How we use your information
- register with us and log in through our website;
- sign up to, and participate in, our Rewards Club or client events;
- submit to us a data protection request , a complaint or any other enquiry relating to our services;
- subscribe to receive our newsletter or any other information from us;
- respond to our marketing communications;
- correspond with us in writing, by phone or email, or otherwise;
- complete any enquiry forms or requests for a quote on our website;
- report to us a problem or issue with our website; or
- submit a job application to us.
Who holds your information?
We will hold your information and for the purposes of the Data Protection Act 1998, we are the data controller. We are Initium DBC Limited; a limited company registered in the UK with company number 05729231, registered office at 10 Queen Street Place, London, EC4R 1AG. (“Initium DBC”).
Visitors to our websites
When someone visits our website, www.initiumdbc.com, we collect standard internet log information (including but not limited to location data, time zone setting, the internet protocol (IP) address used to connect your computer to the internet, browser type and version) and details of visitor behavior patterns (including but not limited to the full Uniform Resource Locators (URL) click stream to, through and from our website, page response times, services you viewed or searched for and length of visits to certain pages). We do this to find out things such as the number of visitors to the various parts of the website.
Uses made of the information
When you place an enquiry with Initium DBC either directly or indirectly through an intermediary, such as an online broker, we store information that you have supplied including your contact information and business requirements. This information is stored in a secure CRM system. We use this information to store account history and contact you via email or phone during and after the sales process based on the requirements you have given us. We also hold this information for as long as necessary to continue to provide any services to you that you have requested and to carry out our obligations arising from any contracts entered into between you and us.
We may also contact you about services similar to those which were the subject of your original communications with us, but only where you have not opted out of marketing communications when you submitted your contact details to us, or subsequently.
We have a clear ‘do not contact’ field on our enquiry forms that stops information being passed through to sales and marketing. You can be suppressed from our CRM system by contacting email@example.com and all of our emarketing communications have a clear ‘unsubscribe’ mechanism where you do not wish to receive further marketing from us.
We may permit companies within the Initium DBC Group to use your personal information and they may contact you about various products or services, but they will only contact you directly if you have opted in to receiving marketing communications (or where you become a customer or negotiate a sale with them).
The “Initium DBC Group” means our subsidiaries and our ultimate holding company from time to time, and any subsidiary from time to time of our ultimate holding company as defined in section 1159 of the UK Companies Act 2006.
We also purchase data from certified professional agencies to market our products and services. This data is not held within our CRM system, and is only available to the marketing department.
People who call our helpline
When you call Initium DBC’s sales/helpline we collect Calling Line Identification (CLI) information. We use this information to help improve efficiency and effectiveness.
However, there may be situations where you do not want us to collect CLI information. The simplest way to deal with this is to dial 141 before dialing our number. Always dial the 141 first, in front of any other numbers. However, if you are dialing from an extension on a business switchboard system, where you have to dial (typically) 9 for an outside line, you should dial 9 first, then 141 and then the outside number.
When you dial 141, this is described as ‘blocking your CLI’. As mentioned above, it stops us from knowing your number. You should note, however, that your phone company and their operators can always see your number should they need to.
Calls to our Initium DBC sales/helpline may be monitored and/or recorded for authentication, security, quality or training purposes. Generally, a call will not be retrieved or monitored unless:
- it is necessary to investigate a complaint made against us;
- it is part of a spot check to ensure that customer service standards are being met;
- it is used to train Initium DBC’s staff; or
- it is necessary to comply with any applicable law or regulation or the rules or requirements of any of the relevant regulatory authorities.
People who make a complaint to us
When we receive a complaint we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone personally.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for four years from closure in a secure environment.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not identify any complainants unless the details have already been made public.
If you apply online to work for Initium DBC or for the Initium DBC Group, we will only use the information you supply to us to process your application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Disclosure and Barring Service we will not do so without informing you beforehand, unless the disclosure is required by law.
Your personal information, including a copy of your CV, will be held for a period no longer than we deem necessary, it will then be destroyed or deleted. We retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Your right to access personal information we hold about you
We try to be as open as we can be in terms of giving people access to their personal information which may be stored by us. Individuals can find out if we hold any personal information subject to the exclusions set out in the Data Protection Act 1998, by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in an intelligible form.
To make a request for access to the personal information we may hold you need to put the request in writing addressing it to Initium DBC Limited, Corporate department, 150 Minories London EC3N 1LS. Any access request will be subject to a fee of £10 to meet our costs in providing you with such information.
