Table of Contents
- Data protection principles
- Your rights
- Data we gather
- How we use your Personal Data
- Who else has access to your details?
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data
Data subject – a natural person whose Personal Data is being Processed
Child – a natural person under 16 years of age
We/us – Dawnthrive Limited
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, and transparent. We always consider your rights before Processing Personal Data. We will provide you with information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is carried out with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
The Data Subject has the following rights:
- Right to information – you have the right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained, and why and by whom it is processed.
- Right to access – you have the right to access the data collected from or about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – you have the right to request rectification or erasure of any Personal Data that is inaccurate or incomplete.
- Right to erasure – in certain circumstances, you can request for your Personal Data to be erased from our records.
- Right to restrict processing – where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled, please contact us.
- Right for the help of supervisory authority – you have the right to use the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right to withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
This might be your name, email address, contact number etc – mainly information that is necessary for us to deliver a product or service to you or to enhance your customer experience with us.
Information automatically collected about you
This includes information such as your IP address that may be automatically stored by cookies and other session tools. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your general activities may be logged.
Publicly available information
We do not gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
- Provide our service to you. For example, this includes registering your account, providing you with other products and/or services that you have requested, communicating with you in relation to those products and services, communicating and interacting with you, and notifying you of changes to any services.
- Enhance your customer experience
- Fulfil an obligation under law or contract
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- To identify you
- To provide you with a service or product
- To communicate either for sales or invoicing
On the grounds of legitimate interest, we Process your Personal Data for the following purposes:
- To administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products and/or services offered/provided
As long as you have not informed us otherwise, we consider offering you products and/or services that are similar or the same as your purchasing history to be our legitimate interest.
With your consent, we Process your Personal Data for the following purposes:
- For any other purposes we have asked your consent for
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered.
To do this, we will ensure that:
- The link between purposes, context and nature of Personal Data is suitable for further Processing
- The further Processing would not harm your interests
- There would be appropriate safeguard for Processing
We will inform you of any further Processing and purposes.
Who else can access your Personal Data?
We do not share your Personal Data with strangers or any third parties.
We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How We Secure Your Data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). Our systems and website are monitored for possible vulnerabilities and attacks.
Even though we try our best, we cannot guarantee the security of information. However, we promise to notify suitable authorities in the case of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and Other Technologies
- Necessary cookies – these cookies are required for you to be able to use some important features on our website. These cookies do not collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
You can remove cookies stored in your computer via your browser settings.
Last updated: 25/06/2018