Privacy Policy Introduction

This Privacy Policy applies to Digital GoToMarket Limited, registered in the United Kingdom with registration number 11800064 and registered offices at 20 High Street, Lewes, East Sussex, England BN7 2LN (hereinafter referred to as "Digital GTM" "us" "we" or "our"), trading as Digital GTM. We are registered with the Information Commissioners Office (ICO) in the UK under registration number ZA796929.

We take your privacy very seriously. We ask that you read this Privacy Policy carefully as, together with our Cookie Policy, it contains important information about what to expect when we collect personal information about you and how we will use your personal data.

Personal data means any information relating to you that allows us to identify or contact you. When you visit our web site, contact us or use our services in any way we may collect and process different types of information about you.

Collection and Use of Personal Data

This policy applies to information we collect about:

visitors to our website
people who use our products and services
people who contact us through our website
people whose personal data is sent to us in any other way
people whose personal data is available through public records and is included in the product(s) that we sell

We do not knowingly collect or process data from anyone under the age of sixteen (16) years old.

When you contact us we will often collect the following personal information from you:

name
email address
telephone number

You may choose to provide personal information to us in writing (through an email, letter, web or mobile form, message, etc.), verbally (in person or via a video or audio stream or recording), visually through gestures or through any other communication method.

We may also collect and process information about you from other sources (such as credit reference agencies), which we will add to the information that we already hold about you in order to help us to provide our services or to comply with legislation. This may happen if, for example, we must undertake reference checks in order to comply with Anti Money Laundering, Anti Bribery, Data Protection or Employment legislation or best practice.

In addition, we may process the following:

location information (including GPS signals sent by a mobile device, location information gathered from social media networks or sensor or IP address data from your device)
information from cookies, web beacons or from the internet, including your IP address, browser type, operating system, domain name, access times, which pages you visit within our website and referring website addresses; you can find out more about how we do that in our Cookies Policy.
if you ask us to connect with other sites (for example if you ask us to connect with your Facebook or Google account), we may receive information that way too
we may record any telephone calls for quality assurance, compliance and training purposes

We may receive data from our customers to enable us to meet their requirements. We ask that they only send us data which is appropriate and to make sure that they have a lawful and secure means of sending that data to us, which allows us to lawfully process that data.

We also process public records data as part of our product offering(s), including personal data relating to company officers, directors and secretaries, shareholders and shareholdings, mortgages and charges, which has been made available pursuant to relevant legislation (such as the UK Companies Act 2006 or the Irish Companies Act 2014). We extract data from publicly available company documents from a number of providers and combine and enrich that data for ongoing use by our customers. The data can include personal details of:

Company Shareholders
Director/Secretary details
Person(s) Entitled to a Charge
Charge Party, Liquidator, Examiner, Receiver and/or Authorised Person(s)
The person filing the document with the registrar

This information is lawfully processed and made available by the relevant registrar under a statutory obligation. Please consult the relevant public body's data privacy statements for further information.

We require all third parties to have appropriate technical and operational measures in place and to comply with UK and EU Data Protection Laws.

How We Use Your Personal Data

General

We process your personal data either where we have your consent to do so, which you may withdraw at any time, or otherwise where this is necessary for:

the performance of our contract with you for the provision of our services or to take preliminary steps at your request
us to fulfil our legal obligations
the purposes of the legitimate interests pursued by us or a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are listed below, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on in pursuing our legitimate interests. You can object to processing with regard to legitimate interests at any time and, if you do so, we will stop processing the affected personal data unless we can show compelling, legitimate grounds that override your rights and interests, or we need the data to establish, exercise or defend legal claims. (See also “Your Rights” below).

Specific

We gather data from a number of authorised data providers and combine and enrich that data to sell on to our customers. All of the data is already within the public domain in line with UK and EU Data Protection Laws.

We gather information from our website (including through links that prompt an email communication) to allow us to answer any enquiries you raise with us. The relevant information is then used by us to communicate with you. If you agree, we may also contact you about other products and services that we think may be of interest to you.

We use the information that you provide to us in contracts and correspondence relating to contracts in order to ensure that we can meet our obligations to you as a current, former or prospective customer, supplier or partner.

We use the information that you provide to us in contracts and correspondence relating to contracts in order to ensure that we can meet our obligations under the law (for example to maintain accurate VAT records) and to our shareholders and stakeholders (who require us to maintain accurate financial records of customer transactions, which may include copies of contracts, orders, invoices and receipts that may in turn contain personal data).

We may also use information and statistics for the purposes of monitoring website use in order to help us to develop our website and our services. We may also provide this information in aggregate form to third parties.

Similarly, when we send emails to you, we may use statistics on the emails we have sent, whether you had read them and other information that we find relevant.

If we sell our business, or part of it, we may share your information with a buyer. They may not be in the same line of business as we are. We will ask any buyer to respect this privacy policy. Likewise, your personal information may be passed on to a successor in interests in the unlikely event of a liquidation, bankruptcy or administration.

We may need to share data for legal or compliance purposes. This may include sharing your information with the Information Commissioner’s Office (ICO). We may also process your data to protect our business or in the interests of security, public interest or law enforcement. We may also need to disclose your data in connection with actual or proposed litigation, or to protect our property, security or people or to enforce our legal rights and interests.

