PRIVACY POLICY

Introduction

This privacy policy sets out how the Duco Group, as defined below, uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. TYPES OF PERSONAL 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. CONTACT DETAILS

11. COMPLAINTS

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

13. THIRD PARTY LINKS

14. CALIFORNIA PRIVACY RIGHTS SUPPLEMENT

15. CANADA PRIVACY RIGHTS SUPPLEMENT

16. GLOSSARY

1. Important information and who we are

Privacy policy

Duco deals with highly sensitive data as a matter of course in our day-to-day business, and as a company we consider data protection and privacy to be of paramount importance.

When you interact with us there are certain situations where we will collect and store various types of data about you and/or your activity on our website and in the provision of the Duco service. The purpose of this policy is to identify what, when, and how this data is collected, and your rights in relation to this data.

We never share, sell, rent, or trade personal data with third parties for their promotional purposes and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation 2016/679 (GDPR), the UK Data Protection Act 2018 (DPA), and other data privacy laws and regulations as further detailed below.

We may update this policy from time to time and notify you in accordance with applicable law. The latest version will govern our practices for collecting, processing, and disclosing the data we collect.

This privacy policy gives you information about how Duco collects and uses your personal data through your use of this website, including any data you may provide when you order a service from us or use our services or sign up to our newsletter.

Controller

The Duco Group is made up of different legal entities, including Duco Technology Limited (UK entity), Duco Technology Inc. (US entity), Duco Technology BV (Belgium entity), Duco Technology Poland sp. zo.o. (Polish entity) and Duco Technology PTE. Limited (Singapore entity). This privacy policy is issued on behalf of the Duco Group so when we mention “Duco”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Duco Group responsible for processing your data. We will let you know which entity will be the controller or processor for your data when you order a service with us. Duco Technology Limited is the controller and responsible for this website.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (9), please contact us using the information set out in the contact details section (10).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified. 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, job title or similar identifier when you use our service.

Contact Data (collected only for certain clients of our services, potential clients and candidates) includes billing address, delivery address, email address and telephone numbers.

Financial Data (collected only for certain clients of our services) includes bank account and payment method details.

Health Data (collected only for certain clients of our services) includes data pertaining to health status which reveals information relating to the past, current or future physical or mental health status of the data subject.

Transaction Data only for certain clients of our services: which includes details about payments to and from you and other details of services you have ordered from us.

Technical Data includes internet protocol (IP) address, the website you visited us from, your login data, browser type and version, time zone setting, language and geographical location, screen resolution, browser type, plug-ins and versions, operating system and platform, device type and ID and other technology on the devices you use to access this website.

Profile Data includes your interests, preferences, parts of our site and services you visit or interact with, the date and duration of your interaction, registering and attending our events, feedback and survey responses.

Usage Data includes information about how you interact with and use our website, communications and our Duco services, including, actions taken by you during the provision of Duco services, naming of processes, datasets, files and rules.

Marketing and Communications Data includes your preferences in receiving marketing materials from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

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

Your direct interactions with us

You may give us your personal data by completing online or contract forms and documents or by corresponding with us by online or by phone, email or otherwise. This includes personal data you provide when you:

• order our services or request information relating to our products and services;
• submit a client support service ticket;
• create an account with us;
• request marketing materials to be sent to you;
• visit our premises and we may collect your first and last name, arrival date and time and business affiliation;
• participate in an event or a survey; 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 receive personal data about you from various third parties and public sources as set out below: 

Technical Data is collected from the following parties:

• Digital adoption platform analytics providers for our services such as Pendo based outside the UK;
• Analytics providers such as Google and Hubspot based outside the UK; and
• Advertising networks such as Linkedin and AdRoll based outside the UK.

Identity and Contact Data is collected from:

• Data brokers or aggregators Zoominfo Technologies and Lusha Systems based outside the UK;
• Publicly available sources such as Companies House and the Electoral Register based inside the UK;
• Events that we sponsor. 

It should be noted that this website and Duco services are not intended for children and we do not knowingly process data relating to children.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure client experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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 explicit consent or are otherwise required or permitted to by law).

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. For example,where we are given a court order to disclose such information about you. When lawful and possible, we shall identify the relevant legal obligation when we rely on this legal basis.

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

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 the various categories of 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.

Direct marketing

You will receive marketing communications from us if you have requested information from us or registered to our mailing list or ordered services from us, and you have not opted out of receiving marketing communication from us.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which services and offers may be of interest to you so that we can send you relevant marketing communications.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

We may get your express opt-in consent from event organisers before we send you communications from us.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at any time at marketing@du.co.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or client service.

Cookies

You can set your browser to refuse all (excluding essential cookies) or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, please note that some parts of this website or of our services, may become inaccessible and/or not function properly. For more information about the cookies we use, please see our cookie policy.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes and subject to the legal basis set out in the table Purposes.

