Dixcart International Limited (“Dixcart”) Privacy Notice (Marketing)
This privacy notice relates to the processing of personal data for marketing purposes. Dixcart respects your privacy and is committed to protecting your personal data.
Welcome to the Dixcart International Limited (“Dixcart”) Privacy Notice (Marketing).
This notice relates to the processing of personal data for marketing purposes. Separate notices are in place relating to personal data processed for services and relating to employees.
Dixcart respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we collect, use, share and look after your personal data when you visit our website www.dixcart.com (“Website”) (regardless of where you visit it from) and when we collect your personal data for marketing purposes. It also tells you about your privacy rights and how the law protects you.
1. Who we are
Dixcart International Limited is part of the wider Dixcart Group, as defined at the end of this privacy notice.
Dixcart is the controller and responsible for your personal data.
Where other entities in the Dixcart Group (see below) contact you for marketing purposes on the grounds of legitimate interest, then the relevant entity within the Dixcart Group is the controller of your data in relation to any contact they make with you, they are responsible for processing your data and their privacy notice applies to you.
We do not have a data protection officer. We have appointed a data privacy manager. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Dixcart International Limited
Postal address: Dixcart House, Addlestone Road, Bourne Business Park, Addlestone, Surrey KT15 2LE
Telephone number: +44 (0) 333 122 0000
Name or title of data privacy manager: Julia Wigram
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version is effective from the effective date as indicated at the end of this notice. Historic versions (if any) can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
The Website is not intended for children and we do not knowingly collect data relating to children.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Contact Data such as first name, last name, title, email address, postal address, telephone numbers, employer and job title.
- Profile Data such as your preferences in receiving marketing from us and from the Dixcart Group, your communication preference and your feedback responses.
- Other Information any information you choose to provide to us such as an inability to attend an event due to a holiday.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How and why we use your personal data for marketing and to whom we disclose it
This privacy notice only deals with the use of personal data for marketing purposes. The notice applies to marketing for both clients and non-client contacts. Use of personal data in relation to services provided by Dixcart is dealt with in a separate Privacy Notice (Client).
We rely on legitimate interest as the legal basis for processing your personal data in relation to marketing communications to you. We consider legitimate interest to arise; if you have a meeting with Dixcart, if you are referred to Dixcart and we have correspondence with you, if you connect to a Dixcart individual on LinkedIn, if you read a Dixcart article posted by Mondaq, if you make an enquiry, or if you subscribe to receive Newsletters via the Dixcart website. You have the right to unsubscribe from Dixcart Newsletters at any time and to ask Dixcart to stop processing your personal data for marketing purposes.
If you make or have made an enquiry to us or register to receive Dixcart Newsletters via a form on our website, this service is provided by HubSpot. Dixcart has reviewed HubSpot’s privacy policies and consider them to be adequate (13.06.23).
Limited data on individuals making an enquiry or registering to receive Newsletters, may be uploaded to HubSpot for the purpose of marketing communications. Dixcart has reviewed HubSpot’s privacy policies and consider them to be adequate (13.06.23).
Data on individuals may be uploaded to HubSpot for the purpose of responding to enquiries.
We have set out how and why we use your personal data and to whom it may be disclosed in a table format:
|Types of Data||Collection||Use||Disclosures|
|Contact Data Other Information Profile Data|
Information you give us by filling in forms or by corresponding or engaging with us by post, phone, email or otherwise.
This includes personal data you provide when you:
register on our Website;
subscribe to our publications;
make an enquiry to us;
agree to receive marketing communications;
connect to a Dixcart individual on LinkedIn; or
read a Dixcart article posted by Mondaq; or
give us some feedback.
|To respond to any request you make.|
To contact you with communications that Dixcart has a legitimate interest to send to you.
|Personal data may be transferred to and viewed by any entity within the Dixcart Group both in the UK and overseas. Dixcart Group entities may contact you if they have a legitimate interest to do so.|
Personal data may be transferred to and viewed by any party providing services to us to support the operation of our business, such as IT and other administrative support.
