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Privacy Policy

LAST UPDATED: 30th May 2023

  1. INTRODUCTION

Welcome to Darabase Limited (we, us, our or Darabase), the owner and operator of the Darabase websites (including Darabase.com and Darabase.io), are committed to protecting and respecting your privacy.

This Privacy Policy explains:

  • why and how we may use the personal information that we have obtained from interactions you (or others) may have with us as a business, including when you visit and use our website currently located at www.darabase.com, (Site), and/or the platform from which we operate from the Site (each, a Platform) or when you contact us;
  • with whom we share your personal information; and
  • the rights you have in connection with the information we use.


Please read the following carefully.

Darabase Limited is the controller of your personal information. This means that Darabase Limited decides why and how your personal information is processed. Please see the section at the end of this Privacy Policy for our contact and legal information.

This Privacy Policy may change from time to time so please check this Privacy Policy occasionally to ensure that you are happy with any changes. For more information on changes to our Privacy Policy, please see paragraph 11 (Changes to this Privacy Policy).

 

This Privacy Policy was last updated on the date set out at the top of this Privacy Policy.

  1. PERSONAL INFORMATION WE COLLECT ABOUT YOU

We collect personal information from you in the following ways:

Personal information you give to us:

This is personal information you give to us when you:

  • make any payments to us;
  • interact with us on social media; or
  • contact us or correspond with us via the Platform, a form available on the Sites, by email, or in another way.

This personal information is provided by you voluntarily and includes personal information you submit on the Platform and Sites) or on social media. We may also ask you for information when you report a problem with the Platform or Sites.

When you use the Platform, the information we may collect includes: 

  • Your personal/business email address;
  • Your personal/business phone number;
  • Your home/company/billing address;
  • Business information, such as company name, company number or VAT registration number if you are acting on behalf of a business or as a sole trader;
  • Your personal/business bank details;
  • Any other information included in any correspondence with us or that you upload to a Platform.

If we do not receive the information listed above, you may be unable to use or interact with certain parts of the Platform or Site or communicate with us effectively. 

Personal information we collect about you:

We may automatically collect personal information about your use of the Platform, such as the number and duration of your visits to the Platform, your interactions with the Platform, your user behaviour and details of which particular pages you have visited. We will generally aim to aggregate, pseudonymise or anonymise this information so that it is not attributable to you. 

We also automatically collect technical information, including data collected by the hosting server for statistical purposes, the Internet Protocol (IP) address used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform as well as cookie information, including tracking pixel and beacon identification information (Technical Information). Please see our Cookies Policy for further information.

We will also hold a record of the transactions between us made via the Platform.

  1. HOW AND WHY WE USE YOUR PERSONAL INFORMATION

In relation to your personal information that we process as a controller, data protection law requires us to have a valid reason to process it for each of the different purposes for which we use that information. The law refers to each reason as a ‘lawful basis’. The purposes for which we use your personal information and the lawful basis on which we rely to process it for each purpose is as follows:

Where you have provided CONSENT

We may use and process your personal information where you have consented for us to do so for the following purposes:

  • contact you via email with marketing information about us, our events and products and services (including the Platform) and about our third party partners; and
  • when you refresh your marketing preferences when responding to a request from us to do so.


You may withdraw your consent for us to use your information in any of these ways at any time. Please see paragraph 10. (Your Rights) for further details.


Where necessary to comply with our LEGAL OBLIGATIONS

We will use your personal information to comply with our legal obligations:

  • to keep a record relating to the exercise of any of your rights relating to our processing of your personal information;
  • to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
  • to anonymise or delete your personal information when it is no longer required for the purposes described in this Privacy Policy;
  • to comply with court orders or other notices where failure to do so would result in us breaking the law; and
  • to handle and resolve any complaints we receive relating to our processing of your personal information as described in this Privacy Policy.

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

Processing necessary for us to promote our business and measure the reach and effectiveness of our campaigns

  • to contact you with marketing information by post or by phone (if you are not registered with the Telephone Preference Service);
  • for analysis and insight conducted to inform our marketing and business strategies, and to enhance your user experience;
  • to identify and record when you have received, opened, forwarded or engaged with the Platform or our electronic communications (please see our Cookies Policy for more information);

Processing necessary for us to respond to changing market conditions and the needs of our users

  • to analyse, evaluate and improve the Platform so that your visit and use of the Platform, the Site and our social media pages are more useful and enjoyable (we will generally use aggregated information for this purpose, which does not directly identify individual users);
  • to undertake market analysis and research (including contacting you with surveys) so that we can better understand your use of the Platform or the Sites or your opinion of us or our business;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

  • to verify your identity;
  • to administer the Platform, the Sites and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
  • for the prevention of fraud and other criminal activities;
  • for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access and for systems administration purposes, including systems migration and testing;
  • for the purposes of corporate restructure or reorganisation or sale of our business or assets;
  • for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
  • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
  • to inform you of updates to our terms and conditions and policies; and
  • for other general administration including managing any reports you make, your queries, complaints, or claims, and to send service messages to you.
  1. DISCLOSURE OF YOUR PERSONAL INFORMATION BY US

Suppliers

We may disclose your information to our third party service providers, agents and subcontractors (Suppliers) for the purposes set out above. Our Suppliers can be categorised as follows:

Recipient / relationship to us Industry sector (& sub-sector)
Advertising, PR, digital and creative agencies Media (Advertising & PR)
Cloud software system providers, including database, email distribution and document management providers e.g. Google IT (Cloud Services)
Customer service/help desk platform providers IT (Customer Services)
Facilities and technology service providers including scanning and data destruction providers IT (Data Management)
Insurers and insurance brokers Insurance (Underwriting & Broking)
Legal, security and other professional advisers and consultants e.g. RPC, Shoosmiths Professional Services (Legal & Accounting)
Map services e.g. Google Maps and Mapbox openstreetmap Media (Mapping)
Market and customer research providers Media (Market Research)
Social media platforms e.g. Facebook, LinkedIn and Twitter Media (Social Media)
Website and data analytics platform providers e.g. Google IT (Data Analytics)
Website and app developers IT (Software Development)
Website hosting services providers and infrastructure providers (including storage, database and monitoring services) e.g. AWS  IT (Hosting & Infrastructure)

When sending your information to Suppliers, we only disclose to them personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions where they process it as our processor.  