Internal Third Parties as set out in the Glossary

External Third Parties as set out in the Glossary

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 of control or restructuring 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 may also be required to disclose information pursuant to applicable laws, court orders, or directives from regulatory authorities. Additionally, we may be permitted to disclose such information in accordance with relevant data protection legislation. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable 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 Duco Group and where necessary, to our third-party suppliers or subcontractors. Such actions may entail transferring your data outside the UK and European Economic Area (EEA).

When we share your personal data within the Duco Group, this will involve transferring your data outside the UK to our offices in the US, Poland, Singapore or Belgium.

Whenever we transfer your personal data out of the UK and EEA to countries which have laws that do not provide the same level of data protection as the UK law, we have taken appropriate safeguards to ensure that your information will remain protected in accordance with this policy and that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are implemented.

For transfers of your personal data outside the UK and EEA, whether within our Duco Group or to external service providers and sub-contractors, we will only transfer this data under the following conditions:

• To countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries

OR

• Using specific Standard Contractual Clauses (SCC) approved for use in the UK/EEA which give the transferred personal data the same protection as it has in the UK/EEA, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

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 where 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

How long will you use my personal data for?

We will only retain your personal data for as long as 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 of 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.

By various legislations, we are required to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients, for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights section below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research and development 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 a number of rights under data protection laws in relation to your personal data. 

You have the right to:

Request access to your personal data (commonly known as a “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, to the extent that this is possible, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data in certain circumstances. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object where we are processing your personal data for direct marketing purposes (see Opting Out of Marketing (4)) for details of how to object to receiving direct marketing communications).

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 (see the table in (4)) for details of when we rely on your consent as the legal basis for using your 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us as set out in Contact details (10).

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: dataprivacy@du.co

Postal address: Duco Technology Limited, 27 Goswell Road, London, EC1M 7AN, England.

11. Complaints

While our goal is to address any issues or complaints promptly and efficiently, you have the right to make a complaint at any time to your local data protection authority.  The Information Commissioner’s Office (ICO) is the UK regulator for data protection issues (www.ico.org.uk).  Anywhere else, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection regulator, so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.

If we make material changes to this policy, for example, changes in why we process your data, who controls it or how you can exercise your rights, we will notify you, as appropriate, depending on the substance of the changes, by email or by posting a notice on our website’s homepage before the changes take place.

Any modifications to this privacy policy will be effective upon our posting of the new terms and/or upon implementation of the new changes (or as otherwise indicated at the time of posting). In all cases, your continued use of our website and/or services after the posting of any modified privacy policy indicates your acceptance of the terms of the modified privacy policy.

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, for example a new address or email address.

13. 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.

14. California privacy rights

Supplemental information for California, USA:

This section for California residents supplements the information contained in our privacy policy and addresses the requirements under the California Consumer Privacy Act 2018 (CCPA) as amended by the California Consumer Privacy Act 2023 (CPRA). 

It applies only to individuals who reside in the State of California and provides an explanation of how we collect (online and offline), use and disclose their personal Information, and of their rights regarding our handling of their personal information.

This section does not apply to Duco Group personnel. Paragraphs 14.2-14.5 of this section do not apply to job applicants.

This section uses certain terms that have the meaning given to them in the CCPA, CPRA and their implementing regulations.

14.1. Personal Information that we collect, use and disclose

We may collect or process (including in the preceding 12 months) the following categories of personal information about California residents: 

Identifiers: identifiers such as name, username, postal address, unique personal identifier, client number, telephone number, online identifier, internet protocol address, email address, account name or other similar identifiers.

Commercial Information: commercial information, including records of services ordered, obtained or considered, client and technical support tickets, or other orders or consuming histories.

Online Activity: Internet and other electronic network activity information, including information regarding your interaction with our website, including by persistent identifiers that can be used to recognize an individual person or device, by using among others, a device identifier, an Internet Protocol address, cookies, beacons, pixel tags, mobile ad identifiers, or similar technology.

Data processed through our services by our clients may include personal information, including categories that would typically be classified as sensitive information. However, we are not collecting or using this type of information to infer characteristics about a consumer from such information. We process this data solely for the purpose of providing services to the client and therefore, it does not qualify as sensitive information under the CCPA.

Such personal information processed by our clients through our services may include the following categories about California residents (in addition to the categories stated above):

• Employment related information
• Government Identifiers
• Mail or Email messages content
• Financial Information – bank account, fund information

We may use (and may have used in the 12 months before this section takes effect) your personal information for the reasons outlined in this privacy policy, as well as for the business purposes specified in the CCPA:

• Performing services, including providing client and technical support services, processing or fulfilling orders and transactions, verifying client information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.
• Auditing related to a current interaction with you and concurrent transactions and auditing compliance.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of our service and to improve, upgrade, or enhance our service.
• Managing career opportunities with the Duco Group.

