1.1 We are committed to safeguarding the privacy of DTW’s website visitors and its clients in accordance to General Data Protection Regulation (GDPR).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of DTW’s website visitors and customers; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to DTW For more information about DTW, see Section 12.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and 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 website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is for our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.5 We may process information contained in, or relating to, any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is for our legitimate interests, namely the proper administration of our website and business and communications with users.
3.6 We may process any of your personal data identified in this policy 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.
3.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of 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.
3.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 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.
5.3 We will retain your personal data as follows:
(a) personal data, Your name and email address, will be retained for a minimum period of 12 months following use of the web contact form, and for a maximum period of 24 months following the sign-up date.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of your email address will be determined based on consent and legitimate interest for the purposes of offering, marketing and selling relevant goods and/or services to you.
5.5 Not withstanding the other provisions of this Section 5, 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.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email.
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.8 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12 You may exercise any of your rights in relation to your personal data by written notice to us OR in addition to the other methods specified in this Section 7.
8.1 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.
8.2 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.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
|__hssc||persistent||30 minutes||This cookie is set by HubSpot. The purpose of the cookie is to keep track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.|
|__hssrc||persistent||This cookie is set by Hubspot. According to their documentation, whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.|
|__hstc||persistent||1 year||This cookie is set by Hubspot and is used for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).|
|__lotl||persistent||180 days||URL of the visitor’s original landing page, if any.|
|__lotr||persistent||180 days||URL of the visitor’s original referrer, if any.|
|__utmc||session||Session||The cookie is set by Google Analytics and is deleted when the user closes the browser. The cookie is not used by ga.js. The cookie is used to enable interoperability with urchin.js which is an older version of Google analytics and used in conjunction with the __utmb cookie to determine new sessions/visits.|
|__utmt||session||10 minutes||The cookie is set by Google Analytics and is used to throttle request rate.|
|__utmz||persistent||6 months||This cookie is set by Google analytics and is used to store the traffic source or campaign through which the visitor reached your site.|
|_global_lucky_opt_out||third party||10 years||If set, will not run Lucky Orange. Set via our luckyorange opt out links.|
|_lo_bn||third party||30 days||Indicated this visitor has been banned from tracking.|
|_lo_cid||session||Session||ID of the visitor’s current chat, if any.|
|_lo_np_||third party||30 days||Set if a user should no longer receive a particular poll.|
|_lo_rid||session||30 minutes (extending)||ID of the visitor’s current recording.|
|_lo_uid||persistent||2 years||Unique identifier for the visitor.|
|_lo_v||persistent||1 Year (extending)||Total number of visitor’s visits.|
|bcookie||third party||2 years||This cookie is set by linkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page.|
|cookielawinfo-checkbox-analytics||persistent||11 months||This cookies is set by GDPR Cookie Consent WordPress Plugin. The cookie is used to remember the user consent for the cookies under the category “Analytics”.|
|cookielawinfo-checkbox-necessary||persistent||11 months||This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Necessary”.|
|cookielawinfo-checkbox-non-necessary||persistent||11 months||This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Non Necessary”.|
|GPS||third party||30 minutes||This cookie is set by Youtube and registers a unique ID for tracking users based on their geographical location|
|hubspotutk||persistent||1 year||This cookie is used by HubSpot to keep track of the visitors to the website. This cookie is passed to Hubspot on form submission and used when deduplicating contacts.|
|IDE||third party||2 years||Used by Google DoubleClick and stores information about how the user uses the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile.|
|lang||persistent||This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.|
|language||persistent||This cookie is used to store the language preference of the user.|
|SERVERID||session||Session||Set by the load balancer required to direct the user to same server for all requests within the same session.|
|uid||persistent||1 year||This cookie is used by Google to measure the number and behaviour of the visitors to the website anonymously. The data includes the number of visits, average duration of the visit on the website, pages visited, etc. for the purpose of better understanding user preferences for targeted advertisements.|
|UIDR||third party||1 year||This cookie is set bu scorecardresearch.com. The cookie is used to tracks the users activity across the internet on the browser such as visit timestamp, IP address, and most recently visited webpages. and may the data send to 3rd party for analysis and reporting to help their clients better understand user preferences.|
|VISITOR_INFO1_LIVE||third party||5 months||This cookie is set by Youtube. Used to track the information of the embedded YouTube videos on a website.|
|YSC||third party||This cookies is set by Youtube and is used to track the views of embedded videos.|
10.3 We use Lucky Orange analytics system to help improve usability and the customer experience.
Lucky Orange may record mouse clicks, mouse movements and scrolling activity. Lucky Orange may record keystroke information that you voluntarily enter on this website.
Lucky Orange does not track this activity on any site that does not use the Lucky Orange system.
11.1 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:
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);
(e) https://support.apple.com/kb/PH21411(Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12.1 This website is owned and operated by DTW Advertising and Marketing Ltd.
12.2 We are registered in England and Wales under Company registration number2304150and our registered office is at Bank Chambers, Market Place, Guisborough, Cleveland, TS14 6BN.
12.3 Our principal place of business is at Bank Chambers, Market Place, Guisborough, Cleveland, TS14 6BN.
12.4 You can contact us:
13.1 Our data protection officer’s contact details are:
Lorna McAteer-Bingham, DTW