Privacy Policy

This policy (version 2.0.4) was updated on 31/10/2023.

Distribution Technology is committed to the privacy of its users, and this Privacy Policy sets out how and why your personal data is collected. It also describes how your personal data is processed in a fair and transparent manner in line with Data Protection Laws such as the UK Data Protection Act 1998 (“DPA”) and the EU General Data Protection Regulation 2016 (“GDPR”) or their supplants.

We may need to make changes to this policy from time to time, so please come back and occasionally review this policy.

Within this policy Distribution Technology is collectively referred to as "we", "us" or "our”.

By using this website and providing personal data you consent to this Privacy Policy.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPO:

FAO Data Protection Officer
Distribution Technology Ltd.
C/O Moorcrofts Llp Thames House,
Mere Park, Dedmere Road,
Marlow,
Buckinghamshire,
SL7 1PB

DPO@Distribution-Technology.com

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK Supervisory Authority (“SA”) for data protection issues (https://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.

It is important that the personal data we hold is accurate and current. Please keep us informed if any personal data changes during your relationship with us.

When this policy applies

This policy applies to Dynamic Planner (“Our Product”) and services provided by Distribution Technology Ltd. including this website but excludes separate services that have a separate privacy policy. This policy applies to personal data collected through your use of this website, including any data you may provide through this website when you sign up to our newsletter, request information, register for an event or use Our Product and services.

Privacy of others

When providing personal data about other individuals, you confirm that you have the consent of those individuals to pass their personal data to us, and in doing so you confirm that you are acting as the Data Controller and processing their data on a lawful basis and that we are acting as the Data Processor. As a Data Controller you acknowledge your obligations under all applicable Data Protection Laws.

Links from Our Product, website(s)

Our Product and websites sometimes contain links to other relevant websites, products and services provided by our partners or third parties. This Privacy Policy does not in any way cover their website, products and services, and we are not responsible for the way in which they process your personal data should you choose to use their services. Therefore, we encourage you to review the privacy policies of those services.

The data we collect about you

Personally Identifiable Information (PII), means any data that could identify a specific individual or natural person. Personal Data, means any information relating to an identified living individual or natural person (“Data Subject”) who can be identified directly or indirectly in reference to an identifier or to one or more specific factors.

When such data is collected, used, stored or transferred, we will ensure that it is relevant and limited to what is necessary for the purposes. We have grouped this data as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes Internet Protocol (IP) address, your login data, device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.

We also collect, use and share aggregated data such as statistical or demographic data. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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.

What data we do not collect about you

We do not collect any Special Categories of Personal Data as defined by GDPR (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic or biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect PII or Personal Data including:

Direct interactions where you may give us Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our products or services;

create an account on our website;

use Our Product or services;

subscribe to Our Product, services or publications;

request marketing to be sent to you;

give us some feedback or complete a survey.

Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your devices, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.

Publicly available sources. We may receive PII or Personal Data about you from various third parties and public sources such as: Identity and Contact Data from publicly availably sources such as Companies House or the ICO.

How we use your personal data

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

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we may not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via post, email or telephone. You have the right to withdraw consent to marketing at any time by contacting us, or using the unsubscribe option at the bottom of one of our marketing emails.

We have set out below, the main ways we plan to use your Personal Data, and on which legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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

Purpose	Type of data	Basis for lawful processing
To provide you with information about Our Product or services	Identity Contact	Consent given for a specific purpose (responding to a direct request from you).
Normal management of your account including: (1) notifying you about changes to our terms or privacy policy. (2) Notifying you about changes to Our Product and services. (3) Manage payments, fees and charges. (4) Collect and recover money owed to us. (5) Asking you to leave a review or take a survey	Identity Contact Financial Transaction	Performance of a contract with you. Necessary for our legitimate interests (such as to recover debts due to us).
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing	Identity Contact	Necessary for our legitimate interest Consent given for a specific purpose
To use data analytics to improve Our Product, website(s), services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep Our Product, services and websites updated and relevant, to develop our business and to inform our marketing strategy)
To administer and protect our business Our Product, and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Profile	Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business Our Product, and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	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) Necessary to comply with a legal obligation

Basis for lawful processing

We have identified the following as normal lawful basis on which we will process your personal data as referenced in the table above: -

Consent means you have given us permission for one or more specific reasons to use your personal data such as responding to your request for information or marketing to inform you about other products and services that we think may be of interest and relevant to you.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Marketing

We provide you with choices on how we contact you for the purposes of marketing Our Product and services. We have established the following personal data control mechanisms:

