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We want you to be fully informed about your rights, and how Drum Cussac uses your data; for example we will cover things such as your platform user profile, any financial transactions and our interactions with travel management companies and security providers on your behalf.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
2. What is Drum Cussac Group Limited?
For simplicity throughout this policy, ‘we’ and ‘us’ means Drum Cussac and its brands.
Drum Cussac complies with the General Data Protection Regulation (GDPR) and for the purposes of this Policy, the Accountability principle under Article 5 of GDPR, which establishes responsibility for, and demonstrating compliance with, the GDPR primarily for Data Controllers. However, Drum Cussac undertakes to adopt this principle as a Data Processor for our Clients (the Data Controller).
In compliance with the Privacy Shield Principles, Drum Cussac 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 Drum Cussac at:
Data Protection Officer, Drum Cussac Group Limited, Avalon, 26-32 Oxford Road, Bournemouth BH8 8EZ, or email email@example.com.
Drum Cussac 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 in the context of a contractual relationship.
4. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box online to receive specific product or service information, intelligence and analysis whitepapers or by email response for direct marketing services.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if your employer’s travel management company provides us with your travel itinerary, we’ll process those details to ensure you receive our travel risk management technological services during your trip.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we can use your personal data to request customer feedback or marketing surveys to help us improve our products and services.
5. When do we collect your personal data?
6. What sort of personal data do we collect?
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of legal and financial transactions we make, brands you show interest in, and how and when you contact us.
We’ll only ask for and use your personal data collected for delivering the services we are contractually obliged to do, recommending products and services of interest and to improve your browsing and internet interactions with us. Of course, it’s always your choice whether you share such details with us.
7. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you products and services that are most relevant to you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for or we are contractually obliged to deliver.
Here’s how we’ll use your personal data and why:
For example, your details may need to be passed to a third party to process a payment or supply a service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as a refund.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
Of course, you are free to opt out of hearing from us by all or any of these channels at any time.
For example, updates to product or service release notices and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
Of course, you are free to opt out of receiving these requests from us at any time by notifying our Data Protection Officer at firstname.lastname@example.org
8. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across Drum Cussac as described above. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the publicly available data lists mentioned above.
9. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to our websites and apps using ‘https’ technology and access to your personal data is password-protected, and secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
10. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
An example data retention period:
When you place an order by contractual agreement, we’ll keep the personal data you give us for seven years so we can comply fully with our legal and contractual obligations.
In the event of contract termination we’ll completely delete the personal data (or anonymise it as described above) after 30 days, or by contractually agreed data retention period.
11. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, payment transaction providers, security service providers, for fraud management, to handle complaints, to host our technology services and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
Examples of the kind of third parties we work with are:
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
For example, if you enter a competition and tick a box agreeing that Drum Cussac or a partner direct marketing company can send you promotional information directly. Or if we run a joint event with a partner direct marketing company, and you agree to receive direct communications from them.
12. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to Drum Cussac in the UK.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data sub-processors in countries that are outside the EEA.
For example, this might be required in order to provide in-country security support services during your travel, or airline and hotel services in evacuating you to safety.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
13. What are your rights over your personal data and how do I exercise them?
An overview of your different rights
You have the right to request:
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a contract’s retention period).
You have the right to request a copy of any information about you that Drum Cussac holds at any time and also to have that information corrected if it is inaccurate.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
14. How can you stop the use of your personal data for direct marketing?
There are the ways you can stop direct marketing communications from us:
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
15. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint in the UK with the Information Commissioner’s Office.
You can contact them by calling +44 (0) 303 123 1113 or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites).
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
16. If you live outside the UK
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in or outside of the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and backup servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
17. Any questions?
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us at email@example.com
Or write to us at Data Protection Officer, Drum Cussac Group Limited, Avalon, 26-32 Oxford Road, Bournemouth BH8 8EZ
This policy was last updated on 01/01/2019
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