DELAWARE DIGITAL LLP PRIVACY NOTICE

1. INTRODUCTION

This Privacy Policy contains important information about who we are, how and why we collect, store, use and share your personal information and your rights in relation to your personal information. Please read it carefully. The types of personal information that we collect and our uses of that personal information will depend on your relationship with us. 

Delaware Digital LLP is a UK Limited Liability Partnership whose registered office is at Parkhill Business Centre, Walton Road, Wetherby, West Yorkshire LS22 5DZ (Delaware). To enable us to provide our services, to provide information about the services we offer and to deal with any queries or complaints that might arise, we need to collect and use certain personal information about you. For the purposes of data protection legislation, this means we are a data controller and we are responsible for complying with data protection legislation and keeping your personal information safe and secure.  

In this Privacy Policy, we use the terms “we”, “us” and “our” to refer to Delaware.  Our contact details are set out towards the end of this Privacy Policy and you can find out further information about us at https://www.delaware.co.uk/en-GB/About-us.

The personal information we collect about you and our uses of that personal information will depend on your relationship with us. In order to make this privacy policy as user friendly as possible, we have split parts of it into the following different sections:

• current and prospective customers
• business partners and suppliers
• website users
• event attendees
• information purchased from third parties (Marketing Leads).

Please refer to the sections that apply to you. 

If you provide personal information to us about other individuals (for example your employees) we will also be data controller of, and responsible for, their personal information. Please refer them to this Privacy Policy so that they understand how we will use their personal information.

2. COLLECTION, USE AND SHARING OF YOUR PERSONAL INFORMATION

2.1 Current and Prospective Customers

Collection of your personal information

If you are a customer or a prospective customer, the personal information we collect will include:

• your name, your address and contact details (including telephone number and email address)
• your job title and details of the company you work for
• information about any services we provide to you
• details of any feedback you give us
• any additional personal information that you give us or we obtain in connection with our provision of services, you attending our offices or any meetings or events or our business relationship.

We collect most of your personal information directly from you, however we may also collect it from:

• publicly accessible sources including Companies House and LinkedIn
• third parties such as customer due diligence providers, sanctions screening providers and commercial credit reference agencies 
• cookies and tracking technologies on our website, within our emails or other communication channels. You can access a copy of our cookie policy at https://www.delaware.co.uk/en-GB/About-Us/Cookie-policy. 

Use of your personal information

We may use your personal information for a number of different purposes.  In each case, we must have a legal ground to do so. We will rely on the following legal grounds when we process your personal information:

• we need to use your personal information to enter into a contract with you or to perform a contract that we have in place with you (e.g. we need to use your personal information to deliver services to you)
• we have a legitimate interest in using your personal information (e.g. to keep business and accounting records, to manage our business operations, to develop and improve our services) - when using your personal information for these purposes, we will assess our need to use your personal information against your rights to privacy to ensure that we are protecting your rights and interests
• we have a legal obligation to use your personal information (e.g. prevention of fraud, anti-bribery due diligence, economic sanctions background check)
• we have your consent.

The following table sets out the legal grounds we rely on for each processing activity:

Sharing of your personal information

We may share your personal information with third parties in certain circumstances. These include:

• other companies in the Delaware group, to help us provide and improve our services
• our business partners 
• our service providers (e.g. companies providing IT systems, software and support (including cloud service providers), document and information storage provisions, business support services such as marketing agencies, document processing, confidential waste disposal, couriers)
• our professional advisors (e.g. legal counsel, auditors, tax advisors) and professional indemnity insurers (in the event of a claim or potential claim)
• law enforcement agencies, courts, regulators and governmental authorities where we believe this is necessary to comply with our legal or regulatory obligations, to enforce any agreements between you and us, to resolve any dispute or otherwise to protect our rights and the rights of any third party
• selected third parties in connection with any sale, transfer or disposal of our business.

We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information. 

2.2 Business partners and contacts at suppliers

Collection of your personal information

If you are our business partner or a contact at one of our suppliers or service providers, we will collect:

• your name, your address and contact details (including telephone number and email address)
• your job title and details of the company you work for
• any additional personal information that you give us or we obtain in connection with the provision and procurement of your services.

We collect most of your personal information directly from you, however we may also collect it from publicly accessible sources including LinkedIn.

Use of your personal information

We may use your personal information for a number of different purposes.  In each case, we must have a legal ground to do so. We will rely on the following legal grounds, when we process your personal information:

• we need to use your personal information to enter into or perform the contract that we hold with you (e.g. we need to use your personal information to fulfil our contractual obligations and/or procure your services)
• we have a legitimate interest in using your personal information (e.g. to keep business records of all third parties we engage, to review performance of business partners and suppliers and to manage our business operations) - when using your personal information for these purposes, we will assess our need to use your personal information against your rights to privacy to ensure that we are protecting your rights and interests.

