden: https://www.dataprivacytrust.se/

UK: https://www.dataprivacytrust.co.uk/

Unless specifically stated, we consider these EU-based websites. For more information on non-EU data processing please see section 6.

 

This policy also covers any additional personal data collected through various channels including:

  • By means of our website pages;

  • By means of online payments;

  • By means of web analytics;

  • By means of telephone communications;

  • By means of chat communication;

  • By means of email messages;

  • By means of physical correspondence;

  • By means of face to face conversations (e.g. at events or trade shows).

 

Please note that our website also contains external links to other 3rd party websites:

  • Our Core Solution Partners (which are explicitly listed in the Partners section on our website);

  • Our Social Media Presence (which are linked from the home page on our website).

 

When you use these external links to connect to another 3rd party website, this Privacy Notice is no longer applicable. Please note that the website you enter, after having made use of such an external link, may apply its own privacy statements. Data Privacy Trust is not responsible for the processing of your personal data on any other websites than our website.

 

4. COLLECTION OF PERSONAL DATA

We collect personal data from you for one or more of the following purposes:

 

  1. To provide you with information that you have requested or that we think may be relevant to you.

  2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.

  3. To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances it may be your entity, rather than yourself, that has provided us with your personal data.

  4. To ensure the security and safe operation of our websites and underlying business infrastructure.

  5. To manage any communication between you and us.

 

The table in section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

 

In addition, to ensure that each visitor to our website can use and navigate effectively, we collect the following:

 

  • Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.

 

  • Your browser type and version.

 

  • Your operating system type and version.

 

  • Information about your visit, including the URL (Uniform Resource Locators) clickstream to and from our website.

 

  • Your login information (only if you access secure password protected areas)

 

Our Cookie Policy, which can be viewed from the home page of our website, describes in detail how we use cookies.

 

In section 8 below, we identify your data subject rights in respect of the personal data that we collect and describe how you can exercise those rights.

 

5. LAWFUL BASIS FOR PROCESSING OF PERSONAL DATA

The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common platforms.

 

We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and where this happens it is also identified below.

 

When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:

 

  • Purpose test – is there a legitimate interest behind the processing?

 

  • Necessity test – is the processing necessary for that purpose?

 

  • Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?

1. Subject matter information

Clarification: Provide you with information

 

A) Purpose: Provide appropriate online or email information about products and services that you have requested

  • Legal basis: Contractual performance

  • Data collected: Name, company name, geographic location, email address, business sector

  • Shared with: Internally only

  • Retention period: Maximum three (3) years from the date the information is collected

B) Purpose: Provide further, related, online or email information or ongoing updates regarding identified areas of interest

  • Legal basis: Legitimate interest

  • Data collected: Name, company name, geographic location, email address, business sector

  • Shared with: Internally only

  • Retention period: Maximum one (1) year if a marketing email is left unopened

 

C) Purpose: Follow up to ensure requested information meets needs and identify further requirements

  • Legal basis: Legitimate interest

  • Data collected: Telephone number

  • Shared with: Internally only

  • Retention period: Maximum three (3) years from the date the information is collected

 

D) Purpose: General mailing list subscription

  • Legal basis: Consent

  • Data collected: Personal contact information as provided through website forms or at trade shows or any other means

  • Shared with: Internally only

  • Retention period: Maximum one (1) year if a marketing email is left unopened

 

2. Transaction details

Clarification: To process your transactional information

 

A) Purpose: Process customer purchases of products and services, and ensure any transaction issues can be dealt with

  • Legal basis: Contractual performance

  • Data collected: Name, physical address, email address, telephone number, bank account details, purchased items

  • Shared with: Internally only

  • Retention period: Maximum eight (8) years from the contract date

 

B) Purpose: Document monetary transactions for accounting and taxation purposes

  • Legal basis: Legal obligation

  • Data collected: Name, physical address, email address, telephone number, bank account details, purchase items