Promotions and events. We may use your name, Contact, Technical, Usage and Profile Data (as defined above) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers we think may be relevant for you. You will also receive marketing communications from us if you have requested specific information about Our Product and services, or if you have registered for an event, and in each case if you have not opted out.
Third-party marketing. We will get your express opt-in consent before we share your personal data with any company outside Distribution Technology for marketing purposes.
Opting out. You can ask us to stop sending you marketing messages at any time, or you can use the unsubscribe option at the bottom of one of our marketing emails. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Disclosures of your personal data

Where we have to share some of your personal data with other parties set out below for the purposes detailed in the table above, we will ensure that is done appropriately and with the absolute minimum required :-

Single Sign On: Your organisation’s administrator (“OU Admin”) may have setup your systems so that you can logon to a third-party system and simply click on a link and be logged into ours without having to type in your credentials again. Your OU Admin may have also subscribed you to Our Product or some of our services, please refer to your OU Admins privacy policy for more information.
External Identity providers: You or your OU Admin may be using a central identity service such as Unipass provided by Origo so that you can easily log in to multiple financial organisations. Please refer to the privacy policies of those organisations.
Integration partners: To link Our Product or services to external financial investment platforms you may have provided us with authentication details, please refer to the privacy policies of those organisations.
Local Authorities: We may need to provide your information to satisfy an applicable law, regulation, legal process or enforceable governmental request.

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.

International transfers

We will not transfer or store your personal data outside the European Economic Area (EEA) without your consent.

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, contractors and other third parties on a need to know business basis. Such persons are bound by strict contractual obligations of confidentiality and will only process your personal data on our instructions.

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.

Data retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, compliance, 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.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as:

Right of access to your personal data
Commonly known as a "Subject Access Request" (“SAR”). You can request a copy of the personal data we hold about you and how we are lawfully processing it.
Right to rectification of your personal data
You can 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.
Right to erasure of your personal data
You can ask us to delete your personal data where there is no good reason for us continuing to process it. However, we may not always be able to comply with your request of erasure for specific legal reasons for which you will be notified, if applicable, at the time of your request.
Right to restriction of processing your personal data
You can ask us to suspend the processing of your personal data in the following scenarios: (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.
Right of data portability of your personal data
You can request the transfer of your personal data to you or to a third party. We will provide to you, or a third party 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.
Right to object to processing of your personal data
You can 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.
Right to withdraw consent
You can 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.

Subject Access Request (SAR)

If you wish to exercise any of these rights, please contact our Data Protection Officer as detailed at the top of this policy. It will help us to process your request without delay if you complete our SAR form which you can download from the link below and either post it or email it to us.

https://legal.dynamicplanner.com/docs/SAR-FORM.pdf

There is no charge for an individual SAR. However, multiple copies or excessive repeat requests may be charged a reasonable fee based on administration costs.

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). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. Details of how to provide acceptable proof of identity are included in our SAR form. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all requests within 30 days. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Depending on how you have submitted your SAR it may be impractical for us to respond in the same way due to technical or security constraints. In this case we may ask you for a more appropriate method of address.

Cookies and similar technologies

Cookies are small text files that your web browser stores on your computer when you visit most websites including ours. The 3 types of cookies we use are:

Essential cookies (also known as ‘session cookies’) are vital for the operation of the website. For example, they store information to allow the website to recognise you and present you with the right information as you move through the website. These are anonymous and deleted by your browser when they expire, and your browser is closed.
Functional cookies (also known as ‘persistent cookies’) let our website remember your preferences such as preferred language and allowing you to carry information across pages of our website.
Analytics cookies and similar technologies are used to analyse how our websites are used and monitor website performance. These typically persist on your computer until you delete them. This allows us to improve the website and quickly identify issues that arise, for example to keep track of which pages are most popular or to identify poorly performing ones. These are sometimes known as ‘first and third-party cookies’ because we may use a third party.

What about third parties? We don’t share this information we collect with third parties, but we may use third parties such as Google Analytics and Pendo to help understand how our websites are being used. You can opt out of being tracked by Google Analytics.

Can I disable cookies? You can disable or block cookies for Our Product or services using the controls built into your web browser, but this may mean that some parts or our websites won’t work as intended.

What other information is used?

IP addresses: Every device connected to the internet is assigned a number known as an Internet Protocol (IP) address. These IP addresses are normally assigned in blocks and associated with geographical regions. Therefore, an IP address can be used to identify where the website is being accessed from. We only store part of the IP address to ensure our websites are suitable for the demographic in that region.
HTTP referer: We monitor how you have arrived at our website through HTTP referrer information. This contains the address of the website whose link you used to get to our website. This allows us to ensure that our website is being accessed in an appropriate manner.
Server logs: The servers from which our websites are hosted record all requests made to our websites. Typically, this includes the date and time of the request, status codes, time taken, type of request, IP address, browser type, and browser language. These logs are used to help us maintain a secure site and fix problems when they occur.