Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. This privacy policy will tell you how we look after your personal data, about your privacy rights and about how the law protects you. This Privacy Policy, along with our Terms of Service governs the relationship we have with you.

We collect your personal data in various ways, including:

Directly from you, for example when you complete and submit an online form;

When we receive an e-mail from you; and

When you visit our website Dispartio.com (regardless of where you visit it from).

Please use the glossary to understand the meaning of some of the terms used in this privacy policy.

Important information and who we are

This privacy policy aims to give you information on how Dispartio Ltd ("we", "us" our") collects and processes your personal data.

Controller

Dispartio Ltd is the controller and responsible for your personal data.

We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. Our registration number is XXXXX.

Data privacy manager

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (as set out in section 10), please contact the data privacy manager using the details set out below.

via Contact Us page

Postal

20-22 Wenlock Road, London, England, N1 7GU

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. 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

This version was adopted to ensure compliance with the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA 2018).

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us and/or our Members (Service Providers).

Our website may include links to third-party websites. 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 policy of every website you visit.

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:

Information you give us

We collect information you provide when you:

Fill in any forms;

Correspond with us;

Open an account or use any of our services;

Take part in online discussions, surveys or promotions;

Speak with a member of our customer support team (either on the phone or through our website)

Speak with a Member (Service Provider) on a phone call facilitated by us; or

We will collect the following information:

Your name, your partner's name, both of your DOB, your address.

Your email address, phone number and details of the device you use (for example, your phone, computer or tablet).

Your username, password and other registration information.

Records of our discussions, if you contact us or we contact you.

Details of the matter(s) you contacted us about.

Your photo (only if you upload one).

Information from your device

Whenever you use our website, we collect the following information:

Technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use and so on.

Information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, length of visits to certain pages, page interaction information and methods used to browse away from the page.

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, Contact and Financial Data by corresponding with us by post, phone, email, messaging service, an online form, via our website or otherwise.

Interactions facilitated by us. We may record phone discussions, messages and any other interactions facilitated through the Dispartio site.

Identity and Contact Data from our Members (Service Providers); and

Identity and Contact Data from publicly available sources such as national registers of companies.

How and why 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; or where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in the unlikely event that we collect and process categories of personal data.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Lawful basis for processing, basis of legitimate interest

To manage our relationship with you (e.g. if you are a client or member (service provider) of Dispartio Ltd)

Identity, Contact, Financial Data, Case Data, Marketing and Communications, Call consultation notes.

Performance of a contract with you, if you are an individual user of our service.

For our legitimate interests (e.g. to effectively manage our relationship with our users, to collect payments). For our legitimate interests (e.g. to provide our users and contacts with useful and relevant information about our services.)

To deliver relevant marketing and other similar materials to you: Identity, Contact, Marketing and Communications

For our legitimate interests (to provide our users and contacts with useful and relevant information about updates, events (eg seminars, networking events etc we may be involved with), and to grow our business.

Marketing

We want to provide you with choices regarding certain personal data uses, particularly around marketing. We rarely send out direct marketing to our contacts.

We may use your Identity and Contact Data to determine what we think may be of interest to you in terms of updates and invitations to events.

You will receive these from us if:

You are or have used our website, as part of our service to you; or

You have opted-in to receive such communications and, in both cases, you have not opted out of receiving that material.

Opting out

You can ask us to stop sending you such material at any time by contacting us. Where you opt out of marketing material, this will not apply to personal data provided to us in the context of the provision of services to you.

Third parties and cookies

We do not share your personal data with third parties for marketing purposes.

Our website uses third party tools and services that allows us to collect information on you, however all information is handled in accordance with the terms laid out in this Privacy Policy.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Disclosures of your personal data

We may have to share your personal data with External Third Parties (as set out in the glossary). We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers outside the European Economic Area (EEA)

If you are resident in the EEA, we may transfer your personal data (primarily your Identity and Contact Details) to a jurisdiction outside the EEA in the following circumstances:

Where we need to communicate with relevant professionals or parties in those jurisdictions (in which case the transfer is necessary for the performance of a contract or our legitimate interests);

Where you ask us to – for example to introduce you to a contact in such a jurisdiction (in which case we have your explicit consent); or where an External Third Party processes your personal data in such jurisdictions (or in the Cloud in circumstances where the location of data centres cannot be controlled by us) as part of providing services to us (in which case it is necessary to enable us to provide our services to you).

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 the 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 necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

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 requirements.

We typically retain certain data about our users (including Contact, Identity, Case Data and Financial Data) for a period of 12 months after they have ceased to be a user.

In some circumstances you can ask us to delete your data: please contact us.

In some circumstances we may 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.

Your legal rights and our obligations

Under certain circumstances, you have rights under the GDPR and the DPA 2018 in relation to your personal data.

To summarise, you have the right to:

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 continuing 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, 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 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; and 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 or on another lawful basis.

If you wish to exercise any of the rights set out above, please contact us.

No fee 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 may 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 30 days. Occasionally it may take us longer 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.

How we use cookies

Some cookies are needed to run the website. For example, when you log in, cookies help to recognise you and keep you logged in as you browse the website. We call these strictly necessary cookies.

We use the following types of cookies:

Necessary cookies

We need to use these cookies to make our website work.

Analytics and advertising cookies

These allow us to recognise and count the number of visitors to our website, and see how visitors browse our website, so we can improve it where necessary. These also allow us to see what pages and links you have visited so we can provide relevant ads and services. We may share this information with other organisations, such as Google, Facebook and LinkedIn, for the same purpose. These cookies are all session cookies, which means that they will stop tracking your activity on the website when you close your website browser.

Can I change my preferences?

You can change your browser settings to refuse the use of all or some cookies. However, if you block all cookies (including necessary cookies), you may not be able to use all or some parts of our website.

Please note, other organisations, such as advertising networks, may also use cookies to track you across different websites. We have no control over these cookies.

Glossary

Lawful basis for processing your personal data

Legitimate Interest

The interest of our business in conducting and managing our business to enable us to provide the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract

Processing your data where it is necessary for the performance of a contract to which you are a party (for example the contract between us and you for the provision of access to our services and members) or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

Processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to (e.g. regulations relating to money laundering)

Third parties we may pass your personal data to

External Third Parties

Service providers acting as processors, including our providers of IT system management and information security; Professional advisers acting as processors or joint controllers including solicitors, lawyers, bankers, brokers, accountants, insurers, various consultants, other intermediaries and business partners; and Tax authorities, regulators and other authorities acting as processors or joint controllers.

Dispartio service providers

Dispartio uses a network of licensed professional Members (Service Providers) to provide services directly to clients. Dispartio Members (Service Providers) engaged through Dispartio are engaged directly by you.