Privacy Policy

Use of Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

We may use cookies to remember your preferred settings on the website. Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Our site uses the following cookies:

Cookie: Act-On Name: wp15066 Expiration:  After 1 year unless you manually clear them

Purpose: Enables cookie tracking when site visitors engage through form submissions, clickthrough’s in email messages and web pages containing the Act-On Beacon Tracker.

Cookie: Google Name: _ga, _gid Expiration: _ga – expires after 2 years and _gid – expires after 24 hours

Purpose: Used to distinguish users

More information: To find out more about the Google cookie policy you can visit – https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Cookie: Cookie Consent Name: viewed_cookie_policy, wordpress_test_cookie Expiration: After 1 year, unless you manually clear your cache

Purpose: Cookie is set by cookie consent plugin to record that you accept the fact that the site uses cookies.

These cookies do not collect any personal information that can be used to identify you. We use them to statistically analyse and understand which parts of our website have been visited so that we can continue to develop the user online experience, our products and our services.

The information we collect is stored securely by Google Inc. in the US. By using our website, you consent to us using cookies in this way.

Most web browsers allow you to disable cookies through your browser settings. However, if you choose to do this, you may not be able to experience the full functionality of our site and you may not be able to access certain areas. We therefore recommend that you accept the use of cookies.

DWS Privacy Policy

Maintaining data privacy and data protection is a priority for DWS.  In recognition of this fact, we have implemented a privacy policy that sets out the legal basis on which any personal data that we collect from you, or that you provide to us, will be processed by us.

Please read this privacy policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Any questions relating to data privacy with DWS or this policy should be sent by email to dataprotection@dws-global.com or in writing to DWS Limited, Ashcombe Court, Woolsack Way, Godalming, GU7 1LQ, U.K.

What personal Information is held

We may collect and process the following data from you:

  • Information you consent to provide DWS that is required to carry out our obligations arising from any contracts entered between you and us, or potential contracts that may be in liaison between you and us.
  • Information that you consent to provide by filling in forms on our website, or as part of any direct marketing or sales activities. This includes and is not limited to personal information about you such as your name, telephone contact number, geographical address/location, email address and interests. Note: Clear consent information is supplied at the point of collection to provide information on the use of data; and a record of the consent is taken at the point of collection.
  • If you contact us by telephone or in writing, we may keep a copy of your correspondence or communication.
  • Details of your visits to our website and the resources that you access.

If you have provided us with the personal data of another person, there is a clear requirement for you to confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a Data Controller and the nature of the processing taking place.  Records will be retained as evidence of this consent.

How will we use the information we hold about you?

We use information held about you in the following ways:

Performance of a contract – We use information held about you to carry out our obligations arising from any contracts entered into between you and us; and to notify you about changes to our services.

Legitimate Interests – We use information held about you to provide you with information, products and/or services which we feel may interest you as relevant to the products or services currently being supplied as part of a contract with DWS, or in relation to a previous contract with DWS whereby you are happy to continue to receive such information;

Consent (Direct Marketing) – We use information held about you to provide you with information on products and/or services you request from us, or which we feel may interest you. Where you have consented to be contacted for such purposes, it is a recognised right of the Data Subject that this consent can also be withdrawn.  Should you wish to withdraw consent, please contact us by email to dataprotection@dws-global.com or in writing to DWS Limited, Ashcombe Court, Woolsack Way, Godalming, GU7 1LQ, U.K.

Consent (Website) – to ensure that content from our Website is presented in the most effective manner for you and your device (see Cookie Policy above);

We will not share your data with third parties for other marketing purposes unless we have your express consent to do so.

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted to this page on our website.

Your rights relating to Personal Data

You have the right to ask us to cease processing your personal data for marketing purposes. We will seek consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can also exercise your right to prevent such processing by contacting us at dataprotection@dws-global.com.

GDPR gives you the right to access information held about you. Your right of access can be exercised at any time. DWS operates both a Data Subjects Rights procedure and a Subject Access Rights Procedure to ensure that all rights exercised by data subjects relating to personal data are managed appropriately.

From time to time, our website may contain links to and from our strategic partner(s), partner network(s), strategic sponsor(s), advertiser(s) and affiliate(s). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Retention of your information

We take appropriate measures to ensure that any information collected from you is kept secure. DWS hold UKAS accredited certification to ISO 27001:2013 and is subject to both internal and external audits to ensure that information security is upheld throughout the company.

We operate a clear Retention Policy (DWS IS-04.01 Data Archive & Retention Policy) and associated Retention Schedule to ensure personal data is kept only for so long as is necessary for the purpose for which such information is used.

If any of your personal data changes, or if you have any questions about how we use data which relates to you, please contact us by email at dataprotection@dws-global.com. We normally update your personal data within seven (7) working days of any new or updated personal data being provided to us, to ensure that the personal data we hold about you is as accurate and up to date as possible.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, strategic partner(s) or strategic sponsor(s) our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.

As part of our GDPR and BS10012:2017 compliance obligations, we are duty bound to check when personal data may be shared with third parties to ensure that they apply the same or greater controls in terms of data protection.  The use of non-disclosure agreements forms part of our third-party data sharing controls.

We may disclose your personal information to third parties

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; or
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply other agreements; or
  • to protect the rights, property or safety of DWS Limited, our customers or others.

DWS has risk assessed where personal information may be transferred outside the EEA. As part of our own due diligence we have identified that personal data held for and by DWS resides within the EU. We will continue to monitor this in consideration of any 3rd party provider changes in the future.

Should there be a requirement for data to be transferred outside of the EU in future, DWS will implement controls and safeguards to ensure that equal to or greater data protection measures are enforced, and records retained to evidence this.

Data Processing Agreement

As part of our effort to be and to remain compliant with EU GDPR, we offer standard terms of data processing. We process very little, if any personal data for our clients as part of our normal day to day consulting or software services. Our Data Processing Agreement terms sets out a minimum baseline to processing personal data. We believe this is appropriate for DWS.

 

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