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Privacy Policy

Introduction
Dalau Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy policy
This privacy policy aims to give you information on how Dalau collects and processes your personal data through your use of this website, including any data you may provide through this website when you submit an enquiry or make contact through our online contact form.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.


Controller

Dalau is made up of different legal entities, details of which can be found here This privacy policy is issued on behalf of the Dalau Group, so when we mention “Dalau”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Dalau Group responsible for processing your data. Dalau Limited is the controller and responsible for this website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the privacy manager using the details set out below:

• Full name of legal entity: Dalau Limited
• Email address: rajen.panchal@dalau.com
• Postal address: Ford Road, Clacton-On-Sea, Essex, CO15 3DZ
• Telephone number: +44 (0)1255 220220

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 10/02/2022. Historic versions (if any) can be obtained by contacting us.
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.


Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which is obtained through the use of this website, which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, and gender.
  • Contact Data includes email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your 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 this website.
  • Profile Data includes any feedback you provide to us in your online submissions to us.
  • Usage Data includes information about how you use our website (via Google Analytics), products and services.
  • Marketing and Communications Data includes your requests for receiving marketing from us and our third parties and any of your communication preferences notified by you to us.

We may also use, store and transfer other kinds of personal data about you which you voluntarily provide to us by post, phone or email request and contact, or otherwise, which may include the following groupings:

  • Financial Data including bank account and payment card details.
  • Transaction Data including details about payments to and from you and other details of products and services you have purchased from us.


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not request or seek to collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we request or collect any information about criminal convictions and offences.


If you fail to provide personal data
Where we need to collect personal data by law, or in connection with any contact or request you submit to us, or under any contract we have with you, and you fail to provide the data required or when requested, we may not be able to respond to your contact or request or perform any contract we might have or try to have with you. In this case, we may not be able to respond to you, or we may have to cancel or not enter into a contract with you (in which case, we would notify you).

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data and Contact Data and Financial Data and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • request marketing to be sent to you; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy here for further details.
  • Third parties or publicly available sources. We will collect and receive personal data about you and the usage of our website from analytics providers such as Google Analytics via Google based outside of the UK.  

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • where we need to comply with a legal obligation; and
  • where we need to respond to your online contact or request, or to perform any contract we have or are about to enter into with you.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.


Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.


Note that 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 where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestData retention period
To manage our relationship with you which will include using your Contact Data to respond to your contact or request in connection with our products or services  (a) Identity (b) Contact (c) Profile (d) Marketing and Communications(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)One year


To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) TechnicalNecessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)  One year
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youIdentity Contact Profile Usage Marketing and   CommunicationsTechnicalNecessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)Identity / contact /  profile: one year Usage and technical: seven days. Google Analytics: six months
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical (b) UsageNecessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)Server access logs: removed after 7 days Google Analytics: retains historical analytical data for 6 months
To register or process you as a new customer(a) Identity (b) ContactPerformance of a contract with youOne year
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)One year
To make suggestions and recommendations to you about our products or services in connection with any contact or request you may make to us(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing & CommunicationsNecessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)Identity / contact / profile / Marketing & Communications: one year Usage and technical: seven days Google Analytics: six months

Marketing and offers

We may strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you, in connection with any contact or request made by you to us. This may help us to decide which products or services may be relevant for you.
You may receive marketing communications from us from time to time if you have requested information from us, or purchased products or services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

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 more information about the cookies we use, please see our cookie policy here.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary here.
  • External Third Parties as set out in the Glossary here.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the Dalau Group. This may involve transferring your data outside the UK. In addition, some of our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.


Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data Security

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.


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.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


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, regulatory, tax, accounting or other requirements.


Details of retention periods for different aspects of your personal data are set out in the table here.
In some circumstances you can ask us to delete your data: see here for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please our privacy manager.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.


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. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

  • LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you our best service/product and a secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.

  • THIRD PARTIES

Internal Third Parties

Other companies and representatives in the Dalau Group and who are based in Germany, the United States.

External Third Parties

  • Service providers based in the UK who provide IT and system administration services.
  • Service providers based in the UK and outside of the UK who provide freight forwarding, courier and delivery services in connection with the products we provide to you.
  • Professional advisers including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the UK who require reporting activities in certain circumstances.
  • YOUR LEGAL RIGHTS

You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time 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. We will advise you if this is the case at the time you withdraw your consent.