The following table sets out the legal grounds we rely on for each processing activity:

Sharing of your personal information

We may share your personal information with third parties in certain circumstances. These include:

• if you are a business partner of or supplier to other Delaware group companies as well as to Delaware, those other Delaware group companies for the purposes of monitoring, enhancing and streamlining the arrangements in place between you and us
• our service providers (e.g. companies providing IT systems, software and support, document and information storage provisions, business support services such as marketing agencies, document processing, confidential waste disposal, couriers)
• our professional advisors (e.g. legal counsel, auditors, tax advisors) and professional indemnity insurers (in the event of a claim or potential claim)
• law enforcement agencies, courts, regulators and governmental authorities where we believe this is necessary to comply with our legal or regulatory obligations, to enforce any agreements between you and us, to resolve any dispute or otherwise to protect our rights and the rights of any third party
• selected third parties in connection with any sale, transfer or disposal of our business

We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.  

2.3 Website users

Collection of your personal information

If you use our website, then depending on the activities you carry out on our website, the personal information we may collect will include:

• details of your IP address
• details of the pages you visit 
• other personal information which is accessible via the device you use to access our website
• details you provide via our “contact us” facility, including your name, your email address, your job title and phone number telephone number and email address

We collect most of your personal information directly from  our website, however we may also collect it from cookies and tracking technologies on our website. You can access a copy of our cookie policy here: https://www.delaware.co.uk/en-GB/About-Us/Cookie-policy.

Use of your personal information 

We may use your personal information for a number of different purposes.  In each case, we must have a legal ground to do so. We will rely on the following legal grounds, when we process your personal information:

• we have a legitimate interest in using your personal information (e.g. to respond to your enquiry, to monitor usage of our website and to manage our business operations) - when using your personal information for these purposes, we will assess our need to use your personal information against your rights to privacy to ensure that we are protecting your rights and interests;
• we have your consent (e.g. to send you marketing communications).

The following table sets out the legal grounds we rely on for each processing activity:

Sharing of your personal information

We may share your personal information with third parties in certain circumstances. These include:

• other companies in the Delaware group, in order to help us answer your query
• our business partners 
• our service providers (e.g. companies providing IT systems, website providers and software and support)
• web analytics providers

We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information. 

2.4 Event attendees

Collection of your personal information

If you register to attend or attend an event which we host or sponsor, the personal information we may collect will include:

• your name, your address and contact details (including telephone number and email address)
• your job title and details of the company you work for

Use of your personal information

We will use your information to interact with you about the event register for and/or attend and to send you information about our services, Delaware news, invitations to events and other communications which we think you may be interested in. The legal ground on which we will rely when doing this is that we have a legitimate interest in generating new business with you.  

Sharing of your personal information

We may share your personal information with our service providers (e.g. companies providing marketing services, IT systems, software and support).  We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.  

2.5 Marketing Leads

From time to time we purchase personal information from a third party for inclusion in our future marketing campaigns. 

We currently receive personal information for our marketing campaigns from Corpdata (www.corpdata.co.uk).  Please see their privacy policy for details of how your personal information is used and shared by them. This can be found at: https://www.corpdata.co.uk/about-us-privacy-statement.

Collection of your personal information

The personal information we collect will include:

• your name, your address and contact details (including telephone number and email address)
• your job title and details of the company you work for

Use of your personal information

We will use your information to send you information about our services, Delaware news, invitations to events and other communications which we think you may be interested in. The legal ground on which we will rely when doing this is that we have a legitimate interest in generating new business with you.  

Sharing of your personal information

We may share your personal information with our service providers (e.g. companies providing marketing services, IT systems, software and support).  We carry out due diligence on all third party service providers with whom we share your personal information and put in place appropriate contractual protections to protect the confidentiality and use of your personal information.  

3. TRANSFERRING YOUR PERSONAL INFORMATION OUTSIDE THE EEA

We may share your personal information outside the European Economic Area (EEA) in certain circumstances, including:

• with other companies in the Delaware group
• with your and our service providers located outside the EEA
• where there is an international dimension to the services we are providing to you
• if you are based outside the EEA

Where we share your personal information with a service provider outside of the EEA, we will take appropriate safeguarding measures to ensure that your personal information is secure and protected and we will comply with data protection laws by using one of the following methods:

• putting in place appropriate contractual protections – we will use “Standard Contractual Clauses” which have been approved by European data protection authorities. You can find out more about the Standard Contractual Clauses here
• transferring personal information only to countries which have been deemed by European data protection authorities to have adequate levels of data protection. You can find out more about this here
• transferring personal information only to those companies in the United States which are certified under the “Privacy Shield”. The Privacy Shield is a scheme under which US companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield here.

