We, DD Hub Limited, use your personal data to provide our website and services (together called “our services”) to you. We have described how we collect, store and use your data in this privacy notice.
We take seriously our responsibilities to look after your data and we are committed to protecting your privacy. There are steps you can take to control what we do with your data and we have explained those steps in this privacy notice.
This notice explains how and why we collect data, our lawful bases for it, and how we use it.
It also explains that we also hold personal data as a data processor, on behalf of our Subscriber firms (explained below).
When we talk about data and personal data in this privacy notice, we mean personal data which identify you or which could be used to identify you such as your name and contact details. It may also include information about how you use our website and services.
The “big picture”
We bring businesses together to share business information.
The personal data we hold relates only to individuals acting in a business capacity – for example, business phone numbers and email addresses.
Firms which subscribe to our services (“Subscriber firms”) provide responses to due diligence questions which we hold in our systems. Those responses may be viewed by individuals who register with us as Registered Users.
This privacy notice tells you about how we use your personal data – please ask if you have any questions.
What you need to know
1. Who is responsible for your data
Where a response provided by a Subscriber firm contains personal data – for example, names of key executives – the Subscriber firm is the data controller and is responsible for the data. Similarly, if you have been registered to use the services by a Subscriber firm, that firm is the data controller.
In all other cases, DD Hub Limited is responsible for your data. We are registered in England under company number 10024950 and our registered office is Office 7, 35-37 Ludgate Hill, London, EC4M 7JN. We are the data controller of the data which we collect from you, and as such we control the ways your personal data are collected and the purposes for which your personal data are used.
2. Information we collect
When you make contact with us or use our services, we collect the following types of information:
Information you, or your firm, provide to us
If you contact us to enquire about our services, we will use your name and contact details to respond to you and keep in contact with you, unless you ask us not to.
Some information is required to create an account on our services, such as your name, email address, password, and your telephone number. You might provide this information directly to us or, where you work for a firm, your firm might provide it to enable you to use our services on the firm’s behalf.
Information we receive from your use of our services
We collect data about the devices and computers you use to access the services, including IP addresses, browser type, language, operating system, the referring web page, pages visited, and cookie information.
When you log in to our services, or access them via a Subscriber firm’s website, we receive certain usage data. This includes information about your use of the services, for example, when you view or search content, or interact with it.
If you make your name and/or business contact details public (for example, on your firm’s website, LinkedIn, or other website), we may use those to contact you in relation to our services if we believe they are likely to be directly relevant to you.
3. How we use your data, and our lawful basis
We can only use your personal data if we have a proper reason for doing so, such as:
- To fulfil a contract we have with you (or with a firm you work for), or
- If we have a legal duty to use your data for a particular reason, or
- When you consent to it, or
- When it is in our legitimate interests.
Legitimate interests are our business or commercial reasons for using your data but, even so, we will not unfairly put our legitimate interests above what is best for you.
Here are the ways in which we use your personal data and the reasons we rely on for doing so:
|Your personal data||How we use it||Legal grounds for using it|
|Your name and contact details which you, or your firm, have given to us||To communicate with you.||Our legitimate interests|
|Your email address and password||To give you access to our services and to personalise content to you.||Fulfilling a contract|
|Your name and contact details||To show colleagues in your firm who has access to our services and who has changed any information.||Fulfilling a contract|
|Information about how you access our services, device, browser, etc||To develop and manage our services and ensure they are delivered to you appropriately||Our legitimate interests|
|Information about your use of our services||To personalise content and give you easy access to searches you’ve made and content relevant to you, including information which you’ve saved, amended or assessed, and to deliver information to help you meet your regulatory requirements such as updated responses to questions.
If you are a Registered User and request access to data which a Subscriber firm which has not yet made available to you, your name and contact details will be passed to that Subscriber with your request for access for them to consider.
If you are a Registered User, information about your viewing of (or downloading of) a Subscriber firm’s data, or your selection of that firm, will be made available to that Subscriber with your details.
|Fulfilling a contract|
|Business contact information you make publicly available||To communicate with you in respect of our services, to the extent that we believe the communication will be relevant to you and your business interests.||Our legitimate interests|
Where we rely on our legitimate interests for using your personal data, these may include:
- Keeping our records up to date
- Considering whether our services may be of interest and relevance to you
- Developing our services and calculating our charges
- Being efficient about how we fulfil our contracts, provide our services and fulfil our legal duties
- Identifying ways to improve the way we deliver services to our customers
We transfer information to the IT companies which host our services which process it for us, based on our instructions and in compliance with the data processing agreement we have with them.
Additionally, where we are processing data on behalf of a Subscriber firm:
|Your personal data||How we use it||Legal grounds for using it|
|(Applies only to data provided to us by a Subscriber firm)
May include your name, contact details and other information relevant to your involvement with that Subscriber firm’s business
|The Subscriber firm must decide which user firms can view that information: we will make the information available to those firms.||Fulfilling a contract with that Subscriber firm|
If you access our services via a Subscriber firm’s website, the contact details you provide and information about the services you choose to use will be made available to that Subscriber firm.
4. How long do we keep personal data for? Asking for personal data to be erased.
Because many of our Registered Users work for firms which are authorised and regulated by the Financial Conduct Authority (“FCA”), they are bound by FCA rules, including the need to retain records. If any later question arose, it may be necessary to establish what information was held and displayed by our services at a particular point in time. We therefore intend to hold information (which may include personal data) for six years from the point at which it was last accessed. If you ask us to erase your personal data before then, we will do so unless there is a legal or regulatory reason to retain it.
5. Where is personal data stored and how do we protect it?
Data is encrypted within our secure servers and file systems all in the UK, with access controls to keep it safe. Regular daily backups ensure that integrity is preserved. Our services deliver the data via secure webpages, to ensure that it cannot be intercepted.
7. Mailing Lists
If you register with us to join our mailing list, we ask for your personal data and your consent to use it. We will send you information and updates following your sign up, and hope that they will be useful and interesting to you. You can ask us to remove you from the list at any time (see 9. below).
8. Your rights
If you have any questions or concerns, or if you want to access or amend your data, please contact us at email@example.com or on 0203 633 2185.
In the unlikely event that you have a complaint about DD Hub and how we have used your personal data, that you don’t feel we can rectify, you have the right to contact the Information Commissioner’s Office: https://ico.org.uk.
Changes to this privacy notice
This notice may be amended from time to time. If we change it, the alterations will be published on these pages, and on our website.
This version: 1.06 19th February 2019