This Policy applies as between you, the User of this Website and DisplayNote Technologies Limited the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Data” means collectively all information that you submit to DisplayNote Technologies Limited via the Website. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998;
“Cookie” means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in Clause 12;
“UK and EU Cookie Law” means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive)
(Amendment) Regulations 2011;
“User” means any third party that accesses the Website and is not employed by DisplayNote Technologies Limited and acting in the course of their employment; and
“Website” means the website that you are currently using (displaynote.com) and any sub-domains of this site unless expressly excluded by their own terms and conditions.
2. Scope of this Policy
This Policy applies only to the actions of DisplayNote Technologies Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
3. Data Collected
Without limitation, any of the following Data may be collected by this Website from time to time:
3.2 date of birth;
3.4 job title;
3.6 contact information such as email addresses and telephone numbers
3.7 demographic information such as postcode, preferences and interests;
3.8 financial information such as credit / debit card numbers;
3.9 IP address (automatically collected);
3.10 web browser type and version (automatically collected);
3.11 operating system (automatically collected);
3.12 a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected); and
4. Our Use of Data
4.1 Any personal Data you submit will be retained by DisplayNote Technologies Limited for 5 years.
4.2 Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties.
4.3 All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. Fore more details on security see Clause 11 below.
4.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
4.4.1 internal record keeping;
4.4.2 improvement of our products / services;
4.4.3 transmission by email of promotional materials that may be of interest to you;
4.4.4 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website.
5. Third Party Websites and Services
5.1 DisplayNote Technologies Limited may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment processing, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services [do not]have access to certain personal Data provided by Users of this Website.
5.2 Any Data used by such parties is used only to the extent required by them to perform the services that DisplayNote Technologies Limited requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.
6. Links to Other Websites
7. Changes of Business Ownership and Control
7.1 DisplayNote Technologies Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of DisplayNote Technologies Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
7.2 In the event that any Data submitted by Users is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
8. Controlling Use of Your Data
8.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
8.1.1 use of Data for direct marketing purposes; and
8.1.2 sharing Data with third parties.
9. Your Right to Withhold Information
9.1 You may access certain areas of the Website without providing any Data at all. However, to use all features and functions available on the Website you may be required to submit certain Data.
10. Accessing your own Data
You have the right to ask for a copy of any of your personal Data held by DisplayNote Technologies Limited (where such data is held) on payment of a small fee, which will not exceed £25.00.
11.1 Data security is of great importance to DisplayNote Technologies Limited and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
12.1 This Website may place and access certain first party Cookies on your computer. First party cookies are those placed directly by DisplayNote Technologies Limited via this Website and are used only by DisplayNote
chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
12.2 By using this Website you may receive certain third party Cookies on your computer. Third party cookies are those placed by websites and/or parties other than DisplayNote Technologies Limited. Third party cookies may be used on this Website for improvement of our products or services and are detailed in full below. These cookies are not integral to the services provided by the Website.
12.3 All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
12.4 Before Cookies are placed on your computer, you will be presented with a pop up message requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling DisplayNote Technologies Limited to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
12.5 Certain features of the Website depend upon Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below. Your consent will not be sought to place these Cookies. You may still block these cookies by changing your internet browser’s settings as detailed below.
12.6 The following first party Cookies may be placed on your computer:
Name of Cookie Purpose Strictly Necessary
None and the following third party Cookies may be placed on your computer:
Name of Cookie Provider Purpose
12.7 This Website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling us to better understand how Users use the Website. This, in turn, enables us to improve the Website and the products services offered through it. You do not have to allow us to use these Cookies, as detailed below, however whilst our use of them does not pose any risk to your privacy or your safe use of the Website, it does enable us to continually improve our business.
12.9 The analytics services used by this Website use the following Cookies:
Name of Cookie First / Third
12.10 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
12.11 You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalization settings.
12.12 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
13. Changes to this Policy
DisplayNote Technologies Limited reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.
DATA PROTECTION POLICY
This document sets out the obligations of DisplayNote Technologies Limited (“the Company”) with regard to data protection and the rights of people with whom it works in respect of their personal data under the Data Protection Act 1998 (“the Act”).
This Policy shall set out procedures, which are to be followed when dealing with personal data. The procedures set out herein must be followed by the Company, its employees, contractors, agents, consultants, and partners or other parties working on behalf of the Company.
The Company views the correct and lawful handling of personal data as key to its success and dealings with third parties. The Company shall ensure that it handles all personal data correctly and lawfully.
2. The Data Protection Principles
This Policy aims to ensure compliance with the Act. The Act sets out eight principles with which any party handling personal data must comply. All personal data:
2.1 Must be processed fairly and lawfully (and shall not be processed unless certain conditions are met);
2.2 Must be obtained only for specified and lawful purposes and shall not be processed in any manner, which is incompatible with those purposes;
2.3 Must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
2.4 Must be accurate and, where appropriate, kept up-to-date;
2.5 Must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;
2.6 Must be processed in accordance with the rights of data subjects under the Act;
2.7 Must be protected against unauthorized or unlawful processing, accidental loss, destruction or damage through appropriate technical and organizational measures; and
2.8 Must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
© DisplayNote Technologies Data Protection Policy- July 2014 Page 2 of 6
3. Rights of Data Subjects
Under the Act, data subjects have the following rights:
o The right to be informed that their personal data is being processed;
o The right to access any of their personal data held by the Company within 40 days of making a request;
o The right to prevent the processing of their personal data in limited circumstances; and
o The right to rectify, block, erase or destroy incorrect personal data.
