Privacy Policy

Last Updated: February 2024

This is the Privacy Policy of DigiBlu UK Limited (“DigiBlu”).  In this document, "We", "Our", or "Us" refer to DigiBlu.  “You/Your/User refers to any person who accesses Our Website www.digiblu.com or interacts with DigiBlu in any way.

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DigiBlu UK Limited is a company registered in the United Kingdom with Registration No.: 12015792; Registered Office: C/O CBHC Limited, Steeple House, Suite 3 First Floor, Church Lane, Chelmsford, CM1 1NH, UK.   

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Introduction

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This privacy notice aims to inform You about how We collect, store and process any information that We collect from You, or that You provide to us.  It covers information that could identify You (“personal information”) and information that could not.  In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.  It tells You about Your privacy rights and how the law protects You.

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We are committed to protecting Your privacy and the confidentiality of Your personal information.  Our policy is not just an exercise in complying with the law, but a continuation of our respect for You and Your personal information.

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We undertake to preserve the confidentiality of all information You provide to Us, and hope that You reciprocate in relation to information that DigiBlu provides to You.

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Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulations (GDPR).

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The law requires Us to tell You about Your rights and Our obligations to You relating to the processing and control of Your personal data.  We do this now, by requesting that You read the information provided at http://www.knowYourprivacyrights.org. 

Except as set out below, We do not share, or sell, or disclose to a third party, any information collected through Our website.

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  1. Data Protection Officer
We have appointed David Williams as our Data Protection and GDPR Officer for DigiBlu and nominated him as the Data Protection Officer (“DPO”) responsible for ensuring that Our policy is followed.

If You have any questions about this Privacy Policy, including any requests to exercise Your legal rights, please contact our DPO, David Williams, at privacy@digiblu.com .
 

  2. Data we process
We may collect, use, store and transfer different kinds of personal data about You.  We have collated these into groups as follows:

Your identity includes information such as first name, last name, title, date of birth, and other identifiers that You may have provided to Us at some time.

Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information You have given to Us for the purpose of communication or meeting.

Technical data includes Your internet protocol (IP) address, 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 Our Website.

Marketing data includes Your preferences in receiving marketing from Us; communication preferences; responses and actions in relation to Your use of Our services.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify You as an individual. Aggregated data may be derived from Your personal data but is not considered personal information in law because it does not reveal Your identity.

For example, we may aggregate profile data to assess interest in a product or service.

However, if we combine or connect aggregated data with Your personal information so that it can identify You in any way, we treat the combined data as personal information and it will be used in accordance with this Privacy Policy.
 

  3. Special personal information
Special personal information is data about Your race or ethnicity, religious or philosophical beliefs, personal preferences, political opinions, trade union membership, information about Your health and genetic and biometric data.

We do not collect any special personal information about You.
 

  4. If You do not provide personal information we need
Where we need to collect personal data by law, or under the terms of a contract We have with You or Your employer, or a third party for whom We are providing services that You have requested  and You fail to provide that data when requested, We may not be able to perform that contract.  In that case, We may have to stop providing a service to You or Your employer or the third party.  If so, We will notify You of this at the time.
 

The bases on which we process information about You
 

The law requires us to determine under which of six defined bases We process different categories of Your personal information, and in certain circumstances to notify You of the basis for each category.

If a basis on which We process Your personal information is no longer relevant, then We shall immediately stop processing Your data in respect of that matter or subject area.

If the basis changes then, if required by law, We shall notify You of the change and of any new basis under which We have determined that We can continue to process Your information.

  5. Information we process because We have a contractual obligation with You

When You or Your employer create an account on our Website, buy a product or service from Us, or otherwise agree to Our terms and conditions, a contract is formed between You and Us.

In order to carry out Our obligations under that contract We must process the information You give Us. Some of this information may be personal information.

We may use it in order to:
 

• verify Your identity for security purposes

• sell products to You

• provide You with Our services

• provide You with suggestions and advice on products, services and how to obtain the most from using Our Website.
   

