LAST UPDATED: 6th June 2019
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.douglasthornton.co.uk
By providing us with your data, you warrant to us that you are over 18 years of age.
DTC Consulting Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer who is in charge of privacy-related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.
Full name of legal entity: DTC Consulting Ltd
Name or title of Data Protection Officer: Douglas Thornton
Registered 0ffice: 31 High Street, Needham Market, IP6 8AL. United Kingdom
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by updating your details in our preference centre:
How We Collect Your Personal Data
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
We may receive data from third parties, for example analytics providers such as Google, advertising networks such as Facebook, and providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
We may process the following categories of personal data about you:
Communication Data: This includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Blogs and Forums: We may provide an opportunity for you to post information to blogs, forums or other public areas on the Services. By doing so, you consent to the posting of any Personal Information that you provide. You should be aware that such Personal Information can be read, collected, or used by other visitors to these public areas. We have no control over how these visitors use your Personal Information.
Inquiries: If you send us a comment or question or make an inquiry, we will retain the information that you provide to us for the purpose of responding to you, as well as for improving the Services and our customer’s use of our services.
Registration: When you register on the Services, such as to subscribe to a newsletter, request information or access a Product, you will be asked to provide certain Personal Information, which we will use to fulfil your request.
Survey Data: We may ask you to complete surveys or opinion polls from time to time. We only use the information that we collect from surveys in an aggregate manner, not in individually identifiable form. We may use specific comments shared on surveys, in an anonymized way. We may also reach out for further clarification on survey responses and potentially request more and permission to share. But we will never share anything personally identifiable shared on a survey unless given consent.
User Data: This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data: that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Web Logs: We maintain web logs that automatically record basic information about everyone who visits the Services. We use web log information to help us design our website, to identify popular features, to improve our services, and for other managerial and analytic purposes. We may also use web logs to help identify any person who may be misusing the Services. These logs contain:
- The Internet domain from which you access the Services
- Your IP address
- The type of browser and operating system that you use
- The date and time you visited the Services
- The pages that you visited on the Services
- The address of the website you linked from to get to the Services
Marketing Data: This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
Customer Data: This includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Linking from Emails: If you click a link to any of our Sites from an email message from us, we will be able to identify your email address and associate that email address with the manner in which you use the Sites (e.g., which pages you visit or whether you make a purchase).
How We Use Your Information
Here is how we may use your information and data:
- Communicating with You: We may use information that we collect from you for the purpose of communicating with you and responding to your inquiries. Those communications could, for example, take the form of service updates, promotions for products or services that we or one of our marketing partners provide, or newsletters.
- Service Providers: We at times contract with third-party service providers to perform functions for us. These service providers may be given access to the information we collect for the purpose of performing those functions, but they will be contractually bound to maintain the confidentiality of the information and not to use it for any other purpose.
- Business Transfers: If we were to transfer all or substantially all of our assets to another company, one of the assets we would likely include in the transfer is our database of Personal Information.
- Disclosures for Legal Reasons: We will disclose Personal Information when we are required to do so by law, regulation or, for example, in response to a court order. We also may disclose such information in response to a law enforcement agency’s request or when we believe such disclosure is appropriate to protect our legal rights or to safeguard anyone’s property or safety.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
We never knowingly share your personal data with any third-party for their marketing purposes.
You can ask us or third-parties to stop sending you marketing messages at any time by clicking the unsubscribe button at the bottom of our emails or by emailing us at the address provided in the contact information above.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
How We Share Information and Why
We may have to share your personal data with the parties set out below:
- Other companies in our group who provide services to us.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities
- With third-party advertising platforms so that we can create marketing campaign advertising (e.g. using your email address to create a Facebook targeting audience).
- When you participate in interactive area of our website, service, and products, and your information may be displayed to other users: such information may include, your name, photo, the comment, and other information you chose to provide at the time of submission. In the case of Surveys, we will never share personally identifiable information without express consent.
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of others;
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
- With your consent or at your direction.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Where we transfer your data to third-parties outside of the European Economic Area (EEA), we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.
- We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data by; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the (EEA), we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us the address provided in the contact information above using the subject line: “Data Request.” In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
We maintain all Personal Information with physical, electronic, and managerial safeguards to help ensure the security and confidentiality of the data against reasonably foreseeable risks. Security is designed to prevent unauthorized use, access, disclosure, destruction, and changes of data.
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, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Third Party Links
This website 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, we encourage you to read the privacy notice of every website you visit.
Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at the address provided in the contact information above.
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 or refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.