4. Personal Data
Personal data is defined by the Act as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession
of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data
controller or any other person in respect of the individual. The Act also defines “sensitive personal data” as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.
The Company only holds personal data which is directly relevant to its dealings with a given data subject. That data will be held and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by the Company from time to time:
o job title;
o contact information such as email addresses and telephone numbers
o demographic information such as post code, preferences and interests;
o financial information such as credit / debit card numbers;
5. Processing Personal Data
Any and all personal data collected by the Company (including that detailed in Section 4 of this Policy) is collected in order to ensure that the Company can facilitate efficient transactions with third parties including, but not limited to, its customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by the Company in meeting any and all relevant obligations © DisplayNote Technologies Data Protection Policy- July 2014 Page 3 of 6 imposed by law. Personal data may be disclosed within the Company. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
The Company shall ensure that:
o All personal data collected and processed for and on behalf of the Company by any party is collected and processed fairly and lawfully;
o Data subjects are made fully aware of the reasons for the collection of personal data and are given details of the purpose for which the data will be used;
o Personal data is only collected to the extent that is necessary to fulfil the stated purpose(s);
o All personal data is accurate at the time of collection and kept accurate and upto- date while it is being held and / or processed;
o No personal data is held for any longer than necessary in light of the stated purpose(s);
o All personal data is held in a safe and secure manner, taking all appropriate technical and organisational measures to protect the data;
o All personal data is transferred using secure means, electronically or otherwise;
o No personal data is transferred outside of the UK or EEA (as appropriate) without first ensuring that appropriate safeguards are in place in the destination country or territory; and
o All data subjects can exercise their rights set out above in Section 3 and more fully in the Act.
6. Data Protection Procedures
The Company shall ensure that all of its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company comply with the following when processing and / or transmitting personal data:
o All emails containing personal data must be encrypted;
o Personal data may be transmitted over secure networks only – transmission over unsecured networks is not permitted in any circumstances;
o Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
o Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
o Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax © DisplayNote Technologies Data Protection Policy- July 2014 Page 4 of 6 machine to receive the data;
o Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient. Using an intermediary is not permitted;
o All hardcopies of personal data should be stored securely in a locked box, drawer, cabinet or similar;
o All electronic copies of personal data should be stored securely using passwords and suitable data encryption, where possible on a drive or server which cannot be accessed via the internet; and
o All passwords used to protect personal data should be changed regularly and should not use words or phrases which can be easily guessed or otherwise compromised.
7. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:
o A designated officer (“the Designated Officer”) within the Company shall be appointed with the specific responsibility of overseeing data protection and ensuring compliance with the Act.
o All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company are made fully aware of both their individual responsibilities and the Company’s responsibilities under the Act and shall be furnished with a copy of this Policy.
o All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be appropriately trained to do so.
o All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be appropriately supervised.
o Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed.
o The Performance of those employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed.
o All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Act and this Policy by contract. Failure by any employee to comply with the principles or this Policy shall constitute a disciplinary offence. Failure by any contractor, agent, consultant, partner or other party to comply with the principles or this Policy shall constitute a breach of contract. In all cases, failure to comply with the principles or this Policy may also constitute a criminal offence under the Act.
o All contractors, agents, consultants, partners or other parties working on behalf © DisplayNote Technologies Data Protection Policy- July 2014 Page 5 of 6 of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Act.
o Where any contractor, agent, consultant, partner or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
8. Access by Data Subjects
A data subject may make a subject access request (“SAR”) at any time to see the information which the Company holds about them.
o SARs must be made in writing, accompanied by the correct fee.
o The Company currently requires a fee of £10 (the statutory maximum) with all SARs. [A fee of £2 shall be required for access to a credit file.]
Upon receipt of a SAR the Company shall have a maximum period of 40 days within which to respond. The following information will be provided to the data subject:
o Whether or not the Company holds any personal data on the data subject;
o A description of any personal data held on the data subject;
o Details of what that personal data is used for;
o Details of any third-party organisations that personal data is passed to; and
o Details of any technical terminology or codes.
9. Notification to the Information Commissioner’s Office
As a data controller, the Company is required to notify the Information Commissioner’s Office that it is processing personal data. The Company is registered in the register of data controllers.
Data controllers must renew their notification with the Information Commissioner’s Office on an annual basis. Failure to notify constitutes a criminal offence. Any changes to the register must be notified to the Information Commissioner’s Office within 28 days of taking place. The Designated Officer shall be responsible for notifying and updating the Information Commissioner’s Office.
10. Implementation of Policy
This Policy shall be deemed effective as of Jul 2014. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.