INTRODUCTION
Do IT 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
access the Do IT Platform (the Platform) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in
this privacy policy.
[All web pages on www.doit.life are encrypted via a secure and modern cypher suite,
meaning data exchanged between your browser and our Platform is safe from prying
eyes.]1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Do IT collects and processes
your personal data through your use of the Do IT Platform (and all related web sites,
applications and online services and tools where this policy is referenced, regardless of how you access or use them, including mobile devices) and including any data you may provide through the Do IT Platform.
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
Do IT is the controller in respect to certain uses of your personal data (collectively
referred to as Do IT, in this privacy policy).
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 data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please
contact our data privacy manager in the following ways:Full name of legal entity: Do IT Life Services Ltd
Email address: data@doit.life
We are registered with the Information Commissioner´s Office (ICO) as a controller of personal data under registration number: ZB043523
You have the right to make a complaint at any time to the Information Commissioner
Office (ICO), the UK supervisory authority for data protection issues (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 our privacy policy and your duty to inform us of changes
to your personal data
We keep our privacy policy under regular review.
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.
Your access to and use of third party websites or services accessible
through the Do IT Platform
The Do IT Platform includes links to third-party websites and applications as well as to
partner providers (Partners) of multiple different types of offline services associated with
a particular Ecosystem.
Third party web sites and applications. Clicking on links to third party web sites,
content or applications may allow those third parties to collect or share data about you.
We do not control those third-party websites or content and are not responsible for their
privacy statements or the way in which they collect or use your data.
Offline Services available through an Ecosystem.
Where you access or use third
party offline services provided by a Partner associated with a particular Ecosystem, we
encourage you to request details of and read the privacy policy of that service provider.
We do not control those third-party service providers and are not responsible for their
privacy statements or the way in which they collect or use your data.We will never share your data with any third-party service provider whether online or
offline without your express permission.
Please Note: The Do IT Platform is made available to you as a service to facilitate your
activities within a particular Ecosystem, we do not engage in any correspondence, or the relationship, between you as a user of the Platform and any Partner services you make
use of which are made available to you as part of your Ecosystem or the Platform
generally. In particular we do not participate in any part of any service or any contract for
services which may be provided to you by an Ecosystem Partner or otherwise available
to you as a user. You accept all responsibility in respect to ensuring that any specific
services which you make use of are suitable for you.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
we have grouped together as follows:
Identity Data which includes first name, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender.
Contact Data which includes your home address, email address and telephone
numbers.
Transaction Data which includes details about payments you have made and
other details of products and services you have accessed or used through the
Platform. We do not store card details on our server.
Technical Data which includes your internet protocol (IP) address, your login
data, browser type and version, hardware information, time zone setting and
location, browser plug-in types and versions, operating system and website, and
other technology on the devices you use to access the Platform.
Profile Data which includes your username and password, purchases or orders
made by you, your interests, volunteer record, preferences, feedback and survey
responses.
Usage Data which includes information about how you use our Platform,
products and services.
Marketing and Communications Data which includes your preferences in
receiving marketing from us and our third party Platform Partners and your
communication preferences.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.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an agreement we
have with you, and you fail to provide that data when requested, we may not be able to
perform the agreement we have or are trying to enter into with you (for example, to
provide you with access to the Platform and particular services). In this case, you may
not be able to access to a service which you have requested, but we will notify you if this
is the case at the time.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, Contact and other Data by
filling in forms or by corresponding with us by email or otherwise on the Platform.
This includes personal data you provide when you: (a) create an account with us;
(b) subscribe (or are subscribed) to our service; (c) request marketing to be sent
to you; (d) enter a promotion or survey; or (e) give us feedback or contact us.
Third parties. We may receive your data through our Affiliates in relation to the
provision of services to you. We may also receive information from third parties
that we use to verify your identity.
Automated technologies or interactions. As you interact with our Platform, 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.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 we need to perform the contract we are about to enter into or have
entered into with you.
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.Generally, we do not rely on consent as a legal basis for processing your personal data
on the Do IT Platform although we will get your consent before sending any personal
data to any third party Platform service provider or any third party direct marketing
communications via e-mail or text message.
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/Activity Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a user of the Platform
1. Identity
2. Contact
Performance of a contract with you
To manage our
relationship with you
which will include:
1. Providing
access to
Platform
services
2. Notifying you
about changes
to our terms or
privacy policy
3. Asking you to
leave a review
or take a
survey
4. Investigating
complaints
5. Transferring
certain
elements of1. Identity
2. Contact
3. Profile
4. Marketing and
Communications
5. Transaction Data1. Performance of a
contract with you
2. Necessary to comply
with a legal obligation
3. Necessary for our
legitimate interests (to
keep our records
updated and to study
how users use the
Platform and the
products/services)your Personal
Data to a third
party service
provider (where
not a consent
driven activity).
