Privacy Policy

DBETA Limited 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 visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. Important information & who we are

Purpose of this privacy policy

This privacy policy explains how DBETA Limited (“DBETA Limited”, “we”, “us”, “our”) collects and processes your personal data when you use this website, including any data you provide when you request information, subscribe to updates, or purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to children. If you are a parent or guardian and believe your child has provided personal data to us, please contact us.

Read this policy together with any other privacy or fair-processing notices we provide on specific occasions. This policy supplements those notices and is not intended to override them.

Controller

DBETA Limited is the controller responsible for your personal data.

We have appointed a Data Protection Lead (DPL) who oversees questions in relation to this policy.

Changes to this policy

We review this policy regularly. Last updated: 23/09/2025. Historic versions are available on request. Please keep us informed if your personal data changes.

2. The data we collect about you

“Personal data” means any information that identifies you. It does not include anonymous data.

• Identity Data (e.g. first name, last name, title, date of birth).
• Contact Data (e.g. billing address, delivery address, email, telephone).
• Financial Data (e.g. bank account and payment card details).
• Transaction Data (e.g. payments to/from you, details of products/services purchased).
• Technical Data (e.g. IP address, browser type/version, time zone and location, operating system