DSI Privacy and Data Protection Policy

DSI is committed to protecting your privacy and maintaining the security of any personal information we receive. We strictly adhere to the requirements of the data protection legislation in the UK. The purpose of this statement is to explain to you what personal information we collect and how we may use it. This policy explains our practices related to personal data privacy and security including:

• Types of personal information we collect;
• How we use the information;
• With whom we share it;
• Rights you may have about the use of your personal information;
• Security measures we implement to protect the security of your information; and
• How you can contact us about our privacy practices.

1. Information about us

Distributor Systems International Ltd is the data controller responsible for protecting personal information you provide to us.  We are registered in England and Wales under company number 02857022, our registered office address is at 10 Mulberry Court, Bourne Industrial Park, Crayford, Kent, DA1 4BF, United Kingdom.

We are registered with the Information Commissioners Office, reference A8306067. Our data protection officer is Paul Lyons. You can contact us via the address above, by telephone on 01322 520480 or dataprotection@dsiltd.co.uk

2. What is personal data

Personal data is information that can be used to detect your identity and includes your name, address, telephone number, and email address. Personal data are also information that can be associated with you, together with other information.

3. Collection of Personal Information

DSI collects and stores business contact information from or about you when you (i) interact with us; (ii) to fulfil your order; and/or (iii) to provide services to you.

The personal information DSI may collect or that you may choose to provide include:

• Contact information (such as name, postal or e-mail address, and phone number);
• Business contact information (such as job title, department and name of organization);
• Content you provide (such as emails, comments or other information provided via webforms);
• On occasion we may supplement the information we collect about you with outside records from third parties in order to provide you with information, services or goods you have requested, and to enhance our ability to serve you;
• Information you provide to third party service providers retained by us. Where you provide information to us in this way, you will be subject to the relevant service provider’s privacy policy. DSI is not responsible for how those site owners collect and handle your data.

In addition to information you choose to submit to us, we and our third party service providers may use a variety of technologies that automatically or passively collect certain information when you interact with us, this may include the browser and operating system you are using, the URL, the time of day you interacted with us, IP address, among other information (“Usage Information”). Usage Information may also include the unique identifier (“Device Identifier”), automatically assigned to any computer, mobile phone, tablet or other device used to access our website. Our servers identify your device by its Device Identifier.

DSI websites may also use cookies when you visit our websites. A cookie is a small piece of information sent to your computer, mobile or other device when you visit a website. Cookies are sent by a web server to a web browser, to enable the server to collect information from the browser and recognise your device on future visits. These types of files serve a number of different purposes such as: remembering your preferences; chosen items; assisting you to improve your site experience; and ensuring that the adverts or offers you see online are more relevant to you. The information we collect in this way may include:

• The home server domain names, type of computer, and type of web browser of users to the website;
• Aggregate and user-specific information on which pages users access.

Internet cookies can save data about individual users, such as your name, password, user-name, screen preferences, the pages of a site viewed by you, and the advertisements viewed or clicked by you. When you revisit the website, DSI may recognise you by the Internet cookie and customize your experience accordingly.

You may decline Internet cookies, if any, by using the appropriate feature of your Web client software, if available. However, declining to use cookies may impede the ability of the website to function properly. When you perform a search within the website, DSI may record information identifying you or linking you to the search performed. DSI may also record limited information associated with every search request made by you and use that information to, among other things, solve technical problems with the service and to calculate overall usage statistics.

4. Tracking

We may not respond to web browser “do not track” signals. If you would like additional information about online tracking and various opt-out mechanisms, please see https://allaboutdnt.com/

5. Use of Personal Information Collected

DSI may use Personal Information it collects from you or about you to:

• Establish, develop and preserve its business relationship respectively with you and other individuals with whom it deals,
• Create, establish and administer your accounts,
• Respond to your inquiries,
• Provide products or services that it offers, or receive the products or services that it requests, and ensure that all related transactions are supported and implemented,
• Authenticate the identity of customers contacting DSI by telephone, electronic means or otherwise,
• Meet legal and regulatory requirements;
• Allow us/our business partners who provide delivery fulfilment services to meet contractual requirements relating to the products and services provided to customers;
• Ask for feedback on our services and products;
• For research and analysis purposes to monitor and improve the services we provide including by recording your visits to our website. In these circumstances, we or our agents acting on our behalf, may contact you by email or telephone to ask you for your feedback and comments on our services; and
• Operate our business (including developing new products and services; conducting research; managing our communications; producing training materials and programmes; determining the effectiveness of and optimizing our advertising; analysing our products, services, and performing accounting, auditing, billing, and reconciliation activities)

DSI may also use Personal Information it collects for internal purposes, specifically, for:

• Solving technical problems,
• Calculating overall usage statistics,
• Marketing and promotional purposes, product development, and content improvement. Unless otherwise required by law, we already hold your contact information and believe there is a legitimate interest in our products and services, we will obtain your opt in consent before we send you communications related to marketing and promotion.
• We may also use aggregated information and statistics for the purposes of monitoring website usage in order to help us develop our websites and our services. We may provide such aggregated information to third parties, but these statistics will not include information that can be used to identify any individual. We will only keep personal information for as long as necessary to fulfill one or more of the purposes set out in this paragraph 3.

