This website is published by Dialogue Capital Ltd [“Dialogue Capital”, “we”, “our” and “us”]. Dialogue Capital is registered in England and Wales as Private Limited Company, no. 9177309, and is also registered with the (UK’s Information Commission as a Data Controller (registration no. A8280167) in accordance with the Data Protection Act of 1998)
For more information on the Data Protection Act, you can visit the UK Information Commissioner’s website: https://ico.org.uk/
This privacy policy relates to all individuals [“users”, “you” and “your”] who register, or have registered on their behalf, their details [“data”] on any of the websites built and maintained by us [“site” and “sites”]. Dialogue Capital respects the privacy rights of our Users and is strongly committed to protecting the privacy of our Users. This privacy policy sets out the information-gathering, utilisation and dissemination practices for all Sites and adheres to industry norms. It is not subject to negotiation or one-off amendment: if you do not accept the terms of this privacy policy, you should not become a User. You can also stop being a User at any time by emailing us at:
If you have any requests concerning your personal information or any queries with regard to these practices, please contact us by e-mail at
United Kingdom
GDPR, PRIVACY AND COOKIE POLICY
Welcome to the GDPR, Privacy and Cookie Policy of https;//www.dialoguecapital.com
(the “Site”) this policy details how we collect and use your personal data, how we protect your privacy and how we may use cookies, when you contact us and use our services.
- What data is covered?
This policy details the obligations of the Site regarding data protection and your rights under the General Data Protection Regulations (GDPR) and how we work to ensure your privacy.
Your personal data will be processed, lawfully, fairly and transparently and only collected for specific, explicit and legitimate purposes and not processed further for any incompatible purposes other than the original purpose for collection.
In this privacy notice, “ personal data ” means any information relating to an individual who can be identified, directly or indirectly by reference to an identifier such as names, an identification number such as a national insurance number, location data or an online identifier such as an IP address.
Personal data also refers to one or more factors including device information and order information, we collect the following: email address; first and last name; address; bank details; order information which may contain other personal information such as billing address; payment information; ( including credit card numbers ); phone number; cookie and usage data.
- Purposes for which we collect and process personal data.
For the performance of our professional services; which includes event services, to fulfil any bookings placed through the site (including processing your payment information, arranging and providing you with your invoices and/or confirmations and event tickets).
We may also use this Order Information to:
- Communicate with you;
- screen your orders for potential risk or fraud;
- when in line with preferences you have shared with us, provide you with information or advertising relating to our services.
The data we collect depends upon the services provided to you, and we only process personal data for the purpose for which it was collected.
Device information is detailed in our Cookies section below.
The purposes for which we process data and the legal basis for doing so
Customers:
* for the performance of any contract we enter into with you or pre-contract due diligence enquires should no contract subsequently be entered into;
* for either our or your legitimate interest;
* in respect of any legal obligation we are subject to;
* where you have provided your consent for us to do so;
* where necessary to do so;
Visitors to the Site: We also collect personal data about you when you visit our website.
Information which is voluntarily provided, for example when completing and online form to contact us or give us an order, when agreeing to subscribe to a newsletter or when registering with us to receive our services. Such voluntary information may be:
* your name
* your address
* any contact details such as mobile number and email address or other telephone numbers
* date of birth
* demographic information, address, post code any preferences and interests
* any other relevant information to enable us to offer and supply our services to you
Any information which you provide on this basis which may be sensitive is not collected or processed intentionally. Such information is provided by you on a voluntary basis and you acknowledge and agree that such information may be processed by us.
If you register on our website or place an order with us your personal data is collected and stored in our storage facility within our computer system any data held on individuals who have not placed an order or ceased placing orders with us is deleted after a period of 18 months or sooner if required by law.
If you opt out of any of our services your basic data will remain on our opt out list.
Cookies
Cookies are small files, which may include personal data and which are automatically collected when you visit the Site. When you visit the Site we automatically collect certain personal data from your device, if you give consent.
Cookies transfer to your computer hard drive through your web browser. This enables the Site to recognise your browser and capture and remember certain information. Such data is:
* IP address
* Unique device identifier number
* Device type
* Browser type
* Geographical location eg country or city location
* other technical information
We collect this information to improve the services supplied to you and Cookies enable us to better understand the visitors to the Site.
The purposes for which we collect and/or process your personal data as a visitor to our website;-
* To assist in administering and managing our website.
* For site security for example to authenticate your identity and to prevent unauthorised access to the site.
* To more personalise your visits to the Site, so we may enhance your experience.
* To analyse visitor data so as to enhance our marketing and other communications.
* To understand which features of the Site visitors use.
* To assist us in monitoring and enforcing all relevant regulations and applicable compliance.
* To assist us in continual risk management assessment.
* Any other purposes for which you provide us with your information.
