Private Policy

Last Updated: 23rd September 2021

At Data Practitioners LTD (DPL) 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 and tell you about your privacy rights.

  1. WHO WE ARE AND WHAT WE DO

Purpose of this privacy policy

This privacy policy aims to inform you how we collect and process personal data.  It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

What we do

We provide services to the owners of websites selling goods and services online, also known as e-commerce platforms and described in this policy as “merchants”.  

Our services are intended to personalise your shopping experience and to present items that may of interest to you.  We achieve this by comparing your browsing history with behavioural studies that match your profile.

To achieve this, we use a single unique identifier called the “ShopperID” that is stored in a Cookie placed in your browser and which is used to identify the outcome of your visit or session on the merchant’s website.

Our ShopperID does not retain any personally identifiable information about you.

Our website

We do not collect any personally identifiable information about you when you visit our website, other than information that you choose to submit to us, such as your contact details.

However, we may collect and aggregate information about the use of our site, including which pages are most frequently visited, how many visitors we receive daily, and how long visitors stay on each page.

Our status

We act as the processor of information that is collected by or on behalf of the merchants to whom we provide our services.  Each merchant is required to ask your permission to collect and process any personal data about you and our processing is covered by this consent.

If you have provided us with your personal data, then we will be the controller of that information and we will process it to respond to your request.  

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at [hello@datapractitioners.org].

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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. This version was last updated on [9th July 2021].

Third-party websites

Merchant websites will have their own privacy policies and may also include links to third-party websites, plug-ins and applications.   Merchant websites or the links on their websites may allow the merchant or third parties to collect or share data about you. We do not control these websites and we are not responsible for their privacy policies. We encourage you to read the privacy policy of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

We may collect the following kinds of personal data about you while a merchant is using our services:

  • identity data – the ShopperID is used to identify you, including your name or similar identifiers in the provision of our services to the merchant;
  • contact data, including billing address, delivery address, email address and telephone numbers;
  • transaction data, including details about the products and services you purchase from the merchant.

However, we do not retain this information at the end of the relevant shopping session and the ShopperID is anonymised at the end of the session so that we do not retain personally identifiable information relating to you.  We may use anonymised information product development.

We may collect the following kinds of personal data about you when you visit our website;

  • identity data, including your name, username or similar identifiers;
  • contact data, including postal address, email address and telephone numbers;
  • technical data, including 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; and
  • usage data, including information about how you use our website, products and services.

We 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, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and contact data by filling in our inquiry form or by corresponding with us by phone, email, or otherwise. This includes the personal data you provide when you purchase our products or services.
  • Automated technologies or interactions. As you interact with our website or the website of the merchants to whom we provide our services, we will automatically collect technical data relating to your current session. [Please see our cookie policy for further details.]
  • Third parties or publicly available sources. We may receive personal data about you from various third parties, including unique customer identifiers set by the merchant, and technical data from analytics providers such as Google Analytics, who may be based outside the EU.
  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to.  Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data.

We will use the following types of data:

  • identity, contact, and transaction data to process services on behalf of merchants.  The lawful basis for processing this information is the consent that you have provided to the merchant;
  • identity and contact data that you provide when contacting us via our website to respond to your request or questions.  The lawful basis for processing this information is the performance of a contract with you; and
  • identity, contact, and technical data to administer and improve our website, including troubleshooting, data analysis, testing, and system maintenance.  The lawful basis for processing this information is because it is necessary for our legitimate interests in the administration or our website, to develop our business by improving our products and services and to keep our website updated, including network security, and preventing fraud.

Marketing

We will not use the personal data that you provide directly to us for marketing or provide it to third parties for their marketing.  If in the future, we wish to use your data for marketing activities, we will notify you and obtain your consent.

However, personal data relating to you is collected and provided to merchants as part of the services that we provide to them.  You should read their privacy policy to understand how they will use and share your information.

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 then we will not be able to provide our services to the merchant and we will not collect any personal data relating to you.

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 and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will 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 this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the merchants to whom we provide our services, though we will only do so in respect of the specific merchants that you use.

We require merchants to respect the security of your personal data and to treat it in accordance with the law and the terms of our contract with them.

[do you need to make a statement regarding analytics providers, eg Google Analytics?]

  1. INTERNATIONAL TRANSFERS

We will not transfer your personal data outside the UK.  However, merchants may do so and you should check their privacy policies to understand when this may happen.

Where we have a contract with a merchant, we may be required to transfer personal data outside the UK.  In these circumstances, the transfer will be to a country that provides adequate protection for personal data and/or is subject to the terms of a written contract, such as the Standard Contractual Clauses approved by the EU Commission (see here).

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed.

In addition, the ShopperID provides us with a unique identifier and we do not receive personally identifiable information from merchants.   Consequently, we do not store or retain your personal data when we provide our services to merchants.

  1. DATA RETENTION

We will only retain your personal data collected via our website for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

We will retain your ShopperID for 180 days or longer if we need to confirm payment for our services from a merchant.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These circumstances are:

  • Request access to your personal data (commonly known as a "data subject access request"). 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. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [hello@dpl.ai].

No fee is usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.