We process this information on the basis there is a contract between Us, or that You have requested We use the information before We enter into a legal contract.

We shall continue to process this information until the contract between Us ends or is terminated by either party under the terms of the contract.
 

  6. Information We process with Your consent
 

Through certain actions when otherwise there is no contractual relationship between Us, such as when You browse Our Website or ask Us to provide You more information about Our business, including Our products and services, You provide Your consent to Us to process information that may be personal information.
 

Wherever possible, we aim to obtain Your explicit consent to process this information, for example, by asking You to agree to Our use of cookies.
 

If You have given us explicit permission to do so, we may from time to time pass Your name and contact information to third parties with whom we provide products and services where You have expressed an interest in obtaining such products and services. 
 

We continue to process Your information on this basis until You withdraw Your consent, or it can be reasonably assumed that Your consent no longer exists.
 

You may withdraw Your consent at any time by instructing us via our “Unsubscribe” function on Our Website.  However, if You do so, You may not be able to use Our Website or Our services further.

  7. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to You, Your employer,  or a prospective employer, or to Us, of doing so.
 

Where we process Your information on this basis, we do after having given careful consideration to:
 

• whether the same objective could be achieved through other means

• whether processing (or not processing) might cause You harm

• whether You would expect us to process Your data, and whether You would, in the round, consider it reasonable to do so.
   

For example, We may process Your data on this basis for the purposes of:
 

• record-keeping for the proper and necessary administration of DigiBlu

• responding to unsolicited communication from You to which we believe You would expect a response

• protecting and asserting the legal rights of any party

• insuring against or obtaining professional advice that is required to manage DigiBlu’s risks

• protecting Your interests where We believe we have a duty to do so.

  8. Information We process because We have a legal obligation
 

Sometimes, We must process Your information in order to comply with a statutory obligation.

For example, We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include Your personal information.
 

Specific uses of information You provide to Us

  9. Communicating with Us
 

When You contact Us, whether by telephone, through Our Website or by e-mail, We collect the data You have given to Us in order to reply with the information You need.

We record Your request and Our reply in order to increase the efficiency of DigiBlu.

We keep personally identifiable information associated with Your message, such as Your name and email address so as to be able to track Our communications with You to provide a high-quality service.

  10. Complaints
 

Key contacts in the event of You wishing to make a complaint about how Your personal data is being held or processed by DigiBlu:
 

When We receive a complaint, We record all the information You have given to Us.

We use that information to endeavour to resolve Your complaint.

If Your complaint reasonably requires Us to contact some other person, we may decide to give to that other person some of the information contained in Your complaint.  We do this as infrequently as possible, but it is a matter for Our sole discretion as to whether we do give information, and if We do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service We provide, but not in a way that could identify You or any other person.

Please see Table 1 overleaf for contact details of those people or organisation who may be able to help resolve Your Complaint.. 

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Table 1

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If a dispute is not settled, then We hope You will agree to attempt to resolve it by engaging in good faith with Us in a process of mediation.
 

If You are in any way dissatisfied about how We process Your personal information, You have a right to lodge a complaint with the UK Information Commissioner's Office (ICO).  This can be done at https://ico.org.uk/make-a-complaint/ .  We would, however, appreciate the opportunity to talk to You about Your concern before You approach the ICO.
 

  11. Affiliate and business partner information
 

This is information given to Us by You in Your capacity as an affiliate of Us or as a business partner.

It allows Us to recognise visitors that You have referred to Us, and to credit to You commission due for such referrals.  It also includes information that allows Us to transfer commission to You.
 

The information is not used for any other purpose.
 

We undertake to preserve the confidentiality of the information and of the terms of Our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Use of information We collect through automated systems when You visit our Website

  12. Cookies
 

Cookies are small text files that are placed on Your computer's hard drive by Your web browser when You visit any website.  They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide You with a personalised experience and the website owner with statistics about how You use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until You close Your browser.  Others last indefinitely.

Your web browser should allow You to delete any You choose.  It also should allow You to prevent or limit their use.

Our website uses cookies.  They are placed by software that operates on Our servers, and by software operated by third parties whose services We use.

