Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We are deltaDNA Limited. We are a company incorporated and registered in Scotland. Our company number is SC383152. Our registered office address is 25 Greenside Place, Edinburgh, EH1 3AA.
When we refer to “we”, “us” or ”our” in this policy, we are referring to deltaDNA Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.
We use the following definitions in this policy to cover the different categories of individuals we interact with via our Site and Services:
Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
Our apps may include third-party advertising networks such as HyprMX. These networks determine independently how to use your information, so review their linked privacy policies to learn more.
We use different methods to collect data from and about you including through:
We may collect and process the following data about you:
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:
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.
Please 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 us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/activity||Type of data||Lawful basis for processing|
|To respond to your enquiries||Contact data||Consent (as you are requesting us to respond to you)
Necessary for our legitimate interests (to respond to enquiries from customers and potential customers)
|To enable Registered Users to access the Services||Account data||Performance of a contract with you|
|To send you marketing emails||Marketing data||Consent
Legitimate interests (to market to network of customers and contacts)
|To personalise our Site and improve user experience for the Site and Services||Technical data
|Legitimate interests (to improve customer interactions)|
|To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Contact data
|Necessary for our legitimate interests (for running our business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Performance of a contract with you
We may have to share your personal information with the following third parties:
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.
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. The table below sets out details of transfers to such third parties and the relevant safeguards.
|Service provider||Description of service||Safeguards|
|SurveyMonkey||Customer feedback and survey||Privacy Shield|
|Eventbrite||Marketing-event management||Privacy Shield|
|Mailchimp||Marketing automation||Privacy Shield|
|Stripe||Credit Card billing||Privacy Shield|
|Marketo||Marketing automation||Privacy Shield|
|Salesforce||Customer CRM||Privacy Shield|
|Status.io||Platform Status||Data Protection Agreement|
|Xero||Finance & Invoicing||Data Protection Agreement|
|AdRoll||Website Tracking||Data Protection Agreement|
|OptinMonster||Consent Gathering||Privacy Shield|
|Crazy Egg||Website Analytics||Privacy Shield|
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures in accordance with industry best practice 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, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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.
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.
We normally delete personal identifiable information we hold on you within 30 days of the end of the service but in some circumstances you can ask us to delete your data sooner: see Deleting personal data below for further information.
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
What are cookies?
A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.
What cookies do we use?
The cookies that we use fall into the following categories:
We use various types of cookies (including some that we place and others which we permit third parties to place on our site) for a number of purposes. The information collected by cookies allows us to monitor how many people are using our services and their interactions with other services. Cookies are also used to facilitate a user’s log-in, as navigation aids, and as session timers, and to restrict underage use of our tools and services.
If for any reason you do not want us to track your use of our site using cookies, you can opt out of this using your browser settings and can also select the option “Do Not Track” (for more information please refer to your browser).
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
To find out how to manage cookies on popular browsers:
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
We use web beacons to collect information about the use of our services. The information collected by web beacons allows us to monitor how many people are using our services, how many people open our e-mails, and determine for what purposes these actions are being taken. Our web beacons are not used to track activity outside of our services.
You can find more information about the individual cookies we use and the purposes for which we use them below:
Marketo Munchkin tracking service is provided by Marketo Inc. The Marketing automation web tracking cookie (“Munchkin”) analyzes browsing activity across sites to establish user profile and records last visit and activity. It expires 24 months from the date that it was set.
You can learn more about marketing automation from Marketo by visiting this page: https://www.marketo.com/software/marketing-automation/
The default behavior of Marketo Munchkin is to do the following on page load:
1. Check to see if the current browser has a Munchkin cookie and create one if it is not there.
2. Send a “Visit Web Page” event to the designated Marketo instance using the information from the current page and browser. This records an activity to the corresponding record in Marketo.
3. Send “Clicked Link on Web Page” event for any user clicks that occur on links.
To opt-out from Marketo Munchkin tracking entirely visit this URL https://deltadna.com/?marketo_opt_out=true
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
The cookie expires 24 months from the date that it was set.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Google AdWords remarketing service is provided by Google Inc. The DoubleClick by Google cookie analyzes audience to improve website design and content for conversion tracking and retargeting. The cookie expires 24 months from the date that it was set.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Crazy Egg is a heat mapping tool that provides graphical representation of where visitors to our website have clicked and scrolled down to. It can also show from which pages visitors have been referred to this website. Cookies placed by Crazy Egg on the computers of visitors to this websites do not include or collect Personally Identifiable Information such as name, phone number, e-mail address or mailing address. Crazy Egg sets one cookie value in order to track whether a visitor is new or returning. A “returning” visitor is one that has previously visited any tracked page on this website within the last 5 years. It expires 24 months from the date that it was set.
For more information regarding Crazy Egg and your data privacy please visit: http://www.crazyegg.com/privacy
It is possible to opt out of Crazy Egg tracking on all websites you visit. F or more information please visit: http://www.crazyegg.com/opt-out
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read below to find out more about these rights.
If you wish to exercise any of the rights set out above, please contact us. 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.
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.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.
You have the right to ask for a copy of the information which we hold on you (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.
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. 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.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected].
You may also object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
In certain circumstances, you may 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.
Please 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.
Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.
This version was last updated on 23/05/2018.
Historic version of this policy can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Protection Officer at [email protected].