Distributed’s privacy policy

Introduction

Distributed is the data controller of your personal data. Our legal name is DSTBTD Limited and we are a company registered in England and Wales (company number 10552489).

This privacy policy applies to any personal data processed by us, where such data and processing is subject to the General Data Protection Regulation, which applies across the European Economic Area (“EEA”) (and pursuant to the UK Data Protection Act 2018).

This privacy policy provides information on how we look after your personal data when you visit our website at www.distributed.co (the “Site”) or interact with us in any other way, including by email, telephone (if you are based in the EEA and the UK) and via our contact form on the Site.

The Site is not intended for children and we do not knowingly collect data relating to children.

Contact details

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

Email address: callum@distributed.co

Postal address: Distributed Ltd, 1 Mark Square, London, EC2A 4EG, United Kingdom

You have the right to make a complaint at any time to the appropriate supervisory authority for data protection issues, which in the UK is the Information Commissioner's Office (the “ICO”) (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 any changes

We keep our privacy policy under regular review. This version was last updated on 18 June 2019. Historic versions can be obtained by contacting us.

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.

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:

Contact Data includes first name and last name, email address, telephone number, company name, company size and the message information that you submit to us via our contact form on the Site, or via our live chat. If you are our business contact, we may collect and hold similar information about you, as well as the information about the organisation you work for or represent.

Communications Data includes information we exchange and collect during our interactions with you when you call us, email us, submit an enquiry form or participate in our live chat on the Site. For example, the chat operator may need to take further details to help with a query or request, such as an address or telephone number.

Technical Data includes internet protocol (IP) address, 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 the Site.

Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

How is your personal data collected?

The majority of personal data we collect is through direct interactions with you, or when you submit it via the Site.

As you interact with the Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. This includes your web browser, IP address, time zone, and some of the cookies that are installed on your device. 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 employing our cookies. Please see our cookie policy which can be located at further down this page for further details.

Additionally, as you browse the Site, we collect information about the individual web pages that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need 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. For instance, it is in our legitimate interest to process personal data of any person who contacts us with an enquiry, in order to respond to such enquiry, or process data for the purposes connected with the administration of our business, for developing our business strategy and monitoring the performance of our business and our Site;
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we may need to get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We use your personal data to:

  • Respond to your enquiries;
  • Manage our relationship with our clients, suppliers and other business contacts;
  • Send you email alerts that you have subscribed to receive;
  • To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • To deliver relevant website content to you; and
  • To help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize the Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

In addition to the purposes mentioned above, we may also process your personal information to manage our business, including for accounting and auditing purposes, to conduct our regular reporting activities on the performance of our company, including in the context of a business reorganisation or group restructure, to maintain our IT systems, to deal with legal disputes involving you, our agents and/or our suppliers, and to comply with our legal obligations.

We use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page athttp://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeted advertising by: GOOGLE -https://www.google.com/settings/ads/anonymous. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:http://optout.aboutads.info/.

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.

Sharing your personal data

We will never pass your personal data to anyone else, except for any successors in title to our business and associated group companies or to suppliers that may process data on our behalf, for example, the suppliers of our IT systems. We may also need to share your personal information for auditing purposes, with our advisers, if we are under any legal obligations or in connection with any legal proceedings, in order to establish, exercise or defend our legal rights. Additionally, we may share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Other than for the purposes of targeted advertising (as explained in paragraph 7 above), we do not share your personal information with any third parties for marketing purposes. We will not sell your personal data, but we cannot be held responsible for the actions of any third party sites from which you may have linked or been directed to the Site.

International transfers

Please note that your information will be transferred outside of Europe, including to Canada and the United States.

We will only transfer your personal data if we can be satisfied that the recipient implements appropriate safeguards (as required by UK data protection laws) designed to protect your personal information, for example, if they enter into standard contractual clauses approved by the European Commission.

Please contact us if you want further information on the specific mechanism used by us when processing your personal data out of the EEA.

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, we limit access to your personal data to those 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 they are subject to a duty of confidentiality.

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.

In some circumstances, we will 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.