Introduction
We are committed to safeguarding the privacy of our website visitors and service users.
In this notice, we refer to our websites and software, and the services available through the websites and software, as “our services“.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
In this notice, “we”, “us” and “our” refer to Daft Springer Limited. For more information about us, see the end of this notice.
The personal data that we collect
In this section we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
We may process data enabling us to get in touch with you (“contact data“).
We may process your user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, services settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our services.
We may process your personal data contained in contracts that you create using our services (“services data“). The services data may include your name, email address, business name, contract execution dates and other contract content. The source of the account data could be you or another registered user.
We may process information relating to transactions, including purchases of our services, that you enter into with us and/or through our services (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our services will generate the metadata associated with communications made using the services contact forms.
We may process data about your use of our services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your service use. The usage data comes from our analytics tracking systems – see below for details.
Purposes of processing and legal bases
In this section, we have set out the purposes for which we may process personal data and the legal bases of the processing.
Operations – We may process your personal data for the purposes of processing and fulfilling orders, taking payments, administering subscriptions, operating and providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our services and business.
Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our service users, the maintenance of our relationships, enabling the use of our services, and the proper administration of our services and business.
Personalisation – We may process account data, services data and/or usage data for the purposes of personalising the content that you see through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our service users.
Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
Research and analysis – We may process usage data, services data and/or transaction data for the purposes of researching and analysing the use of our services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our services and business generally.
Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to run our business properly and efficiently in accordance with this notice.
Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our services and business, and the protection of others.
Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
Our services providers may also collect, store and process your personal information, as detailed below.
| Provider | Purposes | Type |
| Amazon Web Services | Hosting infrastructure and hosting-related services | Sub-processor |
| Heroku | Data processing services | Sub-processor |
| Stripe | Payment processing services | Controller – for information about Stripe’s handling of your personal data, see https://stripe.com/en-gb/privacy |
| Google, Mixpanel, Segment, Amplitude and Facebook | Analytics and advertising services | Controller – see below in the section of this notice regarding cookies |
| Crisp | Messaging services | Controller – see below in the section of this notice regarding cookies |
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Retaining and deleting personal data
This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
- contact data will be retained for a minimum period of 6 years following the date of the most recent contact between you and us, and for a maximum period of 7 years following that date;
- account data will be retained for a minimum period of 6 years following the date of closure of the relevant account, and for a maximum period of 7 years following that date;
- services data will be retained for a minimum period of 6 years following the date of closure of the last associated account, and for a maximum period of 7 years following that date;
- transaction data will be retained for a minimum period of 6 years following the date of the transaction, and for a maximum period of 7 years following that date;
- communication data will be retained for a minimum period of 6 years following the date of the communication in question, and for a maximum period of 7 years following that date; and
- usage data will be retained for 36 months following the date of collection.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Your rights
In this section, we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:
- the right to access – you can ask for copies of your personal data;
- the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
- the right to erasure – you can ask us to erase your personal data;
- the right to restrict processing – you can ask us to restrict the processing of your personal data;
- the right to object to processing – you can object to the processing of your personal data;
- the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
- the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
- the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
Third party websites
Our services include hyperlinks to, and details of, third party websites.
In general, we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
We may use cookies for the following purposes:
- authentication and status – we use cookies to identify you when you visit our websites and as you navigate our services, and to help us determine if you are logged into our services;
- ecommerce – we use cookies to enable purchases and other transactions on our services;
- personalisation – we use cookies to store information about your preferences and to personalise our services for you;
- security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our services generally;
- advertising – we use cookies to help us to display advertisements that will be relevant to you;
- analysis – we use cookies to help us to analyse the use and performance of our services; and
- cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
Cookies used by our services providers
We use Google Analytics, Mixpanel, Segment and Amplitude to gather and analyse information about the use of our services by means of cookies. The information gathered is used to create reports about the use of our services. You can find out more about our analytics services providers’ use of information by reviewing the policies on their respective websites:
We may use a Facebook pixel on our services. Using the pixel, Facebook may collect information about the users and use of our services. The information is used to personalise Facebook advertisements and to analyse the use of our services. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.
We use Crisp as our messaging platform, and again this uses cookies. You can find out about how Crisp uses information by visiting https://crisp.chat/en/privacy/.
Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647 (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- https://help.opera.com/en/latest/security-and-privacy/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our services.
Amendments
We may update this notice from time to time by publishing a new version on our services. You should check this page occasionally to ensure you are happy with any changes to this notice. We may notify you of significant changes to this notice by email.
Our details
We are Daft Springer Limited.
We are registered in England and Wales under registration number 12351517, and our registered office is at 15 Brookside Close, Batheaston, Bath, England, BA1 7HW.
You can contact us: (a) by post, to the postal address given above; or (b) using our contact form.