6. Disclosure of Personal Information

Except as provided in this policy, or as notified to you at the time we collect your information, DSI will not disclose your personal information to third parties except as follows:

• With companies within our Group
• With third parties service providers that perform services on our behalf, including without limitation, those that offer, host or operate our operation;
• To enforce our agreement with you;
• To analyse and enhance our communications and strategies (including by identifying when emails sent to you have been received, read and your location);
• Conduct web analytics to track use of our website. This information is shared with Google Analytics and stored on servers in the US. For more information on Google Analytics, please refer to Google’s privacy policy.
• To the extent: permitted by law; necessary to comply with applicable laws or legal processes; in connection with a merger, acquisition, or liquidation of DSI, in accordance with applicable laws; or to protect the rights or property of DSI. DSI will cooperate with law enforcement authorities.
• If data is disclosed to contractors during commissioned data processing they shall be subject to this policy, and, if applicable, to other additional or relevant alternative data privacy provisions and contractual conditions.

7. Rights regarding the processing of Personal Data

If you have provided us with personal data, we will keep your information in accordance with our retention policy. You may withdraw your consent to our processing by emailing us and we will apply your preferences in our future communications. If statutory retention periods require further provision, we will lock those records.

With your consent, we may share personal information with companies, organizations or individuals outside of DSI when we have your consent to do so. We require opt-in consent for the sharing of data. For example, we may provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. You may also email us to access information we hold about you, or to request rectification of any personal data we hold about you.

DSI will comply with anti-spam laws which apply in your jurisdiction. Moreover, users may at any time opt out of having their Personal Information used by DSI to send promotional correspondence to the user, by contacting DSI by email or postal mail at the address(es) below:

Email dataprotection@dsiltd.co.uk

Data Protection Officer, DSI Ltd, 10 Mulberry Court, Bourne Industrial Park, Crayford, Kent, DA1 4BF, United Kingdom.

For further information about your rights, please contact the Information Commissioner’s Office
or your local Citizens Advice Bureau.

8. Timescales for data subject requests

Data Subject Request Timescale
The right to be informed When data is collected (if supplied by data subject) or within one month (if not supplied by data subject)
The right of access One month
The right of rectification One month
The right to erasure Without undue delay
The right to restrict data processing Without undue delay
The right to data portability One month
The right to object On receipt of rejection
Rights in relation to automated decision making and profiling. Not specified

9. Collection of Personal Information from Children

DSI does not knowingly solicit information from children and we do not knowingly market the Website or its services to children. No one under the age of 16 should submit any Personal Information to DSI and/or the Website.

10. Cross-border Transfer of Personal Information

In some cases, Personal Information that we manage may be transferred, processed and stored outside of your country of residence, including the United States and therefore, your Personal Information may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions. Countries to which your Personal Information is transferred may not have the same data protection laws as the country of residence. When we transfer your information to other countries, we will protect Personal Information as described in this Global Privacy Policy. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area (“EEA”) or Switzerland.

11. Security of Data

The security of individuals’ personal information is important to DSI. We are committed to protecting the information we collect. We have put in place appropriate technical and organizational measures to protect the information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Steps We take to secure and protect your data include but not limited to:

• Encryption
• Firewalls
• Anonymisation
• Use of Pen testing Software
• Software vulnerability scanners

12. Updates to our Global Privacy Notice

Our Privacy Policy may change from time to time. We will post any privacy policy changes on this page.

13. Definitions

There is a total of 26 definitions listed within the GDPR, and it is not appropriate to reproduce
them all here. However, the most fundamental definitions with respect to this policy are as

Personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;”

‘processing’ means:

“any operation or set of operations which is performed on personal data or on sets of personal
data, whether or not by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction;”

‘controller’ means:

“the natural or legal person, public authority, agency or other body which, alone or jointly with
others, determines the purposes and means of the processing of personal data; where the
purposes and means of such processing are determined by Union or Member State law, the
controller or the specific criteria for its nomination may be provided for by Union or Member
State law;”

14. Contacting Us

If you have any questions about our website or this privacy policy, please contact us by email at
dataprotection@dsiltd.co.uk, by telephone on +44 1322 520480, or by post at, DSI Ltd, 10 Mulberry Court, Bourne Industrial Park, Crayford, Kent, DA1 4BF, United Kingdom.

Please ensure that your query is clear, particularly if it is a request for information about the
data we hold about you.