Thank you for trusting us with some information about you. We take that trust seriously and we want
you to know how we use your information and why. If you have queries about how we use your data, or comments or questions about this policy, please do email us at: firstname.lastname@example.org
Policy updates: We keep this policy under regular review, and this page may be updated from time to time. Please come back here to check the latest version. This policy was last updated on the date given at the end of this document. We promise respectful treatment of the personal information of everyone we have contact with.
We want it to be simple and clear and this policy explains: when and why we collect information, how we use it, the situations when other people can see or use it, and how we keep it secure. We do not sell, rent or trade your contact details or email lists with anyone else.
We are committed to protecting your privacy, and honouring your legal rights to control how we use your personal data. We only collect and use personal data when we need to so that we can.
- Reply to queries or complaints
- Develop and manage our business relationships
- Provide services to clients
- Meet our legal obligations
2. Who are we?
We are Dolphin N2 Ltd, a company registered in England (company number 10739616) and our registered is shown below. We have been in business since 2017. Our directors are Thomas Gutwald and Simon Brewster.
DOLPHIN N2 LTD
OLD SHOREHAM ROAD
SHOREHAM BY SEA
3. Words with specific meanings
In this policy, there are words and phrases that have a specific meaning or that we are using in a special way.
- “personal data”: any information about an identifiable living human being.
- “process” : we “process” your personal data when we do anything with it, which
might include: collecting, recording, organising, storing, adapting,
altering, retrieving, using, combining, disclosing, or deleting it.
- “special category data” : personal data revealing racial or ethnic origin, political opinions, religious
or philosophical beliefs, trade union membership, sex life or sexual orientation, health, genetic or biometric data.
4. What this policy describes
This policy describes how we will collect and use personal data about you.
We process information about:
- “Prospects” : potential customers or referrers;
- “Customers”: who have bought goods or services from us;
- “Suppliers”, “ associates” :suppliers or potential suppliers of goods or services to us;
- “Investors” : if you have expressed an interest in the company in terms of
collaboration or investment ;
- “ Affiliates”: who have signed up to our affiliate scheme (if we have one in the future).
5. What information do we process, and WHY?
Most of the information we process comes from you. We process it so we can reply to you, and when you contact us again we know what you asked before, what you were sent, and what you told us. Typically, we are collecting name, contact details, how we came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in our products or services or a relevant contact for our business.
If you sign up to a newsletter list, you will be sent what you asked for. We normally operate ‘double opt-in’ lists and you will need to reconfirm your subscription before anything is sent. You can unsubscribe at any time by clicking the unsubscribe button on any email.
You are not automatically subscribed to any other lists, but may be invited to join an appropriate one. If we email you individually using our own email system, or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored.
If you make an enquiry via our website, we will keep details of that enquiry and response for our data retention period of three years.
We do not intentionally collect special category data since it has no impact on the working relationship. This data would only be associated with your contact details if you have supplied this voluntarily.
Once you buy something from us, we will collect information from you at the point of sale.
This will include the information we collect from “Prospects”. We collect your email address, phone number and postal address so that we can provide what we have contracted to do, to invoice you and to keep proper records of our business relationship.
We process your data to support the delivery the goods and services you have bought. We keep records of the goods/services provided to you, and information you give us, so we can support you when needed and advise you of any additional services you may need.
Financial and credit card details: We do not currently process any financial transactions involving credit card payments.
Supplier and Associates
We collect information on potential and actual suppliers and associates.
If you become a supplier or associate we keep a copy of the contract between us and your bank details so that we can pay you. We also keep a record of invoices/payments for accounting purposes.
We keep a record of the work you undertook for us/our clients along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution. This information is all needed to manage our customer relationships and our supply chain.
Most of the information we process comes from you. We process it so that we can reply to you and when you contact us again we know what you asked before, what you were sent, and what you told us. Typically, we are collecting name, contact details, how we came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in our products or services or a relevant contact for our business.
If you express an interest in the company in terms of collaboration or investment we will keep you updated of news and progress via email, we will keep your contact details on record but only engage in detailed conversation after a non-disclosure agreement (NDA) – the details that we hold on you, from that point are subject to the conditions of the NDA
If we set up an affiliate scheme, affiliate data will be held in accordance with this policy. We will ask you for information when you apply and that will be kept to administer the affiliate scheme.
6. Data sharing – 3rd parties
We do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes.
Newsletters and Automated emails
We do not currently distribute a newsletter or any automated emails.
We keep a list of the software platforms we use to run our business. If you would like a list of all the platforms we use, please email us email@example.com
We have an outsourced support team for our own business which may include Virtual Assistants, Web Designers, IT support, Sales and Marketing, Accounting and more. They have limited access to your data,where the service they provide to us means they need it.
If our IT support wants to check the functionality of a laptop or back up, they may need temporary access to information that may include something about you.
For example, if we invoice you, our Accountant needs to process the information in the invoice.
Your information/advice is held in the strictest confidence. Our team are all contracted to strict confidentiality clauses.
7. Where is your data located and for how long?
Like most small businesses, we do not have any tailor-made software – we use mainstream packages for everything from our customer records, to email, to accounting. This means that some of your data may be held in the EEA, and some may be held in services in the USA (with suitable data privacy shields) or elsewhere. We have picked mainstream suppliers with appropriate security standards.
Your information will be kept for three years from our last contact.
We need to keep customer information long enough to satisfy HMRC and our insurers. We keep information on prospective customers long enough to make our sales enquiry system effective.
If you subscribed to a newsletter or updates list, you will remain on the list(s) you joined until you unsubscribe from that list.
You have the right to know what information we are collecting on you, and to amend it if it is inaccurate. If you feel for some reason we have information we should not be keeping, or it is out of date or otherwise wrong, please let us know and we will take appropriate action.
Most of the information we hold is not based on your individual consent but is based on our needing the information to run our business and provide our products and services. If you want to know what information we have about you (if any) email us at firstname.lastname@example.org and
give us your name, email address(es) and we will happily do a search and let you know what information we hold on you and how we are using it/have used it.
You have a “right to be forgotten” – but that does have some legal limits to it. If you want us to remove information about you, let us know. If you have been a customer, we may not be able to remove all data as we will have to ensure that we can continue to comply with legal, accounting, taxation and our insurer’s require
If you have a complaint about the way we are handling your information or how we have responded to a request for information or removal, you can take this up in the first instance by emailing us at email@example.com
DOLPHIN N2 LTD
OLD SHOREHAM ROAD
SHOREHAM BY SEA
If we can’t sort it out, the relevant supervisory authority for us is the Information Commissioner for the
This Policy was last updated: 12th February 2019