dotdigital Group PLC Navigation Privacy policy We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint. Importantly, (i) where we use the term “client” we are referring to the entity in contract with us to use the dotdigital services; (ii) where we use the term “you” we are referring to visitors to our website www.dotdigital.com or www.dotdigitalgroup.com or clients using the dotdigital services; (iii) where we use the term “end-user” we are referring to individual users of a client, and; where we use the term “contact” we are referring to a person contacted through your use of the dotdigital services, or any individual whose information you provide to us in your use of the dotdigital service. This notice applies in addition to the Shareholder privacy notice. Contents Who we are The personal information we collect and use How we use personal information Transfer of your information out of the UK & the EEA Your GDPR rights Your CCPA rights Keeping your personal information secure How to complain Changes to this privacy notice How to contact us Who we are dotdigital (including dotdigital EMEA Limited (based in the UK), dotdigital B.V. (based in the Netherlands), dotdigital, Inc. (based in the US), dotdigital SG Pte Ltd (based in Singapore) and dotdigital APAC Pty Ltd (based in Australia)) collects, uses and is responsible for certain personal information about you. In the United Kingdom and across Europe, when we do so we are regulated under the Data Protection Act 2018 and General Data Protection Regulation and we are responsible as ‘controller’ of that personal information for the purposes of those laws. In connection with personal data provided through your use of the Engagement Cloud platform and other services that we provide, we are a ‘processor’ for the purposes of the General Data Protection Regulation. As some dotdigital affiliates are based outside of the European Economic Area, and these affiliates have appointed dotdigital B.V. to be our representative within the EEA as necessary. Our representative within the United Kingdom is dotdigital EMEA Limited. Contact details are available later in this Privacy Policy. back to top The personal information we collect and use Information you provide voluntarily In the course of signing up for and using the dotdigital services, consulting with our support teams, sending us an email, connecting another account with the dotdigital services (e.g. using one of our connectors), or communicating with us in any way, you are voluntarily giving us information that we collect. That information may include either your or your end-users’ name, email address, IP address, phone number, postal address, in addition to other details that may include gender, location, occupation or other information of a demographic nature. In supplying this information, you consent to this information being collected, used, disclosed, transferred to dotdigital affiliates and stored by us, as described in our Terms and this Privacy Policy. Information we automatically collect When you browse one of our websites, use the dotdigital platform or interact with an email that we send to you, we may collect information about your web browsing and use of the site or platform. This may include details of your operating system, location, IP address, browser ID, browsing activity, and other information about how you interacted with dotdigital’s services. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. We use this information to help improve the website or monitor the performance of our campaigns. Both dotdigital and our third party partners may use assorted technologies to collect and store information when you use the dotdigital platform or visit our website or interact with an email from us. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyse behaviour, track movements around the website, provide targeted advertisements, and gather demographic information. We may partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods in order to provide you content or advertisements based upon your browsing activities and interests. You are able to control the use of cookies at an individual browser level. Please refer to our Cookie Policy for more information. Information through the Engagement Cloud platform We also obtain personal information from your use of the Engagement Cloud platform. When you upload contact data in the Engagement Cloud platform, we may have access to the data and content of your messages. We receive information about how you use the Engagement Cloud platform and store it in log files or other types of files associated to your account and link it to other information we hold about you. This information might include the date and date of any activity, the browser and IP address as well as actions your end-users have taken within the Engagement Cloud platform. This information helps us to improve the Engagement Cloud platform for you for all users of the platform. Information from elsewhere dotdigital may obtain information about you or end-users from third parties, such as public databases, social media platforms, third party data providers and our marketing partners. Examples of the information we may receive from other sources include device information (e.g. IP address and browser), location, behavioural data and demographic information. We may use this information, alone or in combination with other information described above, to develop or provide more relevant platform features or services (e.g. social media data of end-users allowing you to send more relevant content) or provide more relevant marketing and content to you. Public information & third-party sites dotdigital websites include social media features (either hosted by a third party or hosted directly on our website), which may collect information about your IP address and which page you are visiting. The feature may set a cookie to make sure the feature functions properly. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Your interactions with these platforms are governed by the privacy policies of the companies that provide them. Anything you submit to dotdigital via a social media platform is done so at your own risk without any expectation of privacy. Further, any comments or information you supply on any blog that dotdigital operates can be read, used or collected by anyone. If your information appears in our blog pages and you want it removed, contact our Marketing team: marketing@dotdigital.com. Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. We accept no responsibility or liability for such other websites. You should exercise caution when entering personal information online and look at the privacy statement applicable to the website in question. back to top How we use personal information We use and disclose personal information to: Supply, improve and support the services we provide (this includes using the data you provide to use the Engagement Cloud platform to contact end-users, aggregating information from your use of the platform or our website and sharing this with third parties to improve the services that we provide); Confirm your identity in using the Engagement Cloud platform; Send you information and promotional content (you can amend your marketing preferences in our preference centre or stop receiving messages by unsubscribing); Promote our services to you (e.g. when we collect your personal information on our website, we may contact you further to invite you to use our platform); Perform the obligations of our contract with you or applicable law (e.g. to enforce our terms, communicate with you and provide support); Protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity; Fulfil requests that you may make; Bill you (e.g. to send you invoices, process payment, notices). Note that we use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments; Send notifications about the platform; Bring or defend legal proceedings, meet legal requirements (e.g. complying with court orders, enforcement actions, or other legally valid mechanisms) or respond to lawful requests by public authorities or law enforcement requests; and Provide information to our professional advisors. When using the Engagement Cloud platform, you may import contact or other personal information you have collected into our system. We