Introduction
We are committed to safeguarding the privacy of our website visitors and service users.
In this notice, we refer to our websites and software, and the services available through the websites and software, as “our services“.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
In this notice, “we”, “us” and “our” refer to Daft Springer Limited. For more information about us, see the end of this notice.
The personal data that we collect
In this section we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
We may process data enabling us to get in touch with you (“contact data“).
We may process your user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, services settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our services.
We may process your personal data contained in contracts that you create using our services (“services data“). The services data may include your name, email address, business name, contract execution dates and other contract content. The source of the account data could be you or another registered user.
We may process information relating to transactions, including purchases of our services, that you enter into with us and/or through our services (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our services will generate the metadata associated with communications made using the services contact forms.
We may process data about your use of our services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your service use. The usage data comes from our analytics tracking systems – see below for details.
Purposes of processing and legal bases
In this section, we have set out the purposes for which we may process personal data and the legal bases of the processing.
Operations – We may process your personal data for the purposes of processing and fulfilling orders, taking payments, administering subscriptions, operating and providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our services and business.
Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our service users, the maintenance of our relationships, enabling the use of our services, and the proper administration of our services and business.
Personalisation – We may process account data, services data and/or usage data for the purposes of personalising the content that you see through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our service users.
Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
Research and analysis – We may process usage data, services data and/or transaction data for the purposes of researching and analysing the use of our services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our services and business generally.
Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to run our business properly and efficiently in accordance with this notice.
Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our services and business, and the protection of others.
Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
Our services providers may also collect, store and process your personal information, as detailed below.
| Provider | Purposes | Type |
| Amazon Web Services | Hosting infrastructure and hosting-related services | Sub-processor |
| Heroku | Data processing services | Sub-processor |
| Stripe | Payment processing services | Controller – for information about Stripe’s handling of your personal data, see https://stripe.com/en-gb/privacy |
| Google, Mixpanel, Segment, Amplitude and Facebook | Analytics and advertising services | Controller – see below in the section of this notice regarding cookies |
| Crisp | Messaging services | Controller – see below in the section of this notice regarding cookies |
In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Retaining and deleting personal data
This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
- contact data will be retained for a minimum period of 6 years following the date of the most recent contact between you and us, and for a maximum period of 7 years following that date;
- account data will be retained for a minimum period of 6 years following the date of closure of the relevant account, and for a maximum period of 7 years following that date;
- services data will be retained for a minimum period of 6 years following the date of closure of the last associated account, and for a maximum period of 7 years following that date;
- transaction data will be retained for a minimum period of 6 years following the date of the transaction, and for a maximum period of 7 years following that date;
- communication data will be retained for a minimum period of 6 years following the date of the communication in question, and for a maximum period of 7 years following that date; and
- usage data will be retained for 36 months following the date of collection.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Your rights
In this section, we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:
- the right to access – you can ask for copies of your personal data;
- the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
- the right to erasure – you can ask us to erase your personal data;
- the right to restrict processing – you can ask us to restrict the processing of your personal data;
- the right to object to processing – you can object to the processing of your personal data;
- the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
- the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
- the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
Third party websites
Our services include hyperlinks to, and details of, third party websites.
In general, we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
We may use cookies for the following purposes:
- authentication and status – we use cookies to identify you when you visit our websites and as you navigate our services, and to help us determine if you are logged into our services;
- ecommerce – we use cookies to enable purchases and other transactions on our services;
- personalisation – we use cookies to store information about your preferences and to personalise our services for you;
- security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our services generally;
- advertising – we use cookies to help us to display advertisements that will be relevant to you;
- analysis – we use cookies to help us to analyse the use and performance of our services; and
- cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
Cookies used by our services providers
We use Google Analytics, Mixpanel, Segment and Amplitude to gather and analyse information about the use of our services by means of cookies. The information gathered is used to create reports about the use of our services. You can find out more about our analytics services providers’ use of information by reviewing the policies on their respective websites:
We may use a Facebook pixel on our services. Using the pixel, Facebook may collect information about the users and use of our services. The information is used to personalise Facebook advertisements and to analyse the use of our services. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.
We use Crisp as our messaging platform, and again this uses cookies. You can find out about how Crisp uses information by visiting https://crisp.chat/en/privacy/.
Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647 (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- https://help.opera.com/en/latest/security-and-privacy/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
- https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac(Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our services.
Amendments
We may update this notice from time to time by publishing a new version on our services. You should check this page occasionally to ensure you are happy with any changes to this notice. We may notify you of significant changes to this notice by email.
Our details
We are Daft Springer Limited.
We are registered in England and Wales under registration number 12351517, and our registered office is at 15 Brookside Close, Batheaston, Bath, England, BA1 7HW.
You can contact us: (a) by post, to the postal address given above; or (b) using our contact form.