When You first visit Our website, We ask You whether You wish Us to use cookies.  If You choose not to accept them, We shall not use them for Your visit except to record that You have not consented to their use for any other purpose.

If You choose not to use cookies or You prevent their use through Your browser settings, You will not be able to use all the functionality of Our Website.
 

We may use cookies in the following ways:
 

• to track how You use Our Website

• to record whether You have seen specific messages We display on Our Website

• to keep You signed into Our Website

• to record Your answers to surveys and questionnaires on Our Website while You complete them

• to record the conversation thread during a live chat with Our support team.
   

  13. Personal identifiers from Your browsing activity

Requests by Your web browser to Our servers for web pages and other content on Our Website are recorded.
 

We record information such as Your geographical location, Your Internet service provider and Your IP address.  We also record information about the software You are using to browse Our Website, such as the type of computer or device and the screen resolution.
 

We use this information in aggregate to assess the popularity of the webpages on Our Website and how We perform in providing content to You.
 

If combined with other information We know about You from previous visits, the data possibly could be used to identify You personally, even if You are not signed in to Our Website.
 

Disclosure and sharing of Your information
 

  14. Information We obtain from third parties
 

Although We do not disclose Your personal information to any third party (except as set out in this notice), We sometimes receive data that is indirectly made up from Your personal information from third parties whose services We use.
 

No such information is personally identifiable to You.
 

  15. Data may be processed outside the European Union
 

Our Websites are hosted in the UK. 
 

We may also use outsourced services in countries outside the European Union and or outside of the European Economic Area from time to time in other aspects of Our business.

Accordingly, data obtained within the UK or any other country could be processed outside the European Union.
 

We use the following safeguards with respect to data transferred outside the European Union:
 

• The data processing standards that are adopted for Our organisation meet or exceed those stipulated by the European Union (EU) and the European Economic Area (EEA). 

• The processor abides by the same binding corporate rules regarding data processing.
   

Control over Your own information
 

  16. Your duty to inform us of changes
 

It is important that the personal data We hold about You is accurate and current.  Please keep Us informed if Your personal data changes.
 

  17. Access to Your personal information
 

At any time, You may review or update personally identifiable information that We hold about You on Our Website.
 

To obtain a copy of any information that We hold about You please contact Us to make that request.

After receiving the request, We will tell You when We expect to provide You with the information, and whether We require any fee for providing it to You.
 

  18. Removal of Your information
 

If You wish Us to remove personally identifiable information from Our Website, You should contact Us to make Your request.
 

This may limit the service We can provide to You.
 

  19. Verification of Your information
 

When We receive any request to access, edit or delete personal identifiable information We shall first take reasonable steps to verify Your identity before granting You access or otherwise taking any action. This is important to safeguard Your information.
 

Other matters
 

  20. Encryption of data sent between us
 

Where appropriate, We use Secure Sockets Layer (SSL) certificates to verify Our identity to Your browser and to encrypt any data You give Us.
 

Whenever information is transferred between Us, You can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in Your browser’s URL bar or toolbar.
 

  21. Retention period for personal data
 

Except as otherwise mentioned in this Privacy Process, We keep Your personal information only for as long as required by Us:
 

• to provide You with the services You have requested;

• to comply with other law, including for the period demanded by our tax authorities;

• to support a claim or defence in court.    

  22. Compliance with the law
 

Our Privacy Policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business.  If You think it fails to satisfy the law of Your jurisdiction, please do let Us know. 
 

Ultimately it is Your choice as to whether You wish to use Our Website.
 

  23. Review of this privacy policy
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We may update this Privacy Policy from time to time as necessary.  The terms that apply to You are those posted here on Our Website on the day You use Our Website. We advise You to print a copy for Your records.  Please note that this Privacy Policy was last updated on the date indicated in the filename included in the Footer to this document and may be updated at any time without prior notice. 

If You have any question regarding Our Privacy Policy, please email privacy@digiblu.com for the attention of our Data Protection and Privacy Officer, David Williams.