Disclosure of personal information
We may share your information with any member of the Initium DBC Group.
In many circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. We may also share your information with third parties:
- in the event we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
- if Initium DBC or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
- to assist us in the improvement and optimisation of the website we may share your information with analytics and search providers.
If we refer any dispute between us to the ODR Platform <http://ec.europa.eu/consumers/odr>, and/or we agree to engage in any alternative dispute resolution (ADR) procedure with you through the Platform, then to the extent that your personal data is relevant to the dispute we may disclose it to the European Commission, as operator of the ODR Platform, and to any ADR provider appointed to deal with the dispute.
Links to other websites
How long we keep your personal information for
We aim to keep your personal information for a period no longer than we deem necessary. This period may depend upon the marketing preferences you have selected and may be unlimited. For personal information relating to a complaint, this will be retained for four years from closure of the complaint. Please see ‘People who make a complaint to us’ above for further information about this.
In particular, we may keep your personal information for as long as we have your consent to receive marketing information from us and third parties, and for as long as necessary for us to comply with the law and to respond to any disputes or queries that may arise during that period.
Interactive areas of our website
Information that you post via social networking sites linked to our website, including but not limited to Facebook, Twitter, Google+ and Linked In, is generally accessible to and may be collected by others. This may result in unwelcome communications. For your own safety and security, you should not provide any information on the aforementioned sites, that you would not want others to see.
If you do provide any information via social networking sites linked to our website, we do not accept any responsibility or liability for any breach of privacy, loss (whether in contract or tort, including negligence), damage, effect on your reputation or otherwise, directly or indirectly, relating to your use of social networking sites.
Where we store your personal information
The personal information that we collect from you is stored on the secure servers of our web services provider. We have in place a level of security appropriate to the nature of the information that we store and the potential harm that may arise from a breach of security.
We are committed to safeguarding the security of your personal information. We have implemented technical and organisational measures that are appropriate to the nature of the personal information and the harm that may result from your personal information being accidentally or deliberately compromised.
Unfortunately, the transmission of information via the internet cannot be guaranteed as 100% secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
[Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If we become aware that the security of your personal information has been compromised, we will contact you by email, SMS, by post or as otherwise required by law.]
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. Cookies can, among other functions, remember user preferences and recommend content. Cookies do not themselves identify the individual user, but rather the computer used.
The types of cookies we currently use on this website are set out below. :
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
The table below explains the individual cookies we use and why.
Google Analytics (& Bing Analytics)
Google sets these performance cookies, which These cookies are used to collect information about how visitors use our site. Google stores the information collected on servers in the United States. Google may transfer this information to third parties where required to do so by law, or where third parties process the information on Google’s behalf. Google state that they will not associate your IP address with any other data held by them.
Content Management System cookie
This cookie is set by our content management system. It tracks when the user is logged in and enables a profile. This cookie is essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
We do not actively use the data or export for marketing purposes, it is purely for website functionality.
Online Shopping Cart
Some sections of the site may have a shopping cart functionality. During the selection process through to Checkout the user is tracked by profile to enable a complete booking to be placed in our CRM system. This is an automated process.
The purchase details are stored in the website database for an audit trial of purchase. This information is not exported and never distributed.
The payment is processed by a third party eg.Paypal or Google checkout and we do not have access to this part of the payment or any associated information other than the basic requirements for us to process a booking and register it in our CRM system.
Web Chat Software
This cookie is a functionality cookie which tracks the page and visitor trail through the site, and the IP location to enable rapid response. This cookie remembers your choices in order to improve your experience. No personal detail is taken without request.
The web chat has a non-mandatory login. If the viewer chooses to input their details they are stored on their cookies for future recognition so we can quickly identify any previous enquiries.
Facebook remarketing cookie
This cookie allows us to reach visitors to our website with an advert to our services when those visitors use Facebook.
Twitter remarketing cookie
This cookie allows us to reach visitors to our website with an advert to our services when those visitors browse their Titter timeline.
How to disable cookies
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
You have the ability to accept or decline cookies by modifying the settings in your browser. For example, in Internet Explorer, you can go to Tools and Internet Options, where there is the option to change your settings to disable cookies. However, you may not be able to use all the interactive features of our site if the cookies are disabled. You also have the ability to delete cookies that have been installed in the cookie folder of your browser. To do this you should search for “cookies” in your “Help” function for information on where to find your cookie folder.
We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. To find out more please visit YouTube’s embedding videos information page: http://support.google.com/youtube/bin/answer.py?hl=en-GB&answer=171780
Initium DBC tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.