Third parties with whom the data needs to be shared for Health and Safety reasons.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
You can ask us to stop or stop us and/or the Dixcart Group sending you marketing messages at any time by following the opt-out/unsubscribe links on any newsletter mailshot sent to you or by contacting us at any time at email@example.com.
Where you opt out of receiving marketing messages we may continue to process your personal data on HubSpot in relation to the provision of services.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we obtain your consent to use it for another purpose or where the alternative purpose is required or permitted by law without your consent.
4. International transfers
We share your personal data within the Dixcart Group as joint controller or processor. This may involve transferring your data outside the UK.
Whenever we transfer your personal data out of the UK, we take all reasonable steps to ensure that the transfer is made securely and that there is adequate protection in place to protect your personal data. This can be done in a number of different ways, including:
- transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant UK government authority.
- by using model contractual clauses approved for use in the UK by the relevant UK government authority which give personal data the same protection it has in the UK.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
If you make or have made an enquiry to us or register to receive Dixcart Newsletters via a form on our website, this service is provided by HubSpot.
Data on individuals may be uploaded to HubSpot for the purpose of responding to enquiries, following a meeting with a Dixcart manager (in person or online), if you connect to a Dixcart individual on LinkedIn, and if you read a Dixcart article posted by Mondaq. Dixcart has reviewed HubSpot’s privacy policies and consider them to be adequate (13.06.23).
Dixcart subscribed to the HubSpot Subscription Service after July 19, 2021, and as we are located in Europe (defined by HubSpot as including Switzerland and the United Kingdom), our HubSpot Customer Data is hosted in Europe by default (based on our IP address on sign up). HubSpot will store the Customer Data within the Location for the duration of our Subscription Term in accordance with the terms of their Policy.
HubSpot Inc. is located in the USA. Certain storage and processing may take place outside Europe, this may include the USA and other regions where HubSpot, its Affiliates and Sub-Processors operate, for the following reasons:
- Customer and Product Development Support: In order to provide customer support and product development support, HubSpot employees from other office locations and Sub-Processors may access our HubSpot account and Customer Data
- Security and Abuse Prevention
- Operations Hub: The HubSpot infrastructure that supports the Operations Hub sync engine is hosted in the USA (AWS East). This means that when using sync features powered by Operations Hub, data will be transferred to, processed, and stored in the USA
- User Access: if Dixcart employees are accessing Customer data from outside the EU
- Usage Data
HubSpot uses a variety of security technologies and procedures to help protect Personal Data from unauthorized access, use or disclosure. HubSpot secures Personal Data on computer servers, in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.
5. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
6. Data retention
How long will you use my personal data for?
We will retain your contact details for as long as legitimate interest allows us to do so. If you make a request for Dixcart to erase your personal data that is being held for marketing purposes your contact details will be held on a marketing suppression list.
Details relating to particular events and invitations may be held for as long as necessary to fulfil the purposes we collected it for.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
7. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or to a third party that you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com. No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.
8. The Dixcart Group
Any reference to “Dixcart Group” means; Dixcart Management (Cyprus) Limited (registered in Cyprus, no. HE 310256), Dixcart Trust Corporation Limited (registered in Guernsey, no. 6512), Dixcart Management (IOM) Limited (registered in IOM, no. 0045258C), Dixcart Management Malta Limited (registered in Malta, no. C43184), Dixcart Management Nevis Limited (registered in St Kitts & Nevis, no. 25 of 2000), Dixcart Portugal Lda (registered in Portugal, no. 511031513), Dixcart Switzerland Sàrl (registered in Switzerland, no. CHE-108.554.698), Dixcart International Limited (registered in England and Wales, no. 06227355), Dixcart Group Limited (registered in IOM, no. 004595C), Dixcart Group UK Holding Limited (registered in Guernsey, no. 65357), Dixcart Professional Services Limited (registered in Guernsey, no. 59422), Dixcart Audit LLP (Registered in England and Wales, no. OC304784), and any subsidiary company from time to time of any of them. Each such company is a member of the Dixcart Group.
Effective Date: 13th June 2023 (version 10)