Dotdigital privacy policy

Please read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities if you have a complaint.

If you are a Dotdigital service client or user, or you are visiting either of our websites , this policy applies to you. The Policy does not apply to customer data held within our platforms.

Where we use the term “client” we are referring to the entity in contract with us to use the Dotdigital services; (ii) where we use the term “you” we are referring to visitors to our websites or clients using the Dotdigital services; (iii) where we use the term “end-user” we are referring to individual users of a client, and; where we use the term “contact” we are referring to a person contacted through your use of the Dotdigital services, someone you may contact using the Dotdigital services, or any individual whose information you provide to us in your use of the Dotdigital service.

Who are Dotdigital?

Dotdigital is a Software-as-a-Service (SaaS) marketing platform that enables companies to create, test and send data-driven automated campaigns. In addition, to its marketing automation capabilities, Dotdigital Integrates with key business systems, such as e-commerce platforms and CRMs, enabling businesses to streamline their marketing operations and improve their customer engagement strategies.

Dotdigital and it’s entities are part of the Dotdigital Group which collects, uses and is responsible for certain personal information about you. Please see Appendix 1 for the list of legal entities falling within the Dotdigital Group.

In the United Kingdom and across Europe, when we do so we are regulated under the Data Protection Act 2018 and General Data Protection Regulation and we are responsible as ‘controller’ of that personal information for those laws.
With personal data provided through your use of Dotdigital SaaS Applications and other services we provide, we are a ‘processor’ for the General Data Protection Regulation.

As some Dotdigital affiliates are based outside of the European Economic Area, and these affiliates have appointed Dotdigital B.V. to be our representative within the EEA as necessary. Our representative within the United Kingdom is Dotdigital EMEA Limited. Contact details are available later in this Privacy Policy,
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What personal information of mine do you use?

Information you provide voluntarily

While signing up for and using Dotdigital services, consulting with our support teams, sending us an email, connecting another account with the Dotdigital services (e.g. using one of our technical integrations and connectors), or communicating with us in any way, you are voluntarily giving us information. That information may include either your or your end-users’ name, email address, IP address, phone number, postal address, besides other details that may include gender, location, occupation or other information of a demographic nature. In supplying this information, you consent to this information being collected, used, disclosed, transferred to Dotdigital partners & affiliates and stored by us, as described in our Terms and this Privacy Policy.

Information we automatically collect

When you browse one of our websites, use the Dotdigital platform or interact with an email we send to you, we may collect information about your web browsing and use of the site or platform. This may include details of your operating system, location, IP address, browser ID, browsing activity, and other information about how you interacted with Dotdigital’s services. We may collect this information as a part of log files and through cookies or other tracking technologies. We use this information to help improve the website, security purposes or to monitor the performance of our campaigns.

Both Dotdigital and our third-party partners may use assorted technologies to collect and store information when you use the Dotdigital platform, visit our website, or interact with an email from us. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyse behaviour, track movements around the website, provide targeted advertisements, and gather demographic information. We may partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods to provide you content or advertisements based upon your browsing activities and interests. You can control the use of cookies at an individual browser level. Please refer to our Cookie Policy for more information.

Information through Dotdigital’s SaaS Applications

We also obtain personal information from your use of Dotdigital SaaS Applications. We receive information about how you use the platform and store it in log files or other types of files associated to your account and link it to other information we hold about you. This information might include the date of any activity, the browser and IP address and actions your end-users have taken within the platform. This information helps us to improve the service for you for all users of the platform.

Information from elsewhere

Dotdigital may obtain information about you or end-users from third parties, such as public databases, social media platforms, third party data providers and our marketing partners. Examples of the information we may receive from other sources include device information (e.g. IP address and browser), location, behavioural data and demographic information. We may use this information, alone or combined with other information described above, to develop or provide more relevant platform features or services (e.g. social media data of end-users allowing you to send more relevant content) or provide more relevant marketing and content to you.

Public information & third-party sites

Dotdigital websites include social media features (either hosted by a third party or hosted directly on our website), which may collect information about your IP address and which page you are visiting. The feature may set a cookie to make sure the feature functions properly. We also maintain presences on social media platforms including Facebook, X, and Instagram. Your interactions with these platforms are governed by the privacy policies of the companies that provide them. Anything you submit to Dotdigital via a social media platform is done so at your own risk with no expectation of privacy.
Further, any comments or information you supply on any blog that Dotdigital operates can be read, used or collected by anyone. If your information appears in our blog pages and you want it removed, contact our Marketing team: marketing@dotdigital.com.

