For the purpose of the Data Protection Act 2018 (the Act), the data controller is Decibel Insight Limited of 5th Floor, Aldgate Tower, 2 Leman Street, London E1 8FA, United Kingdom.
We, Decibel Insight Limited are committed to protecting and respecting your privacy. This policy (together with any other documents referred to on it) 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. By visiting the Decibel Insight website which appears at www.decibel.com (“our site”) you are accepting and consenting to the practices described in this policy.
Types of information gathered
Information you give to us
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, request a demo, place an order or make a request on our site, participate in discussion boards or other social media functions on our site such as instant chat, enter a competition, promotion or survey and when you report a problem with our site.
The information you give us may include your name, address, e-mail address and phone number. If you contact us, we may keep a record of that correspondence. You do not have to respond to requests from us to complete surveys or enter competitions.
Information we collect about you
For each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, the company name from which you are browsing our website, your login information, browser type and version, time zone setting, and operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, technical errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
This is purely data about our types of users, browsing actions and patterns, and does not identify any individual unless they provide us with their details.
Information we receive from other sources
We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). If applicable, we will notify you when we receive information about you from them and the purposes for which we intend to use that information.
This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and to deliver a better and more personalised service. For example, they enable us to:
- estimate our audience size and usage pattern;
- store information about your preferences, and so allow us to customise our site according to your individual interests; and
- recognise you when you return to our site.
Use of your information
We use information held about you in the following ways:
Information you give to us
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by e-mail with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data;
- to notify you about changes to our service; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure; and
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
If you have given permission, we may share your personal data with organisations who are our business partners and we or they may contact you (unless you have asked us or them not to do so) by email, telephone or post, about products, services, promotions, and special offers that may be of interest to you. If you prefer not to receive any further direct marketing communications from us or our business partners, you can opt out at any time. See further ‘Your rights‘, below.
If you are an existing customer or you have expressed interest in and requested more information about our products and services, we may contact you by email, telephone or post about existing services that you have purchased as well as about similar products and services where we consider it to be in our legitimate interests to do so.
We only rely on our legitimate interests, where these are not outweighed by your interests or fundamental rights and freedoms. The legitimate interests we rely on for this processing are: to promote the Decibel products and services to you, and issue our direct marketing materials to you. You have a right to object and to seek to restrict such processing. See the ‘Your rights‘ section for more information on how to exercise your right to object.
We will consider several factors when assessing an objection including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. If your objection is upheld, we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.
Where you have given your permission and you change your mind and you no longer wish to receive marketing and promotional communications from us, you may unsubscribe or opt-out of receiving them by following the instructions included in each newsletter or communication or by contacting us. See the ‘How to contact us’ section below.
Decibel will also offer you the opportunity to choose (opt-out) whether your personal data is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you.
See further ‘Your rights‘ below for more information about what you can do in relation to your personal data collected and used by us.
Sharing your information
You agree that we have the right to share your personal information with:
- any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
- selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site; and
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Decibel Insight Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it will be one of the transferred assets; and
Keeping your information secure
We will use industry-standard technical and organisational measures to safeguard your personal data. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us’ below).
What can I do to keep my information safe?
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.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.
Transfers of your information out of the EEA
We may need to transfer your personal data to a country outside the European Economic Area in connection with services that you have requested to access, demo or which you have subscribed to and we share your personal data with Decibel Insight, Inc which involves transferring your personal data to the United States. Whenever 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:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries: https://ec.europa.eu/info/law/law-topic/data-protection_en
EU Model Contracts/Standard Contractual Clauses
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission webpage on Model Contract Clauses: https://ec.europa.eu/info/law/law-topic/data-protection_en
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
To learn more about the Privacy Shield program, and to view our certification (where you will find details of what information is sent to Decibel Insight, Inc, and the purposes for which it processes it), please visit https://www.privacyshield.gov/
If you have a concern about the way your data has been handled when it was transferred to Decibel Insight, Inc in the United States using the Privacy Shield Framework, please refer to the “Complaints” section below.
In the context of an onward transfer, we as a Privacy Shield organization has the responsibility for the processing of personal information we receive under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf. We shall remain liable under the Principles if our agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
Circumstances when we may have to disclose your data
U.S. Federal Trade Commission enforcement: Decibel Insight’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Compelled disclosure: Decibel Insight may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Requesting a copy of your information
If you would like to request a copy of your information which we hold, please:
- email, call or write to us (see ‘How to contact us’ below);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know the information you want a copy of, including any account or reference numbers, if you have them
We may charge a small fee for this service.
Correcting any mistakes in your information
If you would like us to correct any mistakes in your information which we hold, please:
- email, call or write to us (see ‘How to contact us’ below);
- let us have enough information to identify you (e.g. account number, user name, registration details); and
- let us know the information that is incorrect and what it should be replaced with.
Asking us to stop contacting you with direct marketing
If you would like us to stop contacting you for direct marketing purposes, please:
- email, call or write to us (see ‘How to contact us’ below), or click on the ‘unsubscribe’ link within the email you received. It may take up to 14 days for this to take effect; and
- let us know what method of contact you are not happy with (for example, you may be happy for us to contact you by email but not by ordinary mail).
Asking us to stop processing your information
You may request that we cease processing your personal data. If you make such a request, we shall retain only the amount of personal data pertaining you that is necessary to ensure that no further processing of your personal data takes place. Please note that if you exercise this right and you have contracted for a service from us we may not be able to continue providing the service.
Asking us to delete your information
You can ask us to erase all your personal data (also known as the “right to be forgotten”) in the following circumstances:
- it is no longer necessary for us to hold that personal data with respect to the purpose for which it was originally collected or processed;
- you wish to withdraw your consent to us holding and processing your personal data;
- you object to us holding and processing your personal data (and there is no overriding legitimate interest to allow us to continue doing so);
- the personal data has been processed unlawfully; or
- the personal data needs to be erased in order for us to comply with a particular legal obligation.
Unless we have reasonable grounds to refuse to erase your personal data (e.g. because it is necessary to continue to process it in order to provide a service which you have contracted), all requests for erasure shall be complied with.
Asking to take your data with you
The right to data portability only applies:
- to personal data you’ve provided to us (i.e. not any other information);
- where we are processing your personal data because you have provided your consent for us to do so, or under a contract with you; and
- when processing is carried out by automated means.
We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal data concerns more than one individual, we may not be able to transfer the information to you if doing so would prejudice the other person’s rights.
California Privacy Rights
If you are a resident of the State of California, this notice explains your privacy rights and how you can exercise these rights. A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes. Please note that under California law, businesses are only required to respond to a customer request once during any calendar year. If you are a California resident and would like to make the type of request described above, see the ‘How to contact us’ section below.
How long do we keep your 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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. See the ‘How to contact us’ section below.
How to contact us
Inquiries and Complaints
In compliance with the Privacy Shield Principles, Decibel commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Decibel as specified above.
Decibel has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you can contact the Information Commissioner’s Office in the UK (ICO). Specifically, for unresolved complaints concerning Privacy Shield you should follow the process and complete the form found on the ICO’s website: https://ico.org.uk/concerns/eu-us-privacy-shield/
Requesting Binding Arbitration – you have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms in accordance with Section C of Annex 1 to the Privacy Shield Principles which can be found here: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.