Our grounds for processing personal data of visitors to the Site are:
* For the effective and lawful operation of our business.
* To improve and develop our website to enhance visitor experience.
* Any matter for which we have been given your explicit consent.
If you would like to know more about cookies please go to www.allaboutcookies.org
Other reasons we may collect personal data from you could be:
|
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest
|
|
To register you as a new client |
(a) Identity (b) Contact |
Performance of a contract with you such as processing your order |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect money due to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you, such as processing your order (b) Necessary for our legitimate interests (to collect payment due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, client relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
- Sharing Data
However, we may employ third party companies and individuals to facilitate our service (“Service Providers”), to provide the service on our behalf, to perform service-related services or to assist us in analysing how our service is used.
These third parties may have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may also be required to share your Personal Data to comply with applicable laws, and to respond to any legitimate request from any court of competent jurisdiction or to protect our rights and our property rights.
- Security
We take all appropriate security and legal precautions to safeguard the safety and integrity of all of the personal data that we collect. Your personal data will only be accessed by persons within the company who have a legitimate need to do so.
Access to the personal data we collect is limited and we have policies and procedures in place to safeguard your information from loss, miss-use and improper disclosure.
All of our employees are subject to a company policy which ensures that they are contracted to understand your confidentiality requirements and will work to the best of their ability inline with this policy.
- Your Rights and our Complaints Procedure
You have the following rights in relation to your personal data;-
* You may access the data we hold about you
* If you note that your data is incorrect or incomplete you have the right to have that data corrected
* You may opt out of any of the services provided, but please note some services we may be unable to provide should you do so
* You may request that we delete your personal data ( this subject to any legal requirement we may have to retain such data )
* You may request a copy of your personal data held, this may take up to thirty ( 30 ) days
* You have the right to withdraw your consent to the use of any of your personal data for which you have previously given your consent for use
* You have the right to complain to the Data Protection Authority, such a complaint should be directed to the authority in your country or a relevant court of competent jurisdiction. We do however have a complaints procedure which we will deal with any complaints you may have, any such complaint should be directed to us. We will acknowledge your complaint and ensure it is investigated honestly and fairly and inform you how it will be handled.
If you have any other queries or wish to exercise any of your rights in respect of your personal data please contact us at
You may also complain directly to https://ico.org.uk/
- Who we disclose your Personal Information to.
We will disclose your personal information to the following;-
* If required by law.
* If we believe disclosure is appropriate to enforce any of our terms and conditions, to protect and defend our rights, property or safety.
* To comply with any court order, proceeding or under any other legal obligation, regulatory or government requirement.
* With your consent.
We are obliged under current laws to report suspicious transactions and any other such activity to the relevant regulatory authorities under anti money laundering, or related legislation. We will also report any suspected criminal activity to the relevant law enforcement body. In some circumstances we may not be permitted to inform you about this in advance of any disclosure, or at all.
Third Party Recipients of Personal Data include;-
* Professional Advisors such as law firms, tax advisors or auditor all of whom are subject to privacy and confidentiality laws and regulations
* Regulatory and other such bodies
* Providers of identity verification services
* The Courts, police and other relevant law enforcement agencies
* Relevant Government departments and agencies
* Our Service Providers
Do Not Track
We do not alter our Sites data collection and use practices when we see a DO NOT TRACK signal from your browser.
- How long do we retain your Personal Information
We retain your personal information only as long as it is needed by us, thereafter we only retain any information as long as it is required under the regulatory requirements we are subject to.
To ensure we meet our legal responsibilities we may retain some information. Examples of the reason for this could be to protect, defend or exercise our legal rights rights or for archiving and historical purposes.
- Data Security and Breaches
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.
If there is a security breach, or a suspected security breach we will inform you of the breach or suspected breach where we are legally required to do so, and report it to the appropriate regulatory body.
Once such a breach is discovered will will use all reasonable business measures to correct the breach and prevent any further breaches and recover or delete any lost in formation.
- Your Legal Rights
Under certain circumstances, you have rights under data protection laws (General Data Protection Regulations) in relation to your personal data. Specifically, you have the right to:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us.
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. We ask that you update us with any changes to your personal information.
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 to object 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:
- 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
- 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.
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.
Performance of a 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.
- International Transfers of Personal Data
Your personal data will not be transferred too or stored outside of the country where you are located.
- Changes to this Policy
We will, from time to time, make changes to this policy. This may be to ensure that we continue to be in line with the legal requirements and any regulatory changes made in law. We may also change our practices to better serve our and your needs. We will revise the, “last updated” date at the top of this notice and will, if such changes are material, post a prominent notice of the changes on the website.
We request that you read this policy from time to time and keep your personal information up to date at all times.
Dialogue Capital Limited, a company registered in the UK, Registered number 09177309, and registered office 395, Chapter Road, London, NW2 5NG.
Last updated 10-01-2021