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, note that we have no control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. We accept no responsibility or liability for such other websites. Exercise caution when entering personal information online and look at the privacy statement applicable to this website.
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How we use personal information

We use and disclose personal information to:

• Supply, improve and support the services we provide (this includes using the data you provide to use Dotdigital’s SaaS applications to contact end-users, aggregating information from your use of the platform or our website and sharing this with third parties to improve the services we provide);
• Confirm your identity in using Dotdigital’s SaaS applications;
• Send you information and promotional content (you can amend your marketing preferences in our preference centre or stop receiving messages by unsubscribing);
• Promote our services to you (e.g. when we collect your personal information on our website, we may contact you further to invite you to use our platform);
• Perform our obligations under the contract with you or applicable law (e.g. to enforce our terms, communicate with you and provide support);
• Protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity;
• Fulfil requests you may make;
• Bill you (e.g. to send you invoices, process payment, notices). Note we use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
• Send notifications about the platform;
• Bring or defend legal proceedings, meet legal requirements (e.g. complying with court orders, enforcement actions, or other legally valid mechanisms) or respond to lawful requests by public authorities or law enforcement requests; and
• Inform our professional advisors and auditors.
  When using Dotdigital’s SaaS Applications, you may import contact or other personal information you have collected into our system. We have no direct relationship with your contacts or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permissions for Dotdigital to collect and process information about those individuals.

Further to the uses described above, we may aggregate and/or de-identify any information we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes without restriction. We may transfer personal information of you or your end-users to companies that help us promote, provide, or support our platform or other services we provide. We may partner with and use various third-party software and services, including analytics services, to help understand your usage of our products and services. We provide a limited amount of your information (such as your email address and sign-up date) to select third party services to collect data for analytics purposes when you visit our website or use our products and services. This allows Dotdigital to monitor your use of our website, products and services and tracks our relationship so we can improve our service to you. We may also use these third-party services for communications, either through email, or through messages within our products and services. These third-party services may collect publicly available contact and social information related to you, such as your name, email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.

Call Recordings and virtual meetings

Dotdigital has a telephone call recording system in operation and may record both outbound and inbound calls. We record calls for quality and training purposes to ensure we deal with your request as best as possible.

Calls are recorded under the legal basis of legitimate interest and consent.
All recordings will be retained in line with our retention policy. Information will not be retained for a longer period than necessary.

In addition to calls, Dotdigital uses Zoom to host virtual meetings, which may include the use of Zoom’s AI companion. These features are designed to enhance productivity and collaboration. If you prefer not to have these features enabled during the meeting, please contact the meeting host.
More information on how these features handle data can be found here.

Finally, the Dotdigital sales teams use Gong.io in connection with Zoom to capture and analyse interactions over calls and virtual meetings. This provides us with insights and increases business efficiency. For more information, please click here.

Third parties

We may disclose personal information to advertising partners, networks and exchanges to display advertising on our website or to manage and serve our advertising on other sites and may share personal information with them for this purpose. All third parties with which we share this information must use your Personal Information so it is consistent with this policy. This may include using cookies and similar tracking technologies (e.g. pixels and web beacons) to analyse behaviour, track movements around the website, provide targeted advertisements, and gather demographic information. We partner with third parties to display advertising on our website or to manage and supply our advertising on other sites. These partners may use cookies or other tracking methods to provide you content or advertisements based upon your browsing activities and interests. Please refer to our Cookie Policy for more information.

For details about how we engage third parties when we process your contact or end-user data when you use our platform and services, please see our terms & conditions, the standard form of which can be found at https://www.Dotdigital.com/terms-of-service/.

How long will my personal information will be kept?

In providing services to you, we will hold personal information for as long as we are providing you the services, to comply with our legal obligations, enforce our contracts, resolve disputes or prevent abuse.

Why do you collect and use my personal information?

In relation to clients, the lawful basis for which we rely on to collect and process your data is typically performance of our contractual obligations.

If you are not a Dotdigital client, we rely on legitimate interest as the lawful basis on which we collect and use your personal data in relation to contacting you further in certain situations. Our legitimate interests are usually to provide individuals representing a business with details of our products or services through B2B direct marketing . If you are an individual, the basis on which we collect and use your personal data to contact you is often consent.
If you have questions about the lawful basis on which we are processing your personal data, please contact privacy@dotdigital.com.
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Where does my information go?

Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our service or by providing consent to us (where required by law), you agree to transferring information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. All Dotdigital entities operate under Standard Contractual Clauses and applicable measures of the GDPR providing protections and safeguards for cross-border transfers. We take all steps reasonably necessary to ensure that your data is treated securely and under this privacy policy.
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What are my rights under GDPR?

For UK & European residents, under the General Data Protection Regulation, you have several important right. Those include rights to:

• fair processing of information and transparency over how we use your personal information
• access to your personal information and to certain other supplementary information this Privacy Notice is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information about you in certain situations
• receive the personal information about you which you have provided to us, in a structured, commonly used and machine-readable format and may transmit those data to a third party in certain situations
• object to processing of personal information about you for direct marketing
• object to decisions being taken by automated means which produce legal effects about you or similarly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

To exercise any of those rights, please:

• contact our Data Protection Officer using the details further down this page
• let us have enough information to identify you,
• 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 to which your request relates, including any account or reference numbers, if you have them

If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email. It may take up to 24 hours for this to take place.
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What are my rights under CCPA?

Besides the general rights set out under this Privacy Policy, if you are a resident of California, Californian law means you have several important rights free. Those include rights to:

• request information, including a list of the categories of Personal Information (e.g. name, email, and mailing address, and the services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, from businesses with whom you have an established business relationship, & the names and addresses of all such third parties.;
• portability of such information and receive the personal information about you which you have provided to us, in a structured, commonly used and machine-readable format and may transmit hose data to a third party in certain situations
• require the erasure of personal information about you in certain situations; and

We do not sell your data to third parties, and the categories of information we collect are listed above in this policy, but for any queries or other requests please email privacy@dotdigital.com.
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How do you keep my information secure?

We have security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those with a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any regulator of a suspected data security breach where we are legally required to do so
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How can I complain?

We hope we can resolve any query or concern about our use of your information.

For individuals in the UK & EEA, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. For UK individuals, the supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone at 0303 123 1113 or other channels as updated at https://ico.org.uk/global/contact-us.

For individuals in the Netherlands, the supervisory authority is the Dutch Data Protection Authority who may be contacted at https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us.
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Changes to this privacy notice

This privacy notice was published on 11h November 2024. .
We may change this privacy notice occasionally, when we do, we will inform you via email.
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How can I contact Dotdigital?

If you have any questions about how Dotdigital handles any privacy matter or the information we hold about you, please contact us on the details below.

For UK Residents

For UK data protection legislation, please use the following contact details if you wish to contact our Data Protection Officer. Please direct emails to privacy@dotdigital.com, or write to Data Protection Officer, Dotdigital EMEA Limited, No.1 London Bridge, London, SE1 9BG.

For EEA / Swiss Residents

For European data protection legislation, please use the following contact details if you wish to contact our Data Protection Officer. Please direct emails to privacy@dotdigital.com, or write to Data Protection Officer, Dotdigital B.V., Mr. Treublaan 7, Amsterdam 1097 DP, Netherlands.

For all other territories

If you wish to contact our Data Protection Officer please email privacy@dotdigital.com, or write to Data Protection Officer, Dotdigital EMEA Limited, No.1 London Bridge, London, SE1 9BG, United Kingdom.

You are entering into a contract with Dotdigital

Purpose and legal basis for Processing

When you negotiate with us to buy a product or start using one of our services, we process some personal information so that we can enter into an agreement with you or the organisation that you represent.

The legal basis we rely on to process your personal data is article 6(1)(b) of the GDPR, which allows us to process personal data when this is necessary for the performance of a contract to which you are a party or in order for us to take steps at your request prior to entering into a contract.

What we need

If you are entering into a contract with us, we will need your full contact details including address, email and telephone number as well as your job title or position in your business. If we need further information, this will be made clear to you as we will ask you for it at the time.

What we do with it

We store customer contracts and related personal information within our internal CRM system, and our legal case management system is shared with internal employees on a need-to-know basis via email and Dropbox.

What are your rights

As we are processing your personal data for the purpose of entering into a contract with you, you have the right in principle to data portability. However, there are limitation as to when this right applies.

You subscribe to our content

What type of content can you subscribe to

You can subscribe to read blogs, case studies, events and webinars, product demonstrations, product updates and videos.