  • Shared with: Internally and professional advisers

  • Retention period: Maximum one (1) year from the date the data subject entered personal information but did not proceed with a transaction

 

C) Purpose: Keep updated documentation on file in case of contractual claim

  • Legal basis: Legitimate interest

  • Data collected: Name, physical address, email address, telephone number, bank account details, purchase items

  • Shared with: Internally and professional advisers

  • Retention period: Eight (8) years for VAT records from the performance of the contract

 

3. Payment data

Clarification: Process your payment information

 

A) Purpose: Fulfil purchase requests using card payments

  • Legal basis: Contractual performance

  • Data collected: Primary account number (PAN), cardholder name, service code, expiration date

  • Shared with: Payment card companies, all in line with PCI-DSS

  • Retention period: Only retained while the payment authorization is pending

 

4. Fulfilment data

Clarification: Provide services according to your request

 

A) Purpose: Appropriate catering arrangements for events

  • Legal basis: Contractual performance

  • Data collected: Name and dietary requirements

  • Shared with: Internally and event venues

  • Retention period: Maximum six (6) years from the date of the performance of the contract

 

B) Purpose: Access to events and attendance registers

  • Legal basis: Contractual performance

  • Data collected: Name, contact and identification details

  • Shared with: Internally and event venues

  • Retention period: Maximum six (6) years from the date of the performance of the contract

 

C) Purpose: Exam attendance, exam results and certifications

  • Legal basis: Contractual performance

  • Data collected: Name, contact and identification details

  • Shared with: Internally, and external examiners, proctors and certification bodies

  • Retention period: Maximum six (6) years from the date of the performance of the contract

 

D) Purpose: Processing licensing details necessary for allocation and maintenance of a license purchased for use of software products

  • Legal basis: Contractual performance

  • Data collected: Name, address(es), email address, and contact details

  • Shared with: Internally, and any third parties whose products or services you may have purchased from us

  • Retention period: Maximum six (6) years from the date of the performance of the contract

 

E) Purpose: Actual delivery of products or services, in physical or digital form, that you may have purchased from us

  • Legal basis: Contractual performance

  • Data collected: Name, address(es), email address, and contact details

  • Shared with: Internally and any 3rd party logistics or supplier companies with whom we contract in order to fulfil these requirements

  • Retention period: Maximum six (6) years from the date of the performance of the contract

 

5. Security information

Clarification: Safeguard confidentiality, integrity, availability and resilience of our infrastructure

 

A) Purpose: To protect our websites and infrastructure from cyber-attack or other threats and to report and deal with any illegal acts

  • Legal basis: Legitimate interest

  • Data collected: Technical information, as described in section 4, plus any other information that may be required for this purpose

  • Shared with: Internally and, as necessary, with forensics and other organisations that we might contract for this purpose

  • Retention period: Maximum three (3) years

 

6. Contact information

Clarification: Fulfil support communication on your request

A) Purpose: To communicate with you about any issue that you raise with us or which follows from an interaction

  • Legal basis: Legitimate interest

  • Data collected: Names, contact details, identification details

  • Shared with: Internally and, as necessary, with professional advisers

  • Retention period: Maximum three (3) years

7. Call recording data

Clarification: Deliver a high-quality experience to customers

A) Purpose: Provide a consistent experience and improve the quality of our service

  • Legal basis: Legitimate interest

  • Data collected: Names, contact details, identification details

  • Shared with: Internally and, as necessary, with professional advisers

  • Retention period: Maximum three (3) years

8. Survey data

Clarification: Learn about future needs

A) Purpose: Deliver new products that meet the expectations and requirements of our customers

  • Legal basis: Consent

  • Data collected: Names, contact details, identification details

  • Shared with: Internally and, where additional consent is given, for marketing purposes

  • Retention period: If anonymised for statistical research, this data may be kept indefinitely. Where not anonymised, it shall be retained for a maximum of one (1) year

6. STORAGE OF PERSONAL DATA

Data Privacy Trust is a UK-based organisation whose primary offices are in London.

