Privacy Policy

DormFresh Limited

INTRODUCTION
1. This privacy notice is issued on behalf of DormFresh Limited ("we", "us" or "our"), a company incorporated under the Companies Acts with registered number SC209329 and having its registered office at Algo Business Centre, Glenearn Road, Perth, Scotland, PH2 0NJ.
2. We are a data controller of any personal data that you provide us. This means that we are responsible for deciding how we hold and use personal information about you.
3. This privacy notice will inform you about what data we collect from you, how we use it, circumstances where we may disclose this data to others and how we keep it secure.
4. In this policy, “Data Protection Legislation” means all applicable legislation which relates to the use, protection and privacy of personal data and the privacy of electronic communications, including, but not limited to the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018.
5. Any questions relating to this policy and our privacy practices should be sent to us using the
  contact details set out below.
HOW WE COLLECT INFORMATION FROM YOU
1. We collect and process your personal information in the following ways:
  • Off-Line Data: you may give us information by corresponding with us by mail, text, e-mail,
  (or other form of electronic communication), telephone or in person. This includes when you:
  − contact us as part of a business transaction;
  − raise an enquiry;
  − indicate your interest in our products or services;
  − purchase our products or services;
  − sell a product or services to us;
  − give us feedback;
  − from your usage of the Site and any other information you post on the Site; and
  − complete one of our surveys or respond to requests for information.
  • Website Data: you may give us information about you via our website. This may include information you provide when you:
  − contact us via the website;
  − indicate your interest in our products or services;
  − give us some feedback;
  − request marketing to be sent to you;
  − complete one of our surveys or respond to requests for information;
  − subscribe to our service or publications; and
  − from your usage of the website and any other information you post on the Site;
  • We may also receive personal data about you from various third parties and public sources.
2. Our services are not intended for children and we do not knowingly collect data relating to children.
3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices, including our website privacy notice, and is not intended to override them.
WHAT INFORMATION WE COLLECT
1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  • Identity Data: includes first name, maiden name, last name, username or similar identifier,
  marital status, title, date of birth and gender;
  • Transaction Data includes details about payments to and from you and other details of
  products and services you have purchased from us on behalf of your organisation;
  • Contact Data: includes address, email address and telephone numbers;
  • Financial Data: may include bank account and payment card details;
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences; and
  • Website Data:
  − Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
  − Usage Data: includes information about how you use our website; and
  − Profile Data: includes your username and password, searches made by you, your interests, preferences, feedback and survey responses.
WHY WE NEED THIS INFORMATION ABOUT YOU
1. We use the information we collect about you:
  • to provide you with information, services and/or products you have requested;
  • to help us improve our service and understand more about how our website is used;
  • to assist our surveys and data analysis;
  • to be able to send you communications that may be of interest to you (such as details of our products and services), either electronically, by email, by text or otherwise; and
  • to respond to your queries.
2. We will only process your personal data when we have legal grounds to do so. Most commonly, we will rely on one of the following legal bases:
  • to enable us to perform the contract we have entered with you, including provision of the services;
  • if required to comply with a legal or regulatory obligation;
  • if necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • if needed to protect your interests (or someone else's interests).
3. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
4. We usually do not rely on consent as a legal basis for processing your personal data other than: (i) in relation to sending direct marketing communications to you via email or text message or (ii) where you engage with us in responding to our surveys. You have the right to withdraw consent at any time by contacting us.
DATA SECURITY
1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DISCLOSURE OF PERSONAL DATA
1. The information you provide to us will be treated by us as confidential. However, we may disclose your information to other third parties who act for us for the purposes set out below or for any additional purposes approved by you:
  • Group Companies: 1,4GROUP, Inc. which is a DormFresh group company based in the US;
  • ervice Providers: service providers who provide IT and systems administration services;
  • Professional Advisors: professional advisors, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accountancy services;
  • Authorities: HMRC, regulators and other authorities; and
  • Joint Venture Parties and Successors: if our organisation enters into a joint venture with or is sold to or merged with another organisation, your information may be disclosed to our new business partners or owners.
2. We require all third parties to respect the security of your personal data and to treat it in accordance with Data Protection Legislation.
TRANSFERS OUTSIDE THE EEA
1. We may transfer your personal data to 1,4GROUP, Inc which is a DormFresh group company based in the US.
2. Some of the third parties we work with (as detailed in Clause 6.1 above) are based outside of< the United Kingdom (UK) and/or the European Economic Area (EEA), so your personal data may be transferred outside of the UK and/or the EEA (as appropriate).
3. Whenever we transfer your personal data out of the UK and/or the EEA (as appropriate), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (Please click here for further information);
  • 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 (Please click here for further information); and/or
HOW LONG WE WILL KEEP YOUR INFORMATION
1. We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
2. 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.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For further information, please see our website www.dormfresh.co.uk for further information.
THIRD PARTY WEBSITES
Because we want your experience of our website to be as informative and useful as possible, we may provide links to websites operated by third parties (“Third Party Websites”). Please be aware that we do not control such Third Party Websites and that such Third Party Websites may send their own cookies to users, or otherwise collect data or solicit personal information. We assume no responsibility for the information gathering practices of Third Party Websites that you are able to access through our Site, and we encourage you to review each Third Party Website’s privacy policy before disclosing any personally identifiable information.
YOUR RIGHTS
1. Under Data Protection Legislation, you have the following rights in connection with your personal data, which can be exercised in certain circumstances:
  • Right of access: you can request a copy of the personal information we hold about you and check we are processing it lawfully;
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check we are lawfully processing it;
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes;
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
  • Request the transfer of your personal information to another party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format;
  and
  • Withdraw your consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
2. If you would like to exercise any of your rights above, please contact us at info@dormfresh.co.uk.
3. You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues relating to our use of your information.
CHANGES TO OUR PRIVACY POLICY
1. We keep our privacy policy under regular review. This version was last updated in January 2021.
2. Any changes we make to our privacy policy in the future will be posted on the website.
YOUR DUTY TO INFORM US
1. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
CONTACT US
We have appointed Suzette Clarke as our Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:

Name: Dr Bernhard Frings, CEO
Email address: bfrings@dormfresh.co.uk
Postal address: DormFresh Limited, Algo Business Centre, Glenearn Road, Perth, PH2 0NJ
Telephone number: 00 44 (0) 1738 633 859