1.1 This privacy notice (Privacy Notice) sets out the ways in which we, DADI+ Limited (including t/a Edit) (we, us, our), collect and use your personal data (your personal information) in connection with our business. It also explains what rights you have to access or change your personal data.
1.2 Our website is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 18. If you are under the age of 18, please do not access our website at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 18.
2. About us
2.1 We are a company registered in England under company number 08599900, with our registered address as set out below.
2.2 You can contact us as follows:
FAO: Data Information Manager
Address: 7 Marylebone Lane, London, W1U 1DF
3. Information we may collect about you
3.1 Information that you provide to us.
3.1.1 We will collect any information that you provide to us when you:
(a) make an enquiry, provide feedback or make a complaint over the phone, by email or on our website – whether that is about our services, a Token sale, or any other matter;
(b) submit correspondence to us by post, email or via our website;
(c) update your profile;
(d) subscribe to our newsletter and mailing lists;
(e) fill in a form, conduct a search, respond to surveys, participate in promotions or use any other features of the website;
(f) register to and/or attend our events;
(g) submit a CV or an application to a job vacancy;
(h) attend an interview or assessment; and
(i) ‘follow’, ‘like’, post to or interact with our digital platforms, blogs and social media accounts, including GitHub, Twitter, Telegram, Reddit, Medium and Discord.
3.1.2 The information you provide to us will include (depending on the circumstances):
(a) Identity and contact data:
title, names, addresses, email addresses and phone numbers, and we may also collect proof of identity (for Know Your Customer regulations) if applicable;
(b) Employment and background data:
If you are submitting a job application, you may also provide additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your national security number, your passport or other identity document details and any other such similar information that you may provide to us; and
(c) Survey data:
from time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect any information that you provide as part of that survey.
3.1.3 Information we collect about you:
Information contained in correspondence:
we will collect any information contained in any correspondence between us. For example, if you contact us using a query button on our website or by email or telephone, we may keep a record of that correspondence;
Information transmitted on the website:
we will collect information that you upload or post to your website account and/or any correspondence or interactions that you may have with other website users;
Website usage and technical data:
we will also collect certain information about how you use our website and the device that you use to access our website, even where you have not created an account or logged in. This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the website, date and time of the request, operating system and interface) number of page views, the search queries you make on the website and similar information. This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies please read the COOKIES section below.
3.2 Special Category Information
3.2.1 “Special categories” of particularly sensitive personal information require higher levels of protection. Special categories of data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
3.2.2 We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We process special categories of personal information in the following circumstances:
3.2.3 If you are submitting a job application, you may provide information about:
(a) your race, ethnicity, religious or philosophical beliefs and sexual orientation for the purpose of our diversity and equal opportunities records (on the basis that it is needed for reasons of substantial public interest, for equal opportunities monitoring); and
(b) your health as necessary for the purpose of arranging your interview if you are an applicant (on the basis of compliance with our legal obligations to make reasonable adjustments for your circumstances).
3.3 Information we receive from third parties
3.3.1 In certain circumstances, we will receive information about you from third parties. For example:
(a) Service providers: we may collect personal information from our IT support provider, ZenDesk who as based in the US outside the EU;
(b) Fraud detection agencies: Where permitted or required by law, we may receive information about you, including demographic data or fraud detection information from third party service providers and/or partners, for instance to carry out identity checks through Trulioo, who are based outside the EU in Canada;
(c) Employers, recruitment agencies and referees: if you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application; and
3.3.2 We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
4. How we use information about you and recipients of your information
4.1 We will use your information for the purposes listed below either on the basis of:
4.1.1 performance of your contract with us and the provision of our services to you;
4.1.2 your consent (where we request it);
4.1.3 where we need to comply with a legal or regulatory obligation; or
4.1.4 our legitimate interests or those of a third party (see section 4 below).
4.2 We use your information for the following purposes:
4.2.1 To provide access to our website:
to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
4.2.2 To register your account:
when you sign up to use our website or otherwise register for our Token sale, we will use the details provided on your account registration form (on the basis of performing our contract with you);
4.2.3 To process and facilitate transactions with us:
we will use your information to process transactions and payments, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
4.2.4 Relationship management:
4.2.5 User and customer support:
to provide customer service and support (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), deal with enquiries or complaints about the website and share your information with our website developer, IT support provider, payment services provider [insert details of any other service provider] as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our website users and to comply with our legal obligations);
4.2.6 Prize draws, competitions and surveys:
to enable you to take part in prize draws, competitions and surveys (on the basis of performing our contract with you and our legitimate interest in studying how our website and services are used, to develop them and grow our business);
to process any job applications you submit to us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency (on the basis of our legitimate interest to recruit new employees or contractors);
to keep in contact with you about our news, events, new website features products or services that we believe may interest you, provided that we have the requisite permission to do so, and sharing your information with our email marketing services provide Mailchimp (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (on the basis of our legitimate interests in studying how our website/services are used, to develop them, to grow our business and to inform our marketing strategy);
4.2.10 Social media interactions:
to interact with users on social media platforms including Twitter, Telegram, and Discord for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
to use data analytics to improve our website, products/services, marketing, customer relationships and experiences (on the basis of our legitimate interests in defining types of customers for our website and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy);
4.2.12 Suggestions and recommendations:
to share your information with selected third parties such as suppliers and partners, to enable them to contact you with information about things that may interest you (where we have your consent to do so);
to carry out aggregated and anonymised research about general engagement with our website (on the basis of our legitimate interest in providing the right kinds of products and services to our website users);
4.2.14 Fraud and unlawful activity detection:
to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
4.2.15 Compliance with policies, procedures and laws:
to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
4.2.16 - Direct marketing
We are using legitimate interests as our legal basis for processing and email marketing of personal data. This relates to personal data of data subjects that have been identified as business people with decision making and budgetary responsibilities. The personal data is gathered from publicly available sources and / or directly from the companies concerned. Please see our Legitimate Interests Assessment for more information.