 

  • The majority of our websites and web applications are hosted in the EU and are accessed only by our EU-based staff.

 

  • We have appropriate contractual and security measures in place to ensure that personal data is protected on the basis on adequacy.

 

  • Our customer relationship management, marketing and accounting systems for all our businesses are either EU-based or hosted by companies participating in the EU-US Privacy Shield Framework.

 

  • We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.

 

  • Unless we specifically state otherwise, all the CSPs that we use utilise EU-located processing facilities.

 

  • Our payment processors and banking arrangements are based in the EU.

 

  • While shipping and delivering physical products we use logistics companies that are based outside the EU and operate in other countries. We have appropriate legal and security relationships with those partners.

 

  • We resell products supplied by organisations outside the EU. This may mean that our resale partner will have access to information about data subjects who purchase their products.

 

  • When we engage third parties to perform services on our behalf, we protect the confidentiality and integrity of your personal data through contractual arrangements.

 

  • We operate a data retention policy in respect of all data, whether paper-based or digital, and those aspects of it that relate to personal data are contained in the table at 5, above.

 

7. SECURITY MEASURES

We have what we believe are appropriate security controls in place to protect your personal data.

 

We also conduct periodic risk assessments, including assessing risks to the rights and freedoms of data subjects.

 

We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information.

 

We do not accept any liability in respect of breaches that occur beyond our sphere of control.

 

8. YOUR RIGHTS AS A DATA SUBJECT

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email dataprotection@dataprivacytrust.com or use the information supplied in the Contact Us section below.

 

To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

 

The right to be informed
As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.

 

The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:

  1. The purposes of the processing

  2. The categories of personal data concerned

  3. The recipients to whom the personal data has been disclosed

  4. The retention period or envisioned retention period for that personal data

  5. When personal data has been collected from a third party, the source of the personal data

 

In case there are exceptional circumstances when we can refuse to provide the information then we will explain these conditions. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

 

The right to rectification
If you believe that we may hold inaccurate or incomplete personal information about you then you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

 

The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

 

The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the personal data, but we will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:

  1. The accuracy of the personal data is contested.

  2. Processing of the personal data is unlawful.

  3. We no longer need the personal data for processing, but the personal data is required for part of a legal process.

  4. The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

 

The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.

 

The right to object
You have the right to object to our processing of your data where

  • Processing is based on legitimate interest;

  • Processing is for the purpose of direct marketing;

  • Processing is for the purposes of scientific or historic research; or

  • Processing involves automated decision-making and profiling. 

9. CONTACT US

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to: dataprotection@dataprivacytrust.com  

 

Alternatively, you can contact us using the following postal address or telephone numbers:

Data Protection Officer
Data Privacy Trust 
71-75 Shelton Street

London WC2H 9JQ
United Kingdom

 

Telephone (Netherlands): +31 (0)20 808 2031

Our telephone line is open 9:00am – 5:00pm CET, Monday to Friday. A member of our team will answer the call and will ensure that an appropriate person responds as soon as possible.

 

10. COMPLAINTS

If you should wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

 

If you should feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union.

 

For the Netherlands, this is the Autoriteit Persoonsgegevens (APG), which is also our lead supervisory authority. Its contact information can be found at: 

https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us.

 

11. CHANGES TO THIS NOTICE

We may change this Privacy Notice from time to time. If we make changes, we will post the updated version on this Website and update the Privacy Notice’s revision date.

We encourage you to regularly check this Website and the Privacy Notice for updates.

 

@2019 Data Privacy Trust. All rights reserved.

Data Privacy Trust

Email: info@dataprivacytrust.com

Tel.+31-20-8082031

Copyright © 2019 by Data Privacy Trust. All rights reserved.