Purpose and legal basis for processing

Our purpose for collection this information is so that we can send you the requested content, and our legal basis is your consent which you have indicated by providing us with your details. We may also send you details of other products or services that we think you will be interested in and our legal basis for this is where we believe that you have a legitimate interest and in line with your preferences. Set your Dotdigital email communications preferences

What we need

If you wish to receive information from us, you will be asked to provide your contact information including your name, your organisation’s name and other details about your organisation.

What we do with it

Your details will be held on our CRM and marketing platform databases and the information you have requested will be sent to you. We may also send you details of other products or services.

What are your rights?

We rely on your consent to process the personal data you give us. This means you have the right to withdraw your consent at any time. As we also rely on legitimate interest, you do have the right to object. If you do that, we’ll update our records immediately to reflect your wishes. Please also see summary of your data protection rights above.

You are representing your organisation

We hold the names and contact details of individuals acting in their capacity as representatives of their organisations, across the business. The legal basis is article 6(1)(c) of the GDPR for any legal obligation or article 6(1)(f) because the processing is within our legitimate interests as a business.

Visitors to our website

What we need

When you visit our company websites, we collect internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to various parts of the site.

Cookies

• We use cookies, which are small files with a code that is stored on your device, with your consent. They are retrieved from your device when you next visit the site. This allows the site to recognise information about your use and browsing.
• We use a cookie consent tool on our website which notifies you of our use of cookies when you first enter our site of cookies when you first enter our site and gives you the opportunity to refuse the use of cookies or to consent by accepting use of cookies on our site.
• Full information on which cookies we use is available in our Cookies Policy, along with guidance about how you can set your browser to refuse all or some cookies (please note that your decisions may affect some use of the site).

When you make an enquiry or contact our support team

Purpose and legal basis for processing

When you contact Dotdigital via phone, email or live chat to make an enquiry, we collect information, including your personal data, so that we can assist with your enquiry.
Where you have no prior business relationship with Dotdigital the legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR , which allows us to process personal data when this is necessary for our legitimate interests. Where there is a business relationship the legal basis we rely on is article 6 (1) (b) of the GDPR, which allows us to process personal data when this is necessary for the performance of a contract to which you are a party.

What we need

We need enough information from you to answer your enquiry. This information may be obtained for training purposes, or to establish the facts of transactions and enquiries as well as to ensure compliance with our policies and procedures and any regulations we are subject to.

What we do with it

We’ll keep a record of your enquiry on Zendesk & intercom, our support ticketing system We use the information supplied to us to deal with the enquiry and any subsequent issues that may arise, and to check on the level of service we provide.

What are your rights?

Where we are processing your personal data for the purpose of entering into a contract with you, you have the right in principle to data portability. However, there are limitation as to when this right applies. Where we are processing your personal data for our legitimate interests, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.

You wish to attend, or have attended, an event

Purpose and legal basis for processing

Our purpose for collecting this information is so we can facilitate the event and provide you with an acceptable service.

The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR. When we collect any information about dietary or access requirements, we also need your consent (under article 9(2)(a)) as this type of information is classed as special category data.

What we need

If you wish to attend one of our events, you will be asked to provide your contact information including your organisation’s name and, if offered a place, information about any dietary requirements or access provisions you may need.

What are your rights

We rely on your consent to process the personal data you give us to facilitate the event. This means you have the right to withdraw your consent at any time. If you do that, we’ll update our records immediately to reflect your wishes.

Integrations & Connectors

Purpose and legal basis for processing

Dotdigital uses several suppliers of integration platforms for clients wanting to link their Dotdigitial account to supported third party e-commerce systems. The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR.
Please note: when connecting Dotdigital SaaS applications to your Google workspace account using OAuth, we confirm Google Workspace APIs and the data passed within are not used to develop, improve, or train generalized/non-personalized AI and/or ML models.

What are your rights

We rely on your consent to process the personal data you give us to facilitate the event. This means you have the right to withdraw your consent at any time by cancelling the integration link.

Appendix 1 – Dotdigital Group subsidiaries that may collect personal data

Where your data is being collected by any of the following Dotdigital Group subsidiaries, where they are acting as data controller, this will be made clear at the point of collection:

• Dotdigital B.V.
• Dotdigital, Inc.
• Dotdigital APAC Pty Ltd
• Dotdigital SA Pty Ltd
• Dotdigital SG Pte.Ltd
• Dynmark International Ltd.
• Dotdigital Poland Sp.z.o.o.
• Fresh Relevance Ltd (a Dotdigital company)
• Fresh Relevance Inc. (a Dotdigital company)