have no direct relationship with your contacts or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for dotdigital to collect and process information about those individuals. Further to the uses described above, we may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes without restriction. We may transfer personal information of you or your end-users to companies that help us promote, provide, or support our platform or other services that we provide. We may partner with and use various third party software and services, including analytics services, to help understand your usage of our products and services. In particular, we provide a limited amount of your information (such as your email address and sign-up date) to select third party services to collect data for analytics purposes when you visit our website or use our products and services. This allows dotdigital to monitor your use of our website, products and services and tracks our relationship so that we can improve our service to you. We may also use these third party services for communications, either through email, or through messages within our products and services. These third party services may collect publicly available contact and social information related to you, such as your name, email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. Third parties We may disclose personal information to advertising partners, networks and exchanges to display advertising on our website or to manage and serve our advertising on other sites and may share personal information with them for this purpose. All third parties with which we share this information are required to use your Personal Information in a manner that is consistent with this policy. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyse behaviour, track movements around the website, provide targeted advertisements, and gather demographic information. We partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods in order to provide you content or advertisements based upon your browsing activities and interests. Please refer to our Cookie Policy for more information. For details about how we engage third parties when we process your contact or end-user data when you use our platform and services, please see our terms & conditions, the standard form of which can be found at https://www.dotdigital.com/terms-of-service/. How long your personal information will be kept In providing services to you, we will hold personal information for as long as are providing you the services for or in order to comply with our legal obligations, enforce the terms of our contracts, resolve disputes or prevent abuse. Otherwise, we only hold personal information for as long as is necessary. Reasons we can collect and use your personal information In relation to clients, the lawful basis for which we rely on to collect and process your data is typically performance of our contractual obligations. If you are not a dotdigital client, we rely on legitimate interest as the lawful basis on which we collect and use your personal data in relation to contacting you further in certain situations. Our legitimate interests are usually to provide individuals representing a business with details of our products or services through B2B direct marketing . If you are an individual, the basis on which we collect and use your personal data to contact you is often consent. If you have any questions about the lawful basis on which we are processing your personal data, please contact privacy@dotdigital.com. back to top Transfer of your information out of the UK & the EEA Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our service or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Please note that all dotdigital entities operate under Standard Contractual Clauses and applicable measures of the GDPR providing protections and safeguards for cross-border transfers. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. back to top Your GDPR rights For UK & European residents, under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to: fair processing of information and transparency over how we use your use personal information access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address require us to correct any mistakes in your information which we hold require the erasure of personal information concerning you in certain situations receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations object at any time to processing of personal information concerning you for direct marketing object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you object in certain other situations to our continued processing of your personal information otherwise restrict our processing of your personal information in certain circumstances For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please: email, call or write to our Data Protection Officer let us have enough information to identify you, let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and let us know the information to which your request relates, including any account or reference numbers, if you have them If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email. It may take up to 24 hours for this to take place. back to top Your CCPA Rights In addition to the general rights set out under this Privacy Policy, if you are a resident of California, Californian law means you have a number of important rights free of charge. In summary, those include rights to: request information, including a list of the categories of Personal Information (e.g. name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, from businesses with whom you have an established business relationship, & the names and addresses of all such third parties.; portability of such information and receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations require the erasure of personal information concerning you in certain situations; and We do not sell your data to third parties, and the categories of information that we collect are listed above in this policy, but for any queries or other requests please email privacy@dotdigital.com. back to top Keeping your personal information secure We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place 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 back to top How to complain We hope that we can resolve any query or concern you raise about our use of your information. For individuals in the UK & Europe, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. For UK individuals, the supervisory authority in the UK is the Information Commissioner who may be contacted at http://ico.org.uk/concerns or telephone at 0303 123 1113 or other channels as updated at https://ico.org.uk/global/contact-us. For individuals in the Netherlands, the supervisory authority is the Dutch Data Protection Authority who may be contacted at https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us. back to top Changes to this privacy notice This privacy notice was published on 22 December 2020. We may change this privacy notice from time to time, when we do we will inform you via email. back to top How to contact us If you have any questions or concerns about the way in which dotdigital handles any privacy matter or the information we hold about you, please contact us on the details below. For UK Residents For the purposes of UK data protection legislation, please use the following contact details if you wish to contact our Data Protection Officer. Please direct emails to privacy@dotdigital.com, or write to Data Protection Officer, dotdigital EMEA Limited, No.1 London Bridge, London, SE1 9BG. For EEA / Swiss Residents For the purposes of European data protection legislation, please use the following contact details if you wish to contact our Data Protection Officer. Please direct emails to privacy@dotdigital.com, or write to Data Protection Officer, dotdigital B.V., Evert van de Beekstraat 354, 1118 CZ Schiphol, Netherlands. For all other territories If you wish to contact our Data Protection Officer please send an email to privacy@dotdigital.com, write to Data Protection Officer, dotdigital EMEA Limited, No.1 London Bridge, London, SE1 9BG, United Kingdom. back to top Are you interested in investing in dotdigital? 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