4. KEEPING YOUR PERSONAL INFORMATION SECURE

We are committed to keeping your personal information secure. We have implemented appropriate information security procedures, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.

We limit access to your personal information to those who have a genuine business need to know it. Our partners, employees, consultants and third party processors will only process your personal information in an authorised manner and are subject to a duty of confidentiality.  

5. MARKETING ACTIVITIES 

From time to time we may send you information about our services, Delaware news, invitations to events and other communications which we think you may be interested in or which you have provided your consent to receive. 

You can opt-out of marketing communications at any time by clicking the “unsubscribe” link at the bottom of any marketing email communication or by contacting us at info@delaware.co.uk.

6. RETAINING YOUR PERSONAL INFORMATION

6.1 Customers, business partners and contacts at suppliers

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of 7 years from the date of our last interaction with you or longer if we are required to do so by law or regulation or by our insurers. We will delete your personal information when we are no longer required to retain it. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.

6.2 Prospective customers, event attendees and website users

We will keep your personal information for a period of 3 years from the date of our last interaction with you or longer if we are required to do so by law or regulation or by our insurers. We will delete your personal information when we are no longer required to retain it. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.

6.3 Marketing Leads

We will keep your personal information for as long as we are permitted do so by the third party from whom we purchase it (typically this will be for a period of 1 year) or longer if we are required to do so by law or regulation or by our insurers. We will delete your personal information when we are no longer required to retain it. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.

7. AUTOMATED DECISION MAKING AND PROFILING

We do not carry out any profiling or automated decision making.

8. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

You have a number of important legal rights in respect of the personal information that we hold about you and you can exercise any of them at any time by using the contact details below. 

Please note that although we take your rights very seriously, there may be some circumstances where we cannot comply with your request because the right does not apply in those particular circumstances or because complying with it would mean that we are unable to comply with our own legal or regulatory obligations. However we will consider each request carefully and, if we cannot comply with it, we will let you know why not.

• The right to access your personal information – you are entitled to a copy of the personal information that we hold about you and certain information about how we use it. We will usually respond to your subject access request in writing unless you request otherwise. Where your request is made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible
• The right to require us to correct any mistakes in your personal information – if you believe that the personal information we hold about you is inaccurate or there are any discrepancies or gaps, please let us know and we can update it or amend it to ensure that the personal information we hold about you is accurate and where necessary up to date
• The right to require us to delete your personal information in certain situations for example where we no longer need your personal information for the original purpose which it was collected. When assessing whether we can comply with your request, we will need to take other factors into consideration such as our legal and regulatory obligations to keep your personal information
• The right to receive personal information that you have provided to us in a usable electronic format and/or request that we transmit that personal information to a third party in certain situations
• The right to restrict our use or disclosure of your personal information in certain situations for example where you think that the personal information we hold about you is inaccurate or where you think that we no longer need to use your personal information
• The right to object to our use of your personal information for direct marketing purposes - you can opt-out of marketing communications at any time by contacting us using the details set out below or by clicking the “unsubscribe” link at the bottom of any marketing email communication. Please note that where you exercise this right, we will send you communications which are related to the services we provide to you
• The right to object to processing based on our justifiable purpose – where we have indicated that we rely on a justifiable purpose to process your personal information, you can object to such processing unless our purpose outweighs any prejudice to your right to privacy
• The right to withdraw your consent to our processing of your personal information – where we have indicated that we rely on your consent, you have the right to withdraw such consent
• The right to reconsider a decision taken by automated means – however, we do not currently undertake any automated decision making
• The right to complain about our processing of your personal information to the ICO (UK Information Commissioner’s Office) if you believe that we have breached data protection laws. 

For further information on these rights, including the circumstances in which they apply, see the ICO Guidance on individuals’ rights under the GDPR at https://ico.org.uk/. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.  

If you would like to exercise any of these rights please email, call or write to us using the details set out in the How to contact us section below.  We will contact you if we need additional information from you in order to consider your requests.

9. HOW TO CONTACT US

If you have any queries or concerns about this privacy notice or our use of your personal data or wish to make a complaint please contact us in one of the following ways:

email: info@delaware.co.uk

post: Delaware Digital LLP
Parkhill Business Centre
Walton Road
Wetherby
West Yorkshire
LS22 5DZ
tel: 01937 547 093 and ask to speak to Anna Cressall

If you have a complaint which we are unable to resolve you may lodge your complaint with the UK Information Commissioner:  https://ico.org.uk/concerns/ or tel: 0303 123 1113.