Updated: March 2023.
1 - Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account" means an account required to access and/or use certain areas and features of Our Site;
“Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the cookies used by Our Site are set out in section 13, below;
“Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 or such amended or replacement regulation or legislation as may from time to time come into effect;
“Personal data" means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the applicable UK data protection law; and
“We/Us/Our" means Discover AI Limited, a limited company registered in England under company number 10920217, whose registered and main trading address is First Floor, 15 Greek Street, London, England, W1D 4DP United Kingdom.
2 - Information About Us
2.1 - Our Site is owned and operated by Discover AI, a limited company registered in England under company number 10920217, whose registered and main trading address is First Floor, 15 Greek Street, London, England, W1D 4DP United Kingdom. Discover AI is part of Talkwalker group companies.
2.2 - Our VAT number is 283 0473 06.
2.3 - Our Data Protection Officer can be contacted by email at firstname.lastname@example.org, or by post at First Floor, 15 Greek Street, London, England, W1D 4DP United Kingdom.
2.4 - We are registered with the ICO as a Controller (registration number ZA501712).
3 - What Does This Policy Cover?
4 - Your Rights
4.1 - As a data subject, you have the following rights under the UK GDPR, which this Policy and our use of personal data have been designed to uphold:
4.1.1 - The right to be informed about our collection and use of personal data;
4.1.2 - The right of access to the personal data we hold about you (see section 12);
4.1.3 - The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);
4.1.4 - The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);
4.1.5 - The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 - The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 - The right to object to us using your personal data for particular purposes;
4.1.8 - and rights with respect to automated decision making and profiling.
4.2 - If you have any cause for complaint about Our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 - For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5 - What Data Do We Collect?
5.1 - name; gender; business/company name; job title; profession; contact information such as email addresses and telephone numbers; demographic information such as town, country, preferences, and interests; IP address; web browser type and version; operating system; a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to; business and work interests
6 - How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the UK GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.1 - Providing and managing your account;
6.2.2 - Providing and managing your access to Our Site;
6.2.3 - Personalising and tailoring your experience on Our Site;
6.2.4 - Supplying our services to you (please note that we require your personal data in order to enter into a contract with you);
6.2.5 - Personalising and tailoring our services for you;
6.2.6 - Replying to emails from you;
6.2.7 - Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by selecting the opt out option on any emails we send you;
6.2.8 – Market research;
6.2.9 – Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 – With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, device/text message with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the applicable UK data protection laws.
6.4 – Third parties including Google, Facebook, Twitter, HubSpot, Instagram, LinkedIn, and others whose content appears on Our Site may use third-party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 - You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
6.6 - We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.6.1 - We keep your personal data for no longer than reasonably necessary for a period of 6 years in order to meet legal requirements. Examples include: in case of any legal claims/complaints; for safeguarding purposes etc.
7 - How and Where Do We Store Your Data?
7.1 - We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
7.2 Some or all of your data may be stored outside of the UK and/or European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to us. If we do store data outside the UK and/or EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the applicable UK data protection laws including:
7.2.1 - Data is processed by our processor, HubSpot Inc., and there are written data processing terms in place.
7.3 - Data security is very important to us, and to protect your data we strive to take appropriate measures to safeguard and secure data collected through Our Site.
8 - Do We Share Your Data?
Subject to section 8.2, we will not share any of your data with any third parties for any purposes. In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.
8.1 We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
8.2 The third-party processors used by us and listed below could be located outside of the UK and/or the EEA. Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR including:
8.2.1 Ensuring that HubSpot Inc. as our primary processor, has specific policies in place. A signed version of this data processor agreement is available on request by contacting our Data Protection Officer who can be contacted by email at email@example.com, or by post at First Floor, 15 Greek Street, London, England, W1D 4DP United Kingdom.
9 - What Happens If Our Business Changes Hands?
10 - How Can You Control Your Data?
