We regularly review and update this policy to ensure it meets with data protection laws. Most recently, the policy has been reviewed to meet the European Parliament’s General Data Protection Regulation (“GDPR”), which replaces the UK’s Data Protection Act 1998 and at the end of 2020 when the United Kingdom leaves the European Union Data Protection Act 2018.
Where this policy refers to “data protection laws”, it implies the General Data Protection Regulation. The terms “Dig Inclusion”, “us” or “we” refer to Dig Inclusion Ltd. Our company is registered in England and Wales, company number 08245475.
This policy is effective from September 2020.
What we collect
We may collect the following information about you:
- Your name and job title
- Your organisation and work address
- Contact details, typically your email address, telephone number (or digital equivalent, such as your Skype account name) and social media account details
- Your Internet Protocol (IP) address and details of the web browser and operating system you use
- Rarely, as part of customer surveys and/or offers, we may collect demographic information such as personal preferences and interests
Typically, we collect personal information via our website, Hugr, email, telephone, social media or in person. Sometimes, we may obtain personal information via one of our partner organisations. In such cases, our data protection and privacy policies form part of our contracts.
No sensitive personal data is held by Dig Inclusion Ltd. This means that we do not collect information concerning race or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences.
“Cookies” are small files that are placed on your computer’s hard drive by your web browser. They allow web applications to respond to you as an individual. For example, cookies are necessary for any site where you log in or have preferences.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you. Some cookies, as noted below, are necessary for our website to work properly, and it is not possible to opt you out of these cookies.
Our site asks for your consent before cookies are used to identify you. You can also manage cookies in your browser settings, where you can choose to accept or decline cookies and delete existing cookies. However, by declining cookies, you may hinder your user experience of our website. You can read more about cookies and how to manage them at allaboutcookies.org.
We use Google Analytics to help us understand how you interact with our website by collecting and reporting information anonymously. We only use this information for statistical analysis purposes; personal information is not sent to Google. The data helps us analyse traffic to our website and improve it to meet the needs of our customers. Google’s website has more information about Google Analytics cookies and privacy.
We display embedded YouTube videos on some of our pages. We try to ensure that these videos operate in “privacy enhanced” mode so that no cookies are used. However, sometimes the following cookies may be used by YouTube.
Dig InclusionGoogle AnalyticsYouTube
|cookie_notice_accepted||diginclusion.com||1 year||Necessary for tracking website visitor consent.|
|DYNSRV||diginclusion.com / cdn.diginclusion.com||End of session||Necessary for load balancing to manage website traffic demand.|
|_ga||diginclusion.com||2 years||Used to distinguish visitors.|
|_gid||diginclusion.com||24 hours||Used to distinguish visitors.|
|_gat||diginclusion.com||1 minute||Used to throttle request rate.|
|VISITOR_INFO1_LIVE||youtube.com||1 minute||Embedding YouTube videos in some cases.|
|PREF||youtube.com||2 years||Embedding YouTube videos in some cases.|
|YSC||youtube.com||End of session||Embedding YouTube videos in some cases.|
|GPS||youtube.com||30 minutes||Embedding YouTube videos in some cases.|
|test_cookie||doubleclick.net||15 minutes||Used in some cases by YouTube advertising to check if a visitor’s browser accepts cookies.|
|IDE||doubleclick.net||390 days||Used in some cases by YouTube advertising for tracking.|
Internet Protocol (IP) addresses are used to connect your computer to the Internet and are assigned to you by your internet service provider. As standard, web servers collect and store details of your web browser and operating system, the website from which you came, the pages that you browse on our website, the date of your visit, and your IP address. This information is collected as part of reasonable measures towards the prevention and detection of fraud, attacks on our website, and other irregularities. As such, we do not require your consent to collect this data. However, we do whatever we can to anonymise and encrypt this data where possible, then dispose of the data when it is no longer necessary (within a maximum of 12 months). For example, we anonymise this data when it is used in conjunction with third-party software, such as Google Analytics.
What we do with the information we collect
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- To facilitate the normal activities of providing our services to you, which includes communicating with you or your organisation
- For internal record keeping
- To fulfil our legal obligations in the prevention or detection of fraud or other illegal activities
- To contact you to gather feedback on training courses, events or talks you have attended
- To improve our products and services
- To provide you with a user account on Hugr
- To contact you by email, phone or post for market research purposes
- To send occasional promotional emails about new services, special offers or other information that we think you will find interesting using the email address which you have provided (we do not issue regular marketing newsletters)
Where your data is used
We will not sell or lease your personal information to third parties.
Where your data is stored on third-party systems, we try to ensure that your data remains in the UK, or inside the EU. For example, our website is hosted in the UK. All of the Hugr databases are UK based.
Where it is necessary to use services outside the UK, we have contracts in place with those third-party suppliers to ensure they meet data protection laws and our privacy and data protection policies. For example, in some situations, your data may be transferred and stored via online systems that operate outside the UK or the EU. Such services that we use internally include Google’s G Suite (for email, calendars, documents, spreadsheets), Dropbox (for internal file transfer), and MailChimp (to send emails).
How long we retain your personal information
We retain personal information we collect from you as long as we have an ongoing legitimate business need to do so. For example, this may be in the normal activities of providing our services to you or as required by financial obligations or applicable laws. Data retention periods for different types of data are defined in our data protection policy, which is available on request.
Dig Inclusion Ltd is a paperless organisation, meaning that all data is stored electronically. When your personal information goes past its data retention period, it is deleted. If it is not possible to fully delete data, it will be anonymised in order to protect your privacy.
Controlling your personal information
Under data protection laws, you have the right to obtain a copy of any personal data we hold for you. You also have the right to ask that we remove all your data from our records.
You may request from us full details of the personal information we hold about you (commonly referred to as a subject access request). If you would like a copy of the information held on you, please contact us. We will fulfil reasonable requests within one month. There is no fee for reasonable subject access requests.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible. We will fulfil reasonable requests to correct inaccurate or incomplete information within one month.
You may choose to restrict the collection or use of your personal information, or even request that we remove all your data from our records. If you have previously agreed to us using your personal information and have changed your mind in any way, please contact us to request changes to or removal of your data.
Links to other websites
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Two factor authentication is used across all applications that store data.
Our email systems and Hugr are secured using TLS 1.2. Wherever we request personal information from you digitally, we use Hypertext Transfer Protocol Secure (HTTPS) to ensure your data is safely transmitted to our server through a secure socket layer (SSL). Web browsers typically indicate that a website is secure by showing a padlock icon in its address bar.
We adopt a principal of least privileged access for all data. Information is shared only with staff members who need access to carry out their role, this is detailed within our Access control policy.
Data breach notifications
Should we detect any data breaches that adversely affects your privacy, we will contact you as soon as possible and within the 72 hours required by data protection laws.