Last revised 18/04/2018.
At DestiNet Ltd, we take the privacy of our customers, VRAMP users, employees, free account holders and contacts seriously. We are committed to safeguarding privacy and to complying with the UK Data Protection Act 1998 (Data Protection Registration Number Z8717259), the General Data Protection Regulation 2018 and the Privacy and Electronic Communications Regulations 2011.
For the purpose of the General Data Protection Regulations (the GDPR), the data controller is DestiNet of Bradley House, 7 Park Five Business Centre, Harrier Way, Exeter, Devon EX2 7HU, who can be contacted using the following contact details:
- Tel: 01392 447200
- Email: email@example.com
Our Data Protection Officer
DestiNet Ltd have an appointed Data Protection Officer. Our Customer Service team will be your initial point of contact if you wish to exercise your rights and our DPO can be reached here: firstname.lastname@example.org.
Information we collect from you
We will collect and process the following data about you:
Information you give us.
This is information about you that you give us by filling in forms on our site [vramp.io] or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, complete a callback form and when you report a problem with our site. The information you give us may include your name, company name, postal address, e-mail address, phone number and credit card information.
Information we collect about you.
With regard to each of your visits to our site or use of our service we will automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, Customer Identification Numbers, Usernames, time zone setting, device, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for’ page response times, downloads, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources.
This is information we receive about you if you use any of the other websites we operate or other services we provide. We are working closely with third parties (including, for example, payment and delivery services, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Uses made of the information
Except where we use your personal data for marketing purposes on the basis of prior consent and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our products and services.
We use information held about you in the following ways:
Information you give to us.
We will use this information in accordance with our selected lawful basis of processing:
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by e-mail, telephone or direct mail with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have specifically consented to this;
- To notify you about changes to our service;
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you.
The legitimate interests that we will rely upon to process this information are:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If we are not able to process your personal data whether because you withdraw or limit consent, or for any other reason then we will not be able to achieve the purposes listed above.
Disclosure of your information
You agree that we have the right to share your personal information with:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Selected third parties including:
- Suppliers and sub-contractors for the performance of any contract, or to take steps to enter into a contract;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day. We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If DestiNet Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Where we store your personal data
All information you provide to us to use our Email Marketing Service is stored on UK based secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Automated decision making
We do use automated decision making including profiling. For example; you may receive different marketing messages from us based on your interaction with our automated email marketing campaigns.
Retention of data
Your data is retained and cleansed in accordance with our Data Retention and Cleansing Policy which can be obtained by contacting our DPO via email: email@example.com.
We will only process your data for marketing purposes where you have given express consent to us to do so or where there is a legitimate interest for us to do so. The legitimate interests that we will rely on are as listed above under “Uses made of the Information – Information that we collect about you”. In any event, we will only rely on legitimate interest as a grounds for processing your data where we have completed a Legitimate Interest Assessment and where such assessment supports the use of such data processing.
You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any contract or legal requirement.
At any time, even if you have previously consented, you have the right to ask us not to process your personal data for marketing purposes and/or not to disclose it to third parties for marketing purposes. You can do this by contacting us using the following email address: firstname.lastname@example.org. You can also use this email address to notify us of any preferences you have in relation to the processing of your data for example as to the frequency of communications that you receive from us or the manner or the subject matter of such communications.
Your rights under the GDPR
The GDPR also gives you the following rights:
- To access information held about you;
- To request the deletion or correction of information held about you;
- To object to or restrict the processing of information about you;
- To request that information about you be transferred to another person;
- To complain to the relevant supervisory authority. In the UK this is the Information Commissioner’s Office (ICO) whose contact details can be found here: ICO Website
You can exercise these rights by contacting us using the following email: email@example.com.
Third party sites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you have any complaints in relation to how our business has processed your data or in relation to the exercise of your rights as detailed above you can in the first instance raise your concerns by contacting us at the following email: firstname.lastname@example.org. You may also contact the Information Commissioner’s Office in relation to any such complaints ICO website