10.1 - When you submit personal data via Our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
10.2 - You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11 - Your Right to Withhold Information
11.1 - You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under applicable UK data protection laws, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 13.10.
13.2 - By using Our Site you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services, and/or parties other than us. Third-party cookies are used on Our Site for advertising, to track how you use and experience our website, build anonymous statistical data about how our website is performing, and to power the personalisation of website content to you. For more details, please refer to section 6, above, and to section 13.6 below.
13.3 - All cookies used by and on Our Site are used in accordance with current cookie law.
13.4 - Before cookies are placed on your computer or device, you will be shown a pop-up banner at the bottom of any of our website pages requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of Our Site may not function fully or as intended.
13.5 - Certain features of Our Site depend on cookies to function. Cookie law deems these cookies to be “strictly necessary”. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken care to ensure that your privacy is not at risk by allowing them.
13.6 – Third-party cookies from Google, Linkedin, Facebook, Twitter, Instagram and HubSpot function on Our Site and may be placed on your computer or device: HubSpot's tracking code sets the following cookies when someone visits Our Site. The following information is detailed information regarding cookies set by HubSpot. These cookies fall into two general categories:
Functional cookies: these cookies do not require consent. Consent banner cookies: there are cookies included in the consent banner under UK GDPR. Specific cookie names and descriptions are listed below, as well as tracking information for the ads tool and cookies from third-party systems:
This cookie can be set to prevent the tracking code from sending any information to HubSpot. (Expires: 6 months)
This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode. It expires in 7 days.
This cookie is used to record the categories a visitor consented to. It expires in 6 months.
This cookie is used to consistently serve website visitors the same version of an A/B test page that they have seen before. (Expires: session cookie)
This cookie is used to save a visitor’s selected language choice when viewing pages in multiple languages. It is set when a visitor selects a language from the language switcher and is used as a language preference to redirect them to sites in their chosen language in the future if they are available.. It expires in 2 years.
When visiting a password-protected page, this cookie is set so future website visits to the page from the same browser do not require login again. The cookie name is unique for each password-protected page. It contains an encrypted version of the password so future visits to the page will not require the password again. It expires in 14 days.
This cookie is used to determine and save whether the chat widget is open for future visits. It is set in your visitor's browser when they start a new chat, and resets to re-close the widget after 30 minutes of inactivity. If your visitor manually closes the chat widget, it will prevent the widget from re-opening on subsequent page loads in that browser session for 30 minutes. It expires in 30 minutes.
This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed. It expires in one day.
This cookie is set when visitors log in to a HubSpot-hosted site. It contains encrypted data that identifies the membership user when they are currently logged in. It expires in seven days.
This cookie is used to ensure that content membership logins cannot be forged. It contains a random string of letters and numbers used to verify that a membership login is authentic. It expires at the end of the session.
This cookie is set by HubSpot’s CDN provider because of their rate limiting policies. It expires at the end of the session.
This cookie is set by HubSpot's CDN provider and is a necessary cookie for bot protection. It expires in 30 minutes.
These are non-essential cookies controlled by the cookie banner.
The main cookie for tracking website visitors. It contains the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). (Expires: 6 months)
This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor. (Expires: 6 months)
This cookie keeps track of sessions. This is used to determine if Hubspot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. (Expires: 30 min)
Whenever HubSpot changes the session cookie, this cookie is also set to determine if the user has restarted their browser. If this cookie does not exist when HubSpot manage cookies, it is considered a new session. (Expires: None. Session cookie)
How are cookies from third-party systems handled?
HubSpot is not able to control the cookies placed by other scripts included on our website. However, we can choose to use the cookie consent banner to know when a website visitor has given consent to place cookies in their browser.
13.7 Our Site uses analytics services provided by HubSpot and Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
13.8 The analytics service(s) used by Our Site use(s) cookies to gather the required information.
13.9 The analytics service(s) used by Our Site use(s) the following cookies: see https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
13.10 In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.