Policies

Privacy Notice

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). 

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our: DINN Enterprise CIC a company incorporated in England And Wales under number 11937494 whose registered office is 15, 48 Reminder Lane, London SE10 0NQ

Personal data: Any information relating to an identified or identifiable individual

Special category personal data: Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data (when processed to uniquely identify an individual). Data concerning health, sex life or sexual orientation

Data subject: The individual who the personal data relates to

Personal data we collect about you

The personal data we collect about you depends on the particular services we provide to you, a company you are engaged with or a project you are a part of. We will collect and use the following personal data about you:

  • your name and contact information, including email address and telephone number and company details

  • information to check and verify your identity, eg your date of birth

  • your gender, if you choose to give this to us

  • race or ethnic information, if you choose to give it to us

  • your sexual orientation, if you choose to give it to us

  • location data, if you choose to give this to us

  • your billing information, transaction and payment card information

  • your personal or professional interests

  • your professional online presence, eg LinkedIn profile

  • your responses to surveys, competitions and promotions


We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services for you or your organisation.

How your personal data is collected

We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information: 

  • from publicly accessible sources, eg Companies House or HM Land Registry;

  • directly from a third party, eg:

    • your employer;

    • any organisation you are associated with;

    • any project you are working on or obtaining assistance from;

  • from cookies on our website—for more information on our use of cookies, please see our cookie policy  - www.doitnownow.com/cookie-policy

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason. For example:

  • where you have given consent;

  • to comply with our legal and regulatory obligations;

  • or the performance of a contract with you or to take steps at your request before entering into a contract; or

  • for our legitimate interests or those of a third party.


A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The list below gives some examples of what and why we process your data.

  • What we use your personal data for: Providing services to you 
    Our reasons: To perform our contract with you or to take steps at your request before entering into a contract

  • What we use your personal data for: Providing services to an employer or organisation 
    Our reasons: For our or a third party’s legitimate interest or, where applicable, your consent 

  • What we use your personal data for: Preventing and detecting fraud against you or us
    Our reasons: For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us 

  • What we use your personal data for: To enforce legal rights or defend or undertake legal proceedings 
    Our reasons: Depending on the circumstances:

    • to comply with our legal and regulatory obligations;

    • in other cases, for our legitimate interests, ie to protect our business, interests and rights

  • What we use your personal data for: Operational reasons, such as improving efficiency, training and quality control
    Our reasons: For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best price

  • What we use your personal data for: Ensuring the confidentiality of commercially sensitive information
    Our reasons: Depending on the circumstances:

    • for our legitimate interests, ie to protect trade secrets and other commercially valuable information;

    • to comply with our legal and regulatory obligations 

  • What we use your personal data for: Statistical analysis to help us manage our business, eg in relation to those we are able to provide our services to
    Our reasons: For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price 

  • What we use your personal data for: Marketing our services to:

    • existing and former customers; 

    • third parties who have previously expressed an interest in our services;

    • third parties with whom we have had no previous dealings.

Our reasons: For our legitimate interests, ie to promote our business to existing and former customers

How and why we use your personal data: Special category personal data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:

  • Race and ethnic origin

  • Sexual orientation 

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws. For example:

  • we have your explicit consent;

  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or

  • the processing is necessary to establish, exercise or defend legal claims.

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us at [email protected]; or 

  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

  • companies within the group or who are associated with us

  • third parties we use to help deliver our services to you, eg payment service providers or sub-contractors;

  • other third parties we use to help us run our business, eg marketing agencies or website hosts;

  • third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;

  • Third parties who fund any services provided to you, eg. your employer or an organisation you are affiliated with

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

  • our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;

  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;

  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;

  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

Who we share your personal data with: Further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our group or associated companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

How long your personal data will be keptWe will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we keep basic information for 6 years and we keep special category data for 12 months. Different retention periods apply for different types of personal data. 

Transferring your personal data out of the UK and EEAThe EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

  • our service providers located outside the UK and the EEA; and 
    As we are based in the UK we will also transfer your personal data from the EEA to the UK.
    Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

  • in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: countries in the EEA

  • in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequate decisions in relation to is available here. We rely on adequacy decisions for transfers to the following countries: the EEA

  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or

  • a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) [insert transfer mechanism, eg legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR.

In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) [insert mechanism, eg legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR]. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Your rights

You have the following rights, which you can exercise free of charge;

Access: The right to be provided with a copy of your personal data 
Rectification: The right to require us to correct any mistakes in your personal data 
Erasure (also known as the right to be forgotten): The right to require us to delete your personal data - in certain situations
Restriction of processing: The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data 
Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations 
To object:
The right to object:

  • at any time to your personal data being processed for direct marketing (including profiling);

  • in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
The right to withdraw consents: If you have provided us with consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by email [email protected]. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

  • email, call or write to us—see below: ‘How to contact us’; and

  • provide enough information to identify yourself and any additional identity information we may reasonably request from you;

  • let us know what right you want to exercise and the information to which your request relates.


Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner. The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113

Changes to this privacy policy

This privacy notice was published on 12th November 2021 
We may change this privacy notice from time to time- when we do we will inform you via email. 

How to contact us

Individuals in the UK:
You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details:
[email protected]

 Last review: 04 March 2024