14.2. Sources of Personal Information

During the 12 month period prior to the effective date of this section, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you contact us with a question or comment
• From your devices, such as when you visit our website
• Our clients who process their data through our Duco SaaS product which contains your personal information 
• Suppliers who provide services on our behalf
• Third parties or publicly available sources

14.3. Sale of Personal Information

We do not and will not sell your personal information.

14.4. Sharing of Personal Information

During the 12 month period prior to the effective date of this section, we may have shared your personal information only with certain categories of third parties, for a business purpose, as described below:

14.5. California Privacy Rights

As a California resident, you have the right to access or delete your personal information in addition to other choices that we offer you, regarding our handling of your personal information. However, these rights are not absolute, and we may decline your request as permitted by the CCPA.

Access: You may have the right to request, twice in a 12 month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from or about you.

Opt-Out: You have the right, at any time, to direct us not to share your personal information to third parties, as defined under the CCPA. This is also referred to as your right to opt-out.

You have the right to opt-out of share within the meaning of the CCPA, of certain information subject to the CCPA  (we will never sell your information). You are not required to have an account with us to exercise your right to opt-out of sharing your personal information to third parties. Please submit your request to our email marketing@du.co.

The Duco services are not targeted to or intended for children under the age of 18. If you have any reasons to believe that a minor has shared any information with us, please contact us at dataprivacy@du.co.

How to Submit a Request: To submit an access or deletion request (or to submit a request as an authorised agent on behalf of a consumer), email us at 212-353-6542 or call us toll-free at 212-353-6542. For questions or concerns about our privacy policies and practices, please email us at dataprivacy@du.co or call us toll-free at 212-353-6542.

Identity Verification: To protect your privacy and maintain security, we are required by the CCPA to verify the identity of anyone submitting a data request before providing a substantive response. When you request access to or deletion of your personal information, you may be asked to provide details such as your email address, the name of the Duco Group representative you typically interact with, and the date of your last interaction with them. If you request specific pieces of personal information, you will need to sign a declaration under penalty of perjury confirming that you are the consumer whose information is the subject of the request. The request must contain sufficient detail to allow us to understand, evaluate, and respond appropriately.

Authorised Agents: As a California resident you can appoint an authorised agent to make a request under the CCPA on your behalf if: (i) The authorised agent is a natural person or a business entity registered with the Secretary of State of California; and (ii) You sign a written declaration authorising the agent to act on your behalf. If you use an authorised agent to submit a request to exercise your right to know or to request deletion, please email a certified copy of your written declaration to the postal address included in section 10 – Contact details.

15. Canada privacy rights

Supplemental Information for Canada:

The handling of Personal Data, as defined in PIPEDA, in Canada is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant provincial laws, notably Quebec’s Bill (64). The Duco Group collects and processes Personal Data in accordance with PIPEDA and provincial laws. To learn more about Duco’s adherence to PIPEDA and provincial laws, please contact us.

16. Glossary

16.1. Internal Third Parties

means other companies in the Duco Group who are based in the UK, US, Poland, Belgium and Singapore that provide services or support services.

16.2. External Third Parties

means:

Zendesk Inc. – provider of customer support and service software, including tools for managing and responding to customer inquiries, support and feedback tickets. View their privacy notice here.

Service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf including but not limited to IT and system administration service, telemarketing and marketing.

Professional advisers including lawyers, bankers and financial businesses, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to the Duco Group.

Government, regulators and other legal authorities.

Amazon Web Services – our hosting provider. View their privacy notice here.

Amazon Web Services and Microsoft Azure – providers of our optical character recognition (OCR) service. View their privacy notice here and here.

BambooHR – provider of human resources services including the career application service through our website. View their privacy notice here.

Google and Hubspot – providers of data analytics services used to improve Duco’s services, marketing, client relationships, and experiences. These services may collect your IP address, web application data (such as page title and URL), and geolocation (limited to country and city) for security purposes. View their privacy notice here and here.

Hubspot – provider of services required for storing, collecting and performing our email communications to prospects and clients. View their privacy notice here.

Mailchimp – provider of our inbound and outbound emails communications in our SaaS service product. View their privacy notice here.

MongoDB – Provider of database services used for storing and managing data for our AIDP Module. View their privacy notice here.

Osano Inc. for the purposes of cookies and consent management for use of non-essential cookies on our website. View their privacy notice here.

Pendo – provider of digital adoption platforms for our services. View their privacy notice here.

ProductBoard Inc. – Provider of product management service used for collecting, summarising and prioritizing feedback from our clients, in order to maintain and enhance our service and product development. View their privacy notice here.

Salesforce, Zoominfo Technologies and Lusha Systems – providers of lead generating services for potential prospects and clients. View their privacy notices here, here and here.