This document refers to personal data, which is defined as information concerning any living person (a natural person) that is not already in the public domain.
Doulos is pleased to provide the following Privacy Notice:
Personal Data and how we use it¶
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, email address. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
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How we use collected information
Doulos, may collect and use Users personal information for the following purposes:
To improve customer service: Information you provide helps us respond to your customer service requests and support needs more efficiently.
To personalize user experience: We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
To improve our Site: We may use feedback you provide to improve our products and services.
To run a promotion, contest, survey or other Site feature: To send Users information they agreed to receive about topics we think will be of interest to them.
To send periodic emails: Users may receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
How we protect your information¶
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Legal basis for processing any personal data¶
To meet Doulos’ contractual obligations to clients and to also respond to marketing enquiries.
Legitimate interests pursued by Doulos and/or its clients¶
To promote the marketing and consulting and training services offered by Doulos and/or to market the services and/or products offered by Doulos’ clients.
Through agreeing to this privacy notice and by using the Site, you are consenting to Doulos processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing DPO@doulos.com or writing to us, see last section for full contact details.
Doulos may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Doulos requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Some data is passed to parties situated outside the EEA. In this case Doulos will ensure they are part of the EU-US Privacy Shield (if a USA entity) or adhere fully to the requirements of GDPR.
Doulos do not broker or pass on information gained from your engagement without your consent. However, Doulos may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. Doulos may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Doulos, its clients and/or the wider community.
Doulos stores Personal Data only for as long as necessary for the purposes for which it was collected, to provide you with products or services, for legitimate business interests including audit and forensics purposes, and where required or permitted by law.
Data is held in the UK and in the USA using different servers. The data held in the USA conforms to the full requirements of GDPR. Data stored in the cloud will be with GDPR compliant suppliers.
Backups of the EDA Playground database are kept for up to 15 calendar months. Therefore, anything deleted from the database will remain in backed up data for this period. Anonymised records are kept of any deletions so that they can be re-deleted in the event of a restoration from backed up data.
Your rights as a data subject¶
At any point whilst Doulos is in possession of or processing your personal data, all data subjects have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing. See The Doulos Opt-Out Policy
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Doulos refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Doulos at your request can confirm what information it holds about you and how it is processed
You can request the following information:¶
Identity and the contact details of the person or organisation (Doulos) that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Doulos or a third party such as one of its clients, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (Data Protection Regulator).
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required¶
Doulos will accept the following forms of ID when information on your personal data is requested: a photocopy or scanned image of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Doulos is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to email@example.com or by writing to us at the address further below.
Changes to this policy¶
In the event that you wish to make a compliant about how your personal data is being processed by Doulos or its partners, you have the right to complain to Doulos’ CEO. If you do not get a response within 30 days you can complain to the Data Protection Regulator.
The details for each of these contacts are:
Doulos, attention of the CEO 22 Market Place, Ringwood, Hampshire, BH24 1AW Telephone +44 1425 471223 or email firstname.lastname@example.org
Data Protection Regulator (ICO) Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Telephone: +44 303 123 1113 or online messaging: https://ico.org.uk/global/contact-us/email Or email: email@example.com
This document was last updated on 11 May 2020