This is the Privacy & Cookies Policy (the ‘Policy’) of Ditto Sustainability Limited, company number 06863577 of Ditto Sustainability Limited, c/o Hansel Henson Limited, 3rd Floor, 8 Bloomsbury Street, London, WC1B 3SR (hereafter ‘Ditto’, ‘we’ or ‘us’). This Policy describes the ways in which Ditto collects and uses information about you when you use our website rio.ai (the “Website”), or register an account on one or more of our platforms whereby we (in accordance with our Terms of Service) grant you a licence to access certain learning content in relation to sustainability on such platform (each a “Platform”).
Ditto may change this Policy at any time in which case we shall notify you of any changes to this Policy by noting this on the Platform and/or the Website (as applicable). The changes will apply to your use of the Platform and/or the Website (as applicable) after we have given notice. If you do not wish to accept the new Policy you should not continue to use the Platform and/or the Website (as applicable). If you continue to use the Platform and/or the Website (as applicable) after the date on which the change comes into effect, your use of the Platform and/or the Website (as applicable) indicates your agreement to be bound by the new Policy.
This Policy was last changed on 23 October 2020.
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- ICO registration: For the purposes of data protection legislation, Ditto is the controller for the processing of your personal data. Ditto has notified the Information Commissioner’s Office (“ICO”) of its processing of personal data. The notification indicates what data is processed by Ditto and for what purpose, and to which persons or entities the data will be provided. Click here to consult the notification in the public register of the ICO. Ditto’s registration number is ZA012204.
- Information which is collected when you access and use a Platform or when you use the Website: Ditto may collect the following information from you when you access and use a Platform or when you use the Website (as applicable)
- any information which you choose to submit via the Website in order to contact Ditto about a particular request, namely your name, company name, telephone number, e-mail address, job title, Twitter username and LinkedIn link;
- any information which you enter into the Platform when creating an account, specifically your name, company address, e-mail address, mobile phone number, company name and company division in which you work;
- if you choose to submit it, certain information that you provide to Ditto when using a particular Platform i.e., user-generated content.
- Other information collected by Ditto: Ditto may also, on an ad-hoc basis, collect information relating to prospective clients such as name, telephone number and e-mail address. This data may be obtained in person by e.g., face-to-face meetings at roadshows or other networking events, by Ditto’s own internal research, as well as via use of third parties. Ditto only collects this data for use in a business to business capacity and only from targeted users who Ditto believes will benefit from Ditto’s service or to identify partners who could help Ditto develop content. It is only used to connect with such clients on a professional or B2B marketing basis.
- How the information collected about you listed in Clauses 2 and 3 above is used by Ditto: The information about you described in Clauses 2 and 3 may be used by Ditto as follows:
- the information in 2(a) is used by Ditto to process your particular contact request e.g., to answer any questions you have about Ditto’s products and/or services;
- the information in 2(b) to 2(d) is used to provide the features and content of a particular Platform to you, and, in the case of 2(c), the Website too. Ditto uses the information in 2(b) to verify your identity and allow you to register as a Platform user, the information in 2(c) to carry out various administrative tasks on both the Platforms and the Website and the information in 2(d) to allow a user to participate in a particular learning, compliance or data management experience and to generate reports such as a user's individual learning record as a result;
- the information in Clause 3 is used to create a list of targeted users whom Ditto believes will benefit from its services and to contact those users on a professional/sales basis;
- your e-mail address may be used (subject to you having provided your express consent when registering or us otherwise being permitted to do so in accordance with applicable data protection and direct marketing legislation) to send e-newsletters relating to our latest developments and events, links to content that we think you will like, promotional offers, discounts and loyalty rewards. You can opt-out of this use of your e-mail address at any time by clicking “unsubscribe” within the e-mail or e-mailing firstname.lastname@example.org with the subject heading “UNSUBSCRIBE”; and
- all of the information set out in Clauses 2 and 3 is shared with third parties as described in Clause 6 below.
- Grounds for processing: Ditto relies on the following processing grounds:
- for the information in 2(a), consent, as it is your choice as to whether to submit a contact us request to us or not;
- for the information in 2(b), contractual necessity as Ditto requires all of this information to be able to verify your identity and create an account for you in order to allow you to access and use a particular Platform;
- for the information in 2(d), consent, as it is your choice as to whether to submit any user-generated content or not; and
- for the information in 3, consent where you choose to provide such data to Ditto e.g., when meeting a Ditto representative face-to-face and e.g., handing over your business card, and legitimate interests in all other situations. It is in Ditto’s legitimate interests to collect such items of personal data because Ditto wishes to contact the client/supplier in question in order to be able to market its Platforms and/or improve and build upon its existing Platforms and this doesn’t outweigh the rights/freedoms of the data subject in doing so, especially as, once contacted, a data subject can request not to be contacted again immediately and the data is limited to business card type data i.e., it is not particularly sensitive.
