Welcome to the privacy notice of Global Digital Solutions (“the Administrator”). The Administrator respects your privacy and is committed to protecting your personal data. Its full contact details in connection with all matters relating to this privacy notice are:-
Data Privacy Manager
2. Important information
Purpose of this privacy notice
This privacy notice informs you as to how your personal data is collected and processed when you use a Site or a Service and tells you about your privacy rights and how the law protects you.
The Site is not intended for use by (and we do not knowingly collect data relating to) individuals who are under 16 years old.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice the Administrator may provide on specific occasions when your personal data is being collected or processed so that you are fully aware of how your personal data is being used and why. This privacy notice supplements those other notices and is not intended to override them.
The Administrator is the controller and responsible for your personal data. It has appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details in paragraph 1 above.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). The Administrator would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact the Data Privacy Manager using the details in paragraph 1 above in the first instance.
Changes to the privacy notice and your duty to inform of changes
This version was last updated on 23 March 2023.
It is important that your personal data is accurate and current. Please keep the Data Privacy Manager informed (using the details in paragraph 1 above) if your personal data changes.
The Site may contain links to and from the websites of partner networks, advertisers and affiliates and, when a Service is accessible via such a website, the third party concerned may have access to your personal data. If you follow a link to any of those websites, please note that they have (or should have) their own privacy policies and that we do not accept any responsibility or liability for those privacy policies (or the absence of them) or for any personal data that may be collected through those websites. Please read all (if any) of those privacy policies before you submit any personal data to those websites.
3. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data includes first name, last name, username or similar identifier, age range and gender; Contact Data includes address, email address and telephone numbers; Financial Data includes bank account and payment card details; Transaction Data includes details about payments from you and other details of Services you have purchased from us; Technical Data includes internet protocol (IP) address, your login data, 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 a Site, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface and/or the mobile phone number used by your device), mobile network information and your mobile operating system; 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 a Site; Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 Site 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 notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
Where you fail to provide personal data that we request, we (in our absolute discretion) may not provide Services (or any further Services, as the case may be) to you.
4. How is your personal data collected?
We use different methods to collect data from and about you including through: Direct interactions You give us your Identity, Contact, Financial and Profile Data by filling in forms on a Site and by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you create an account, enquiry or other entry on a Site, subscribe to a Service, request marketing material to be sent to you, enter a competition, promotion or survey or give us some feedback. Automated technologies or interactions as you interact with a Site, we automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details. Third parties or publicly available sources We receive personal data about you from various third parties and public sources such as (i) Technical Data from analytics providers such as Google based inside or outside the EU, advertising networks based inside or outside the EU and search information providers based inside or outside the EU (ii) Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU (iii) Identity and Contact Data from data brokers or aggregators based inside or outside the EU (iv) Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside or outside the EU.
5. 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:
(i) to provide Services to you;
(ii) 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; and
(iii) to comply with our legal and regulatory obligations.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party marketing and other communications to you via email, push notification and/or text message. You have the right to withdraw consent to marketing and other communications at any time by sending an email to that effect to the Data Privacy Manager (using the details in paragraph 1 above).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases 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 for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Data Privacy Manager (using the details in paragraph 1 above) if you need details about the specific legal ground relied on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Provide products/Services to you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Provide products/Services to you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Provide products/Services to you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/Services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Provide products/Services to you
(b) Necessary for our legitimate interests (to study how customers use our products and Services, to develop them and grow our business)
To administer and protect our business and a Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) 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)
(b) Necessary to comply with a legal obligation
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products and Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, products, Services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and Services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products and/or Services that may be of interest to you
Necessary for our legitimate interests (to develop our products and Services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and other communications. Personal data control mechanisms are available to you by emailing the Data Privacy Manager (using the details in paragraph 1 above) accordingly.
Promotional offers by us
We may use your Identity, Contact, Technical, Usage and Profile Data 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 may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, purchased goods from us, used Services, provided us with your details when you entered a competition or registered for a promotion and, in each case, have not opted out of receiving marketing communications.
We will get your express opt-in consent before we share, for marketing purposes, your personal data with any organisation out with the Global Digital Solutions Group or the Administrator Group.
You can ask us or third parties to stop sending you marketing and other messages at any time by emailing the Data Privacy Manager (using the details in paragraph 1 above) accordingly. Where you opt out of receiving these 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 transaction.
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Data Privacy Manager (using the details in paragraph 1 above). If we need to use your personal data for an unrelated purpose, the Administrator will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosure of your personal data
For the purposes set out in the table in paragraph 5 above, we may have to share your personal data with:
(i) Internal Third Parties and/or External Third Parties (as each is defined in paragraph 11 below);
(ii) without prejudice to the foregoing, other members of the Administrator Group and/or Global Digital Solutions
(iii) third parties to/with whom we may choose to sell, transfer or merge all/part of our business.
Alternatively, we may seek to acquire other businesses. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
7. International transfers
We do not transfer your personal data outside the Combined Area.
8. Data security
The Administrator has put in place and/or procured appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, the Administrator limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. The Administrator has put in place and/or procured procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where legally required to do so.
9. How long will you retain my personal data for?
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, 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.
10. Your legal rights
You have rights under data protection laws in relation to your personal data. Please see the website of the Information Commissioner’s Office (at https://ico.org.uk) to find out more about those rights and contact the Data Privacy Manager (using the details in paragraph 1 above) if you wish to exercise any of them.
In summary, you have the right to:
(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to 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.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you by the Administrator, if applicable, at the time of your request.
(d) 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.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) 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 (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) 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 provide a Service to you.
(g) 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 products or Services to you. The Administrator will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
The Administrator seeks to respond to all legitimate requests within one month. It can, though, take longer than a month if your request is particularly complex or you have made a number of requests. In this case, the Administrator will notify you and keep you updated.
Administrator Group means the group of companies of which the Administrator forms part from time to time;
Combined Area means the combined area of the European Economic Area and the United Kingdom.
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.
External Third Parties means
(a) service providers based in the Combined Area who provide IT and system administration services;
(b) professional advisers including lawyers, bankers, auditors and insurers based in the Combined Area who provide consultancy, banking, legal, insurance and accounting services; and
(c) HM Revenue & Customs, regulators and other authorities based in the Combined Area who require reporting of processing activities in certain circumstances.
Group of companies means a company, any subsidiary or subsidiary undertaking of that company, any holding company or parent undertaking of that company and any other subsidiary or subsidiary undertaking of that holding company or parent undertaking (including, for the avoidance of doubt, a holding company, parent undertaking, subsidiary and/or subsidiary undertaking constituted in a jurisdiction out with the United Kingdom, however described in that jurisdiction).
Internal Third Parties means other companies in the Administrator Group and/or the Global Digital Solutions Group who are based in the Combined Area and provide IT and system administration services and undertakes leadership reporting.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Service/product and 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting the Data Privacy Manager (using the details in paragraph 1 above).
Services means services offered by a member of the Administrator Group, whether through a Site and/or otherwise, from time to time and Service means any of them.
Site means a website of a member of the Administrator Group.
We mean the Administrator and each member of Global Digital Solutions (and us and our shall be construed accordingly).
Global Digital Solutions means each member of the organisation of companies of which it forms part from time to time and member of Global Digital Solutions shall be construed accordingly.