Privacy & Cookie Policy

Your privacy is important to us at Digital Moments Group Ltd (“us” or “we”) and we are committed to protecting and respecting your privacy.

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It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

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For the purpose of the Data Protection Act 1998 (the “Act”) and the UK General Data Protection Regulation (“GDPR”) and all successor legislation to the Data Protection Act 1998 and the GDPR (the “Data Protection Legislation”), the data controller is Digital Moments Group Ltd (15496429) of 20 Wenlock Road, London, N1 7GU.

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1. Information we collect from you‍

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 (known as “anonymous data”).

We may collect, use, store and transfer 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 or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you subscribe to or use our services; book a demo on our site; subscribe to our newsletter; when you provide us with feedback and when you report a problem with our site. The information you give us may include your name, e-mail address, other details required for the formation or performance of any contract with you, and information about your activities.
• Information we collect about you. With regard to each of your visits to our site, we will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet; and
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, 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 us;
• Information we receive from other sources. We may receive personal data about you from various third parties including, for example, business partners, advertising networks, analytics providers and search information providers.

We may 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. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

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2. Uses made of your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information:

• where we need to perform the contract we are about to enter into or have entered into with you;

• to comply with any legal obligations to which we are subject;

• where it is necessary for our or a third party’s legitimate interests, including for the purposes of preventing fraud, except where such interests are overridden by your interests or fundamental rights and freedoms; or

• where you have provided valid consent.

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3. Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

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Purpose/Activity, Type of data, Lawful basis for processing including basis of legitimate interest:

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To process and deliver the services that you or your business have requested including:

(a) Manage payments, fees and charges;

(b) Collect and recover money owed to us

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Identity, contact details and financial information

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to perform our contractual obligations and to recover debts due to us)

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Contact details

(a)  Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

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To enable you to contact us, contact details are necessary for our legitimate interests (to enable us to provide you with a demonstration of our services on your request with a view to entering into a contract in respect of such services)

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To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) identity, contact details and technical data such as IP address are

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(a)            Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

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(b)            Necessary to comply with a legal obligation

To use data analytics to improve our website, services, marketing, customer relationships and experiences technical data such as IP address is necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

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To make suggestions and recommendations to you about services that may be of interest to you or your business identity, contact details, usage data are necessary for our legitimate interests (to develop our products/services and grow our business)

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To send our newsletter to you where requested contact details and consent.

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

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We will get your express opt-in consent before we share your personal data with any company outside Digital Moments Group Ltd for marketing purposes.

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You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

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Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

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Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

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If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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4. Disclosure of your information

We may have to share your personal information with the third parties set out below, or any other third parties notified to you, for the purposes set out in paragraph 3 above:

• Service providers including Webflow, G Suite.
• Xero, our internal accounting software provider
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK.
• Regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or mere 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 policy.
• Fraud prevention agencies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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5. International transfers

Some of our external third parties are also based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA.

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Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO and European Commission.

• Where we use certain service providers, we may use specific contracts approved by the ICO and European Commission which give personal data the same protection it has in the UK and Europe.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.

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6. 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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However, the transmission of information via the internet is never 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.

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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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7. Retention

We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 whether we can achieve those purposes through other means, and the applicable legal requirements.

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In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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8. Your rights

Under the Data Protection Legislation you may be entitled to the following rights:

• Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by writing to us.
• You can ask us to rectify any inaccuracies in the personal information that we hold about you.
• You can request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed you information unlawfully or where we are required to erase your personal data to comply with local law.
• You can object to our processing of your personal data where we are relying on a legitimate interest (or that 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.
• You can ask us to restrict our processing of your personal data (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• You can request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
• You can ask not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
• You have the right to access information held about you. 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.

9. Links to and from our site

Our site may, from time to time, contain links to and from the websites of our partners 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.

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10. Changes to your personal data

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.

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11. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

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12. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

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A cookie is a small piece of information sent by a web server to store on a web browser so it can later be read back from that browser. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, and general usage and volume statistical information. Cookies may also be used to collect individualised website use data. Some cookies may remain on users’ computers after they leave the website.

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Your browser may provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion. Cookies, however, are important to the proper functioning of a site, and disabling them may degrade your experience and interfere with web site features and customisations.

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We may engage one or more third party service providers to track and analyse both individualised usage and volume statistical information. Your personal information is never directly connected to or stored on your computer, but is accessed when we identify your cookie to provide you with a more personalised experience when visiting our site. Aggregate cookie and tracking information may be shared with third parties.

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You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

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Cookie Purpose

‍Google Analytics

This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (for example, how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.

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13. Contact

Questions, comments and requests regarding this privacy and cookie policy are welcomed and should be addressed to us using the contact forms available on the website. You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Further information can be found at www.ico.org.uk.

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