Marketing

If you have given us permission, we may contact you by mail, telephone, SMS, text/picture/video message, social media or email to provide you with information about special features of our website or any other service we think may be of interest to you. If you would rather not receive this information, please simply email unsubscribe@digitialgotomarket.com. If you agree to us providing you with marketing information, you can always opt out at a later date.

Cookies and Other Information-Gathering Technologies

Our website uses cookies. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. These cookies allow us to distinguish you from other users of the website which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

For more information on which cookies we use and how we use them, see our Cookies Policy.

We use a third party service, Wix.com (Wix), to host our website. Wix use cookies to provide us with analytics and statistics regarding the use of our site. An explanation of the cookies used can be found at https://support.wix.com/en/article/cookies-and-your-wix-site.

We have a link to our company LinkedIn page on our website. You can find details of their privacy policies at https://www.linkedin.com/legal/privacy-policy.

Telephones

In common with many other businesses, we may use VOIP technology when you call us or when we call you. You can find out more about VOIP here https://en.wikipedia.org/wiki/Voice_over_IP. Since your call will be relayed via the internet, we can’t control where your data is processed. If you would prefer not to use VOIP you can call any of our team on their mobile phones.

We also regularly hold calls with you through third-part services, such as WhatsApp (https://www.whatsapp.com/), Microsoft Teams (https://products.office.com/en-gb/microsoft-teams/group-chat-software) or Zoom (https://zoom.us/) We can’t guarantee the security of these products and you should visit their websites to see their privacy and security policies.

Security and Retention

We have put in place security procedures and technical and organisational measures designed to help safeguard your personal information. We will use what we consider to be reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet (and VOIP) is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from or to you.

Despite the measures taken by us and any third parties we engage, the internet is not secure and, as a result, others may nevertheless intercept or access private transmissions or data. If you ask us to share data with third party sites, their servers may also not be secure.

We will retain your personal data only as long as is necessary for the purposes set out in this Privacy Policy, or as is required by applicable law, and then we will delete it.

If you are a Digital GTM customer, we retain your data as long as we are providing the services to you. We may retain your data after we cease providing services to you to the extent necessary to comply with our legal and regulatory obligations, for the purpose of fraud monitoring, detection and prevention and to comply with our tax, accounting, and financial reporting obligations. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

Consent

By submitting your personal information, you consent to the use of that information as set out in this policy.

Your Rights

This section outlines your rights as a Data Subject of Digital GTM. However, your rights may be restricted under the following circumstances

Where it's necessary for the prevention, detection, investigation and prosecution of criminal offences
Where it's necessary for the exercise or defence of a legal claim or proceedings.

To the extent permitted by law, you have the right to:

request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it
request access to your data ("Data Subject Access Request"); you will receive a copy of the personal information we hold about you and confirmation that we are processing it legitimately
request correction of the personal information that we hold about you
request erasure of your data where there is no reasonable explanation for us to continue to hold it; you also have the right to ask us to delete or remove your data where you have exercised your right to object to processing
object to profiling that is not to be subject of any automated decision-making by us using your personal information or profiling of you
request the restriction/suspension of processing of your personal information
request a transfer of your data in an electronic and structured form to you or to another party (commonly known as a right to "Data Portability")
withdraw consent, in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your data for a specific purpose; once we have received notification that you to withdraw your consent, we will stop processing your information for the purpose you originally agreed to, unless we have another legitimate basis for doing so in law

You can find more about those rights in the EU by reading the General Data Protection Regulation available at https://eur-lex.europa.eu/eli/reg/2016/679/oj.

If you wish to inquire about those rights or would like to submit a request then please send an email to compliance@digitalgotomarket.com or send a letter to Compliance, Digital GTM, 20 High Street, Lewes, East Sussex, England BN7 2LN.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

this right only applies to your own data
when exercising this right, please be as specific as possible

You have the right to opt-out of receiving communications from us at any time even if you have chosen to opt-in on an earlier occasion. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) – see “Complaints” below.

Digital GTM is committed to respecting all of the above rights in compliance with applicable laws and regulations. If you wish to inquire about any of those rights or have any concern, please contact us immediately using the contact details below. We will respond to any of your inquiries or concerns as soon as possible and in any case within 1 month of receipt of the request as per Article 12(3) of the General Data Protection Regulation (GDPR).

Links to other Sites

Our website contains links to other websites that are clearly identifiable as such, and we are not responsible for the content or the Privacy Policies of these other websites.

Changes to our Privacy Policy

Our Privacy Policy may change from time to time and any changes to the statement will be communicated to you by way of an email or a notice on our website and this page will be updated. By continuing to use our Site after we post any such changes, you accept and agree to this Privacy Policy as modified. This Privacy Policy was last updated on 18 December 2020.

Enquiries, Comments or Complaints

If you wishto make a complaint about how your data is being processed by Digital GTM or how your complaint has been handled, you have the right to lodge a complaint by contacting the Digital GTM Data Protection Officer. (See Contact Details below).

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.

ICO Address:

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Contact Details

If you have any questions, comments and requests about the information set out in this Privacy Policy, please contact:

Data Protection Officer: Adrian Mathias

Digital GTM

20 High Street
Lewes
East Sussex
England BN7 2LN.

Adrian.Mathias@digitalgotomarket.com