Ditto also relies on consent to send newsletters to an individual acting in a non-business capacity as it will only send such newsletters where an individual has expressly opted-in to do so.
- Sharing information with third parties: Ditto shall not pass your information to any third party (other than as described in this clause). Your information may, subject to Ditto’s obligations to comply with applicable data protection legislation, be shared with the following third parties:
- its Platform/Website hosting service providers, including AWS, Microsoft and UK Fast;
- its affiliates, including Ditto AI Limited;
- its and its affiliates development teams and their associated mobile devices and office accounts such as Slack, Office 365 and Asana
- for the information in 2(b), storage providers such as HubSpot;
- Atlassian in relation to any support related requests submitted by clients;
- SurveyMonkey in relation to survey information on online learning evaluation;
- DocParser in relation to any optical character reading required to read utility bills;
- Landbot in relation to hosting chatbot services;
- if you wish to receive e-mail newsletters/marketing information, your name and e-mail address with HubSpot to carry out such marketing campaigns;
- having taken precautions to maintain the security of such information, Ditto may share this information with its regulator (the ICO);
- in anonymised form, Ditto may share the information with:
- any third party, in relation to the sale of some or all of Ditto’s business, or its assets, or as part of any business restructuring or reorganisation. Ditto will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this clause;
- data aggregators and platform providers as part of an analysis of user metrics or sales performance; or
- law enforcement agencies in compliance with law enforcement.
- Links to third party websites and third party adverts: Ditto is not responsible for the privacy policies and practices of other sites even if you access them via a Platform or the Website (as applicable). You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to your account from a third party site or via a social network, Ditto is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
- Security: Ditto has implemented technology and policies to safeguard your privacy from unauthorised access and improper use. You may also change your account settings on your social networks to prevent both us and third parties seeing information in relation to you.
- Storage and Data Retention: We store your personal data in the EEA and we retain your personal data for as long as you have an active account with us, or, in the case of the information submitted in Clause 2(a), until that query is resolved and in the case of the information in Clause 3 such information will be deleted once the lead has been followed-up to establish whether the client/supplier is interested in working with Ditto and, in any event, will not be held for longer than 6 months if a lead is not delivering. We will delete or anonymise your personal data within 6 months after the date on which you terminate your account/your query is resolved (as applicable) or, if no such termination occurs, 18-months after your last account access i.e., after a 18-month period of inactivity. You can close your account at any time by following the instructions supplied via your account.
- Disabling Cookies: The use of the cookies described above improves the functionality of the particular Platform and/or the Website (as applicable) and your experience of using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings within the Platform and/or on the Website (as applicable) or on your device. Please note that if you do decide to disable cookies you may not be able to access some of the Platform and/or the Website (as applicable), and some of the features of the Platform and/or the Website (as applicable) may not function properly.
- More information: To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org.
||Ditto uses persistent cookies and session cookies to, for example, assist in the navigation around the Website, to enhance your use of the Website and to support graphic and video features.
||Ditto uses Google Analytics cookies to collect information about how visitors use the Website, which Ditto uses in turn to help improve its services. These cookies collect information in an anonymous form, including the number of Website users, where users are located when using the Website and the parts of the Website they visit.
||These are used to track certain user behaviour when using the Website.
||Ditto uses a session authentication cookie to grant access to the platform. These cookies are granted to a user following a successful login attempt. Ditto also uses persistent cookies and session cookies to, for example, assist in the navigation around the Platform, to enhance your use of the Platform and to support graphic and video features.
||Ditto uses Google Analytics cookies to collect information about how visitors use the Platform, which Ditto uses in turn to help improve its services. These cookies collect information in an anonymous form, including the number of Platform users, where users are located when using the Platform and the parts of the Platform they visit.
||These are used to track certain user behaviour when using the Website.
- Exercising your rights: You can contact us using the details set out in Clause 12 below if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data.
- Ditto Details: If at any time you would like to contact Ditto about your views on this Policy or any enquiry relating to your personal information, you can do so by sending an e-mail to us at email@example.com or write to us at “Data Protection Query, Ditto Sustainability Limited, c/o Hansel Henson Limited, 3rd Floor, 8 Bloomsbury Street, London, WC1B 3SR”. You also have the right to make a complaint to the ICO by contacting them at any time.