Other third parties

When we share your personal information with any third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

We may disclose your personal information to other third parties as follows:

  • any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
  • if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies.
  1. WHERE WE STORE YOUR PERSONAL INFORMATION

Due to the international nature of our business and the services we provided, your information may be transferred to countries outside Switzerland, the UK and the European Economic Area (EEA).   Those countries may not have similar data protection laws to the United Kingdom and so may not protect the use of your personal information to the same standard.

Where we transfer your information outside of Switzerland, the UK and EEA, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy. These steps include imposing contractual obligations on the recipient of your personal information using standard clauses issued by the Federal Data Protection and Information Commissioner (FDPIC) (or other relevant body) and relying on decisions issued by the European Commission (or other relevant person) declaring that a country is adequately protective of personal information to a degree that allows us to safely transfer your personal information to that country.  

Please contact us using the details at the end of this Privacy Policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

If you use our services whilst you are outside the UK and EEA, your information may be transferred outside those territories in order to receive those services.

  1. THE PERIOD FOR WHICH WE KEEP YOUR PERSONAL INFORMATION

If we collect your personal information, the length of time for which we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will generally retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under paragraph 3. (How and why we use your personal information) above. The only exceptions to this are where:

  • the law requires us to hold your personal information for a longer period, or delete it sooner;
  • you exercise your right to have the information erased (where it applies) and we  are not permitted or required to retain such information under the law (see paragraph 10. (Your Rights) below);
  • you exercise your right to require us to retain your personal information for a period longer than our stated retention period (where it applies) (see paragraph 10. (Your Rights) below); or
  1. SECURITY AND LINKS TO OTHER SITES

We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you access to certain parts of the Platform and Site, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.

If you are using a computer or terminal in a public location, we recommend that you always log out and close the website browser when you complete an online session for your security. We will never ask you to confirm any account or credit card details via email. If you receive an email claiming to be from darabase.com asking you to do so, please ignore it and do not respond.

The Platform, the Site and social media pages may contain links to other websites run by other organisations which we do not control. This Privacy Policy does not apply to those other websites‚ so we encourage you to read their privacy policies. We are not responsible for the privacy policies and practices of other websites (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. 

In addition, if you linked to the Platform from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

  1. COOKIES

‘Cookies’ are small pieces of information sent to your computer or device and stored on its hard drive to allow our Sites to recognise you when you visit.

If you are using the Sites, it is possible to switch off non-essential cookies by setting your browser preferences. For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy.

  1. AUTOMATED DECISION MAKING

We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this Privacy Policy and inform you if this position changes.

  1. YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 calendar month from either:

  • the date that we have confirmed your identity; or
  • where we do not need to do this because we already have this information, from the date we received your request.

You have the following rights, some of which may only apply in certain circumstances:

Your Rights Further Information
To have your information corrected if it is inaccurate and to have incomplete personal information completed If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this Privacy Policy.
To object to processing of your personal information Where we rely on our legitimate interests as the lawful basis for processing your personal information for particular purposes, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this Privacy Policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
To withdraw your consent to processing your personal information Where we rely on your consent as the lawful basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
To restrict processing of your personal information

You may ask us to restrict the processing of your personal information in the following situations:

  • where you believe it is unlawful for us to do so,
  • you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.

 

In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
To have your personal information erased

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this Privacy Policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

 

Please note that information written to the blockchain cannot, due to its decentralised nature, be erased. If you ask us to delete information held on the blockchain, we will remove links between the data we hold and the corresponding data on the blockchain except to the extent that such links are necessary for the Retained Uses.
To request access to your personal information and how we process it You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this Privacy Policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
To electronically move, copy or destroy your personal information in a standard, machine-readable form

Where we rely on your consent as the lawful basis for processing your personal information or need to process it in connection with a contract in place directly with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Rights relating to automated decision making, including profiling You may also contest a decision made about you, and that has a significant effect on you, based purely on automated processing by contacting us using the information at the bottom of this Privacy Policy. However, as stated above, we do not currently make such decisions and unless we do, this right does not apply. 
To complain to a data protection regulator You have the right to complain to a data protection regulator (which in the UK is the Information Commissioner’s Office (ICO)) if you are concerned about the way we have processed your personal information. Contact details for the ICO, can be found on the ICO’s website at: https://ico.org.uk/.

 

  1. CHANGES TO THIS PRIVACY POLICY

We may review this Privacy Policy from time to time and any changes will be notified to you by posting an updated version on the Platform and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Platform, whichever is the earlier. We recommend you regularly check for changes and review this Privacy Policy whenever you visit or use the Platform. 

  1. CONTACT US

Please direct any queries about this Privacy Policy or about the way we process your personal information to our Privacy Manager using our contact details below.

If you wish to write to us, please write to Darabase Limited, Bourne House, Queen Street, Gomshall, GU5 9LY, United Kingdom.

Our email address for data protection queries is support@darabase.com alternatively you can contact us via the Platform.

Please see our Terms of Use for legal information relating to Darabase Limited.