This is the privacy notice of DIGITAL CONVERSATION LIMITED, company number 13278274. (‘we’, ‘our’, or ‘us’). Our registered office is at 7 Bell Yard, London, WC2A 2JR.

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through our website and other platforms, including Microsoft 365, HubSpot and Gather Town.

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

Personal data we process

1. How we obtain personal data

The information we process about you includes information:

• you have directly provided to us

• that we gather from third party databases and service providers

• as a result of monitoring how you use our website or our services

2. Types of personal data we collect directly

When you use our website, our services or buy from us, we ask you to provide personal data. This can be categorised into the following groups:

• personal identifiers, such as your first and last names, your title and your date of birth

• contact information, such as your email address, telephone number and postal address, for billing, delivery and communication

• account information, including your username and password

• payment information, such as a debit or credit card number and expiry date, and bank account details

• records of communication between us, including messages sent through our website, email messages and telephone conversations

• marketing preferences that tell us what types of marketing you would like to receive

3. Types of personal data we collect from third parties

We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us and sometimes to assess the quality of your services.

The additional information we collect can be categorised as follows:

• information that confirms your identity

• business information, including your business trading name and address, your company number (if incorporated), and your VAT number (if registered)

• information that confirms your contact information

• reviews and feedback about your business on other websites through which you sell your services

4. Types of personal data we collect from your use of our services

By using our website and our services, we process:

• your username and password and other information used to access our website and our services.

• information you contribute to our community, including reviews.

• your replies to polls and surveys.

• technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, browser type and version and your device’s operating system.

• usage information, including the frequency with which you use our services, the pages of our website that you visit, and whether you receive messages from us or reply to those messages.

• transaction information that includes the details of the products and services you have bought from us and payments made to us for those services.

• your preferences for receiving marketing from us, how you wish to communicate with us, and your responses and actions in relation to your use of our services.

5. Our use of aggregated information

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

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data and will use it in accordance with this privacy notice.

6. Special personal data

We may collect particular personal data about you if there is a lawful basis on which to do so.

7. If you do not provide personal data we need

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.

If so, we may have to stop providing you with a service. If so, we will notify you of this at that time.

The basis 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 data and to notify you of the basis for each category.

If the basis on which we process your personal data is no longer relevant, we shall immediately stop processing your data.

If the basis changes, 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 if required by law.

8. Information we process because we have a contractual obligation with you

When you 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.

To carry out our obligations under that contract, we must process the information you give us, some of which may be personal data.

We may use it to:

• verify your identity for security purposes when you use our services

• 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 based on whether there is a contract between us or whether you have requested that 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 contract terms.

9. 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 job opportunities and our products and services, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information; for example, we ask you to agree to our use of non-essential cookies when you access our website.

If you have given us explicit permission to do so, we may, from time to time, pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

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 at collide@digitalconversation.ai. However, if you do so, you may not be able to use our website or our services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

10. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, in doing so.

Where we process your information on this basis, we do so after having given careful consideration to the following:

• 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

• improving our services

• record-keeping for the proper and necessary administration of our business

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

• preventing fraudulent use of our services

• exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property

• insuring against or obtaining professional advice that is required to manage organisational or business risk

• protecting your interests where we believe we have a duty to do so

11. Information we process because we have a legal obligation

Sometimes, we must process your information to comply with a statutory obligation.

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

This may include your personal data.

How and when we process your personal data

12. Information you provide

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by others.

For example, when you leave a review or post a message on our website, we reasonably assume that you consent to the message being seen by others. We may include your username with your message, and your message may contain information that is personal data.

In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do store it, and we reserve the right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable, and there is no legal basis for us to retain it, then at our discretion, we may agree to your request to delete the personal data that you have posted. You can make a request by contacting us at collide@digitalconversation.ai

13. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

14. Information obtained from third parties

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

15. Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

16. Service providers and business partners

We may share your personal data with businesses that provide services to us or with business partners.

As examples:

• we may pass your payment information to our payment service provider to take payments from you

• we may use fraud prevention agencies and credit reference agencies to verify your identity, and we may pass your information to those agencies if we strongly suspect fraud on our website

• we may pass your contact information to marketing agencies to use to promote our services to you

Use of information we collect through automated systems

17. Cookies

Cookies are small text files that your web browser places on your computer’s hard drive when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed later.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can improve the experience of other visitors; and serve you advertisements relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires explicit consent for using cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask 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 prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We 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 in to our website

• to record your answers to surveys and questionnaires on our site while you complete them

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

18. 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 use 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 web pages 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.

Other matters

19. Your rights

The law requires us to inform you about your rights and our obligations regarding the processing and controlling of your personal data.

We do this now by requesting that you read the information provided at http://www.knowyourprivacyrights.org

20. Use of our services by children

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.

We collect data about all users and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.

21. Encryption of data sent between us

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 marks in your browser’s URL bar or toolbar.

22. Delivery of services using third-party communication software

With your consent, we may communicate using software from a third party such as Gather Town, Microsoft (Teams) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please write to us at collide@digitalconversation.ai

23. Data may be processed outside the UK

Our websites are hosted in the UK and backed up in the Netherlands.

We may also occasionally use outsourced services in countries outside the UK in other aspects of our business.

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

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

• the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority.

24. Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

You may contact us at any time to request that we provide you with the personal data we hold about you.

If you would like to obtain a copy of any information that is not provided on our website, you should contact us to make that request.

When we receive a request to access, edit, or delete personal data, we first take reasonable steps to verify your identity before granting you access or taking any action. This is important to safeguard your information.

Please be aware that we are not legally obliged to provide you with all personal data we hold about you. If we do provide you with information, the law allows us to charge for it if doing so incurs costs. After receiving your request, we will tell you when we expect to provide you with the information and whether we require a fee for providing it.

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.

We remind you that we are not obliged by law to delete your personal data or stop processing it simply because you do not consent to us doing so. While your consent is an important consideration when deciding whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

25. Communicating with us

When you contact us, whether by telephone, through our website, or by email, we collect the data you provide so that we can reply with the information you need.

We record your request and our reply to increase the efficiency of our business.

We may keep personally identifiable information associated with your messages, such as your name and email address, to track our communications with you and provide high-quality service.

26. Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should write to us at collide@digitalconversation.ai

When we receive a complaint, we record the information you have given us with your consent and use that information to resolve your complaint.

If your complaint reasonably requires us to notify someone else, we may decide to give that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter of our sole discretion whether we https://ico.org.uk/make-a-complaint/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.

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 mediation or arbitration process.

If you are in any way dissatisfied with how we process your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). You can do this 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.

27. Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

• to provide you with the services you have requested

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

• to support a claim or defence in court

28. Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

29. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.