Last updated: July 12, 2023

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, contact us or purchase our software and services.

It is important that you read this privacy notice together with any other privacy notices, such as our mobile App privacy notice. This privacy notice supplements our other company policies and is not intended to override them.

Our software and service is not intended for children and we do not knowingly collect data relating to children.

We have a dedicated data protection team who can help with any data protection queries or questions regarding this privacy notice. If you wish to contact our data protection team please email: privacy@dhihyperlocal.com

CHANGES TO THE PRIVACY NOTICE

We keep our privacy notice under regular review. This version was last updated on 20 October 2022. You are advised to check our privacy notice regularly for minor changes. Any major changes to our data protection practices will be communicated to you via updates and notifications.

It is also 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. You can do this in your account or by contacting us at the above email address.

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:

Identity Data includes first name and last name.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment details our payment gateway (Stripe) requires via our website.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes 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.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data includes your location, for example by using GPS. For example, if you wish to book a taxi then we will require API for local taxi services local to you.To access your location, we must ask for your permission. A prompt will appear upon opening our App on Apple or Android explaining why we are asking for permission. You can turn Location Services on or off via the location services setting. When location services are off, we cannot use your location in the foreground or background, and this may limit the various services that we can offer you.
Even if you do not use our location-related features, we use IP addresses and other information like phone number area codes to estimate your general location (e.g., city and country). We also use your location information for diagnostics and troubleshooting purposes.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about data subjects nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our software or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

make an enquiry on our website;
create an account on our website/App;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Interactions via our agents and resellers. We may receive personal data about you from various third parties such as our agents and resellers when you express an interest in our services.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Publicly available sources. Where applicable we may collect personal data via publicly available sources.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to (this is known as having a ‘lawful basis’). While there are six lawful bases to choose from, we would commonly only use the following three lawful bases to process your personal data:

Where we need to perform the contract we are about to enter into or have entered into with you. Here the processing of your details is necessary for the performance of a contract to which you are a party.
Secondly, we need to comply with a legal obligation. The processing of your personal data is necessary for compliance with a legal obligation that we are subject to, for example for tax and auditing purposes.
where processing your personal details is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, for example fraud prevention.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing (see below).

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, 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 where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or potential new customer	(a) Identity (b) Contact (c) Location	Performance of a contract with you
To process and deliver your order including: (a) Manage subscriptions, payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Location	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you and provide continuous service, which will include: (a) Notifying you about changes to our terms or privacy notice (b) Product and software updates (c) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Technical (f) Location	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Location	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Location	Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you do not wish to receive any further marketing material from us you can opt-out anytime by selecting the ‘unsubscribe’ link on the marketing link, or by contacting us.

Third-party marketing

We will ensure that we get your consent before we share your personal data with any third party for marketing purposes.

THIRD-PARTY LINKS

Our website or App may include links to third-party websites, plug-ins and applications. 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 via a third party link, we encourage you to read the privacy notice of every website you visit.

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, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie 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 need to disclose your personal data to selected third parties in the following limited circumstances:

With our platform providers who we use to offer our services for example AWS.
With our third-party providers, such as software companies and cloud services who we use to run the website and software such as Stripe our payment gateway. We share your personal data with these companies to help with the proper functioning of the website and software, to analyse and understand your usage of our website and software so that we can make improvements, and to contact you via email.
We may also share your personal data with third-parties who we use for marketing and advertising.
We may share your personal data with our insurance providers or other professional advisers if this is necessary for, for example, obtaining or maintaining insurance coverage, managing risks, obtaining professional advice or exercising or defending legal rights and claims.

We will never sell your personal data. 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 notice.

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

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, e.g:

if our service providers located outside the UK/EEA;
if you are based outside the UK/EEA;

where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:

the UK government or the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’); or
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’) (for UK customers);
Gibraltar; and
Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Tech businesses use and often need third parties to help them host their application, communicate with customers, provide analytics services or power their emails etc. We partner with AWS as we believe are one of the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this privacy notice. Where personal data is transferred to a third party for example in the USA, or other third party outside the UK/EEA, we ensure a similar degree of protection is afforded to it. For example, for EEA users we will use specific contracts approved by the European Commission (Standard Contractual Clauses or SCC’s), and the Information Commissioner's Office for approved data transfer mechanisms for UK users.

DATA SECURITY

We have Implemented appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For example, all our user passwords are encrypted. 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.

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. This could include for example staff training material.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

to access personal data held about you;
to request us to make any changes to your personal data if it is inaccurate or incomplete;
to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is carried out by automated means, and it is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us;
to object to, or restrict, our processing of your personal data in certain circumstances;
if we ever use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
if we use your personal data on the basis of having a legitimate interest (as set out in the table above), you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection;
to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and
Right to 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 privacy@dhihyperlocal.com

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.

COMPLAINTS

You have the right to make a complaint at any time to your local EEA Supervising Authority. If you are based in the UK, then this is the Information Commissioner’s Office (ICO). We would however appreciate the chance to deal with your concerns before you approach the ICO or Supervising Authority so please contact us in the first instance.

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