To administer and
protect our business
and our services
(including
troubleshooting, data
analysis, testing,
system maintenance,
support, reporting and
hosting of data)1. Identity
2. Contact
3. Technical
4. Transaction Data1. Necessary for our
legitimate interests
(for running our
business,
administering our
CRM, provision of
administration and IT
services, network
security, to prevent
fraud and in the
context of a business
reorganisation or
group restructuring
exercise)
2. Necessary to comply
with a legal obligationTo enable you to
partake in a
competition or
complete a survey1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and
Communications1. Performance of a
contract with you
2. Necessary for our
legitimate interests (to
study how users use
the Platform and to
develop and grow our
business)To deliver relevant
Platform content and
advertisements to you
and measure or
understand the
effectiveness of the
advertising we serve
to you1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and
Communications
6. Technical
7. Transaction DataNecessary for our legitimate
interests (to study how users
use the Platform and to grow
our business and inform our
marketing and growth
strategy)To use data analytics
to improve our
Platform,
products/services,
marketing, user and
Partner relationships1. Technical
2. UsageNecessary for our legitimate
interests (to define types of
users for certain Platform
services and to keep our
services and web site
updated and relevant, toand experiences develop our business and to
inform our marketing
strategy)To make suggestions
and recommendations
to you about services
available through the
Platform that may be
of interest to you1. Identity
2. Contact
3. Technical
4. Usage
5. Profile
6. Marketing and
Communications
7. Transaction DataNecessary for our legitimate
interests (to develop the
products and services
available through the
Platform)Marketing
We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.
Recommendations from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is how we
decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information
from us previously used services or purchased products or services through the Platform
and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any
third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal
data provided to us as a result of your use of the Platform or any associated services.
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 our Platform may become inaccessible or not function properly.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 “Purposes for which we will use your personal data” above.
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 happens to our business, then the new owners may
use your personal data in the same way as set out in this privacy policy.
Where third parties support the provision of services made available to you through the
Platform, these third parties may receive certain personal data from you. Except where
you have previously given consent, you will be informed of any transfer of data prior to it
taking place and the extent of the data being shared. In these cases, during the transfer,
we will, at all times, control and be responsible for the use of your personal data. Whilst
we are not in control of any third parties to whom you request your data to be shared, 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 your instructions.
To help constantly improve and tailor the service we provide to you through our Platform,
we may use aggregated information so that we can administer and improve our services,
analyse trends, gather broad demographic information and detect suspicious or
fraudulent transactions and most importantly monitor and improve our operations on a
day to day basis. In carrying out this activity, we may pass some information to third
parties in aggregate and anonymised format.
Your disclosure to third parties
Except as otherwise expressly included in this Privacy Policy, this document addresses
only the use and disclosure of information we collect. If you disclose your information to
others, different rules may apply to their use or disclosure of the information you provide
to them. Do IT does not control the privacy policies of third parties, and you are subjectto the privacy policies of those third parties where applicable. We will prompt you before
you share personal data from the Platform with external third parties and encourage you
to ask questions before you disclose that personal information to others.
6. International transfers
We may transfer your personal data outside the European Economic Area (EEA) in our
performance of services.
Whenever we transfer your personal data out of the EEA, we ensure an appropriate
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 by the European
Commission.
Where we use certain service providers, we may use specific contracts approved
by the European Commission which give personal data the same protection it
has in Europe.
Where we use providers based in the US, we may transfer data to them if they
are part of the Privacy Shield which requires them to provide similar protection to
personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us
when transferring your personal data out of the EEA.
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
How long will you use my personal data for?
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 datafor 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.
With your prior consent, we may process sensitive personal data on the
Platform. 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). No sharing of sensitive
personal data will be used made without your express prior written consent.
In some circumstances you can ask us to delete your data: see your legal rights 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 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. 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 toobject 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:
o If you want us to establish the data's accuracy.
o Where our use of the data is unlawful but you do not want us to erase it.
o 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.
o 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.
If you wish to exercise any of the rights set out above, please contact us.
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 could 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. Glossary
Affiliates means companies in the same group of companies as Do It and close
affiliates including Do It Trust (the Do It Foundation) Legitimate Interest means the
interest of our business in conducting and managing our business to enable us to give
you the best service/product and the best and most 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. In respect to Do IT, that is the performance of our
agreement with you to make the Platform and its services available, and to support your
entering into any agreement with providers of services to the Platform. We are not
involved in the processing of your Personal Data during any engagement you enter into
with our third party partners. We will always get your consent to transfer any Personal
Data to any third party whom you enter into an agreement with for the provision of their
services to you.
Comply with a legal obligation means processing your personal data where it is
necessary for compliance with a legal obligation that we are subject to.
External Third Parties
Service providers acting as processors who provide our IT and system
administration services.
Payment service providers who provide payment services to us and our Affiliates
and may also provide such services to you and persons you nominate for such
services
Providers of our cloud services such as AWS and Google.
Professional advisers acting as processors or joint controllers including lawyers,
bankers, auditors and insurers based in the United Kingdom who provide
consultancy, banking, legal, insurance and accounting services.
Regulators and other authorities acting as processors or joint controllers based in
the United Kingdom who require reporting of processing activities in certain
circumstances.
Our third-party partners and affiliates who you engage with through the use of the
Platform in order to facilitate the provision of services.
External Third Parties (with consent)
Platform service providers where sensitive (special category) data is processed.