Dasein Privacy Policy

This Privacy Policy (“Policy”) applies whenever Dasein Privacy Limited (referred to in this Policy as “Dasein”, “we” or “us”) processes any personal information about you – for example, by collecting it, using it, storing it, or disclosing it to others. It describes how and why we process your personal information, and what rights you can exercise in respect of your personal information.

Dasein is a company registered in England and Wales (company registration number 13984488). Our registered office is at 80 Ashton Road, Denton, Manchester, Lancashire, UK, M34 3JF. Dasein is registered as a data controller with the Information Commissioner’s Office (ICO), and our registration number is ZB331620.

If you have any questions concerning Dasein’s processing of your personal information, wish to exercise any of your data protection rights, or otherwise wish to raise a data protection concern with us, please contact us by sending an email to [email protected].

Dasein collect and process the following categories of personal information for the following reasons:

 

Clients and prospects - we process name, contact details, financial information (e.g. payment details), the nature of services required, and any other contextual information the client provides for the purposes of contracting with us (which may include personal data relating to third parties). Clients may need (or choose) to provide us with personal information that is considered “sensitive” or “special category data” under applicable data protection laws for the purpose of obtaining consultancy services (such as personal information relating to an individual’s health, race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, genetic data or biometric data).

Why: We use this to contact individuals who may wish to work with Dasein, and to contract with our clients. If individuals subscribe to marketing communications from Dasein, we may also use their contact details to send those marketing communications.

Lawful basis under EU/UK GDPR: When we process information to provide our services - legal obligations and legitimate interests. Where we process sensitve to provide our services we will do so only where permitted by data protection law – for example where the processing is necessary for the exercise, establishment or defence of legal claims, or with explicit consent. When we process this personal information for the purpose of sending marketing communications, consent.

 

Website visitors - our website servers may automatically receive certain information about your device, including your IP address, browser type, device type and similar technical information.

Why: We use this information to ensure our website is rendered correctly to you. We do not collect website analytics or engage in targeted advertising.

Lawful basis under EU/UK GDPR: When we process this information for the purpose of rendering our website correctly, legitimate interests.

 

Business partners and other third parties: Dasein works with vendors and other contacts to operate its services. Additionally clients may disclose information about third parties when working with Dasein. The specific personal information that Dasein receives is determined solely by the client, and may include personal information that is deemed “sensitive” or “special category data” under applicable data protection laws.

Why: We use this to operate our services and provide services to our clients.

Lawful basis under EU/UK GDPR: When we process information to provide our services - legal obligations and legitimate interests. Where we process sensitve to provide our services we will do so only where permitted by data protection law – for example where the processing is necessary for the exercise, establishment or defence of legal claims, or with explicit consent.

We may disclose the personal information we process:

  • to third parties who provide services on our behalf, such as IT hosting providers, email providers and data backup providers, subject to strict contractual terms that protect the personal information in accordance with data protection law;
  • to any competent law enforcement, judicial or regulatory authority if we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy; and
  • to any other person if the relevant data subject(s) have consented.

Although Dasein is registered limited company in UK, some of the service providers we use may be based in countries that are outside the United Kingdom and European Economic Area. This means that the personal information Dasein processes may, in some cases, be transferred to and processed in non-UK and non-EEA countries by our service providers.

 

Where we can, we will use service providers established in countries that are recognised as having adequate data protection laws (by the competent UK and EU authorities). However where this is not possible, then we implement appropriate safeguards with our service providers in accordance with the requirements of data protection law. These may include using the International Data Transfer Addendum or International Data Transfer Agreement (issued by the UK Information Commissioner) and the EU Standard Contractual Clauses (adopted by the European Commission).

We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by sending an email to [email protected];
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us by email at [email protected];
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you. Dasein does not ordinarily undertake any such automated decisions.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or email [email protected];
  • Where processing your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; and
  • You have the right to lodge a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for the ICO, the UK’s data protection authority, are available here. Contact details for data protection authorities in the European Economic Area, are available here.)

We have instructed our website provider not to serve any cookies or similar tracking technologies through our website unless they are strictly necessary to deliver the site – meaning we don’t use cookies for analytics, advertising or otherwise – and so do not display a cookie notice.

We may update this Policy from time to time in response to legal, technical or business developments. When we update our Policy, we will take appropriate measures to inform you, which will be consistent with the significance of the changes we make.

You can see when this Policy was last updated by checking the “last updated” date displayed at the end of this Policy.

 

Last updated: 29 January 2024