4.3 As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in:
4.3.1 personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
4.3.2 detecting and preventing fraud and operating a safe and lawful business; and
4.3.3 improving security and optimisation of our network, sites and services.
4.4 Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 9 below.
5. Who we might share your information with
5.1 In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
5.1.1 Our service providers:
service providers we work with to deliver our business, who are acting as processors and provide us with:
(a) IT, support, system administration and security services (including ZenDesk) based in the US;
(b) marketing and advertising services (including the Google AdWords service), analytics providers (including Google Analytics), email marketing services (including Mailchimp) all based in the US;
(c) identity verification, fraud prevention and detection services based Canada; and
(d) legal, accountancy, auditing and insurance services and other professional advisers based in the United Kingdom.
5.1.2 Corporate affiliates:
other companies of the DADI group, including but not limited to DADI+ Limited and DADI Tech Limited, based in the UK;
5.1.3 Regulators and governmental bodies:
HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances;
5.1.4 Marketing parties:
any selected third party that you consent to our sharing your information with for marketing purposes; and
5.1.5 Other third parties (including professional advisers):
any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) based in the United Kingdom where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
5.2 We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
6.2 If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org ). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the website.
6.3 The names of the cookies used on our website and the purposes for which these cookies are used are set out in the table below:
|Google analytics||Analysis and tracking of users on the website||Session|
|DADI||Anonymous tracking of users||Session|
7. How we look after your information and how long we keep it for
7.1 We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
7.1.1 ensuring the physical security of our offices, warehouses or other sites;
7.1.2 ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
7.1.3 maintaining a data protection policy for, and delivering data protection training to, our employees; and
7.1.4 limiting access to your personal information to those in our company who need to use it in the course of their work.
7.2 We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it. For example:
7.2.1 we archive our email and paper correspondence regularly and destroy information older than 5 years;
7.2.2 we retain information relating to website user queries for approximately 90 days;
7.2.3 we retain information relating to identity checks our Token sale as long as is necessary to comply with any requirements around “know your customer” regulations where DADI tokens purchased and for those not successful in purchasing DADI tokens we destroy information 30 days after the end of the Token sale; and
7.3 we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently.
8. Help keep your information safe
8.1 You can also play a part in keeping your information safe by:
8.1.1 choosing a strong account password and changing it regularly;
8.1.2 using different passwords for different online accounts;
8.1.3 keeping your login and password confidential and avoiding sharing these details with others;
8.1.4 making sure you log out of the website each time you have finished using it. This is particularly important when using a shared computer;
8.1.5 letting us know if you know or suspect that your account has been compromised, or if someone has accessed your account without your permission;
8.1.6 keeping your devices protected by using the latest version of your operating system and maintaining any necessary anti-virus software;
8.1.7 being vigilant to any fraudulent emails that may appear to be from us. Any emails that we send will come from an email address ending in @dadi.cloud; and
9. International transfers of your information
9.1 Our company is located in the UK.
9.2 Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
9.3 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 transfer solutions are implemented:
(a) 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
(b) where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, European Commission: Model contracts for the transfer of personal data to third countries; or
(c) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
9.4 Countries outside of the EEA to which we may transfer your personal information includes the United States
9.5 Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
10. Your rights to the information we hold about you
10.1 You have certain rights in respect of the information that we hold about you, including:
10.1.1 the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
10.1.2 the right to ask us not to process your personal data for marketing purposes;
10.1.3 the right to request access to the information that we hold about you;
10.1.4 the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
10.1.5 the right to withdraw your consent for our use of your information in reliance of your consent (refer to section 2 above to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;
10.1.6 the right to object to our using your information on the basis of our legitimate interests (refer to section 2 above to see when we are relying on our legitimate interests) (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;
10.1.7 the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;
10.1.8 in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
10.1.9 the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.
10.2 How to exercise your rights
10.2.1 You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for marketing activities also by unsubscribing using the links provided.
10.2.2 Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your user account even when you have requested not to receive marketing communications.
10.3 What we need from you to process your requests
10.3.1 We may need to request specific information from you to help us confirm your identity and to enable you to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.3.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will 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.
11. Sharing data directly with third parties
11.1 You might end up providing personal information directly to third parties as a consequence of your interactions with our website and other services offered by us. For example, you may attend an event hosted by us where you communicate personal information directly with other attendees. We are not responsible for how such third parties use personal data provided by you.
11.2 Please be responsible with personal information of others when using our website and the services available on it. We are not responsible for your misuse of personal information, or for the direct relationship between you and others when takes place outside of the website or our services.
12. THIRD-PARTY LINKS
The 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 notice of every website you visit.
13. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
13.1 We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes by e-mail.
13.2 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 by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice.
This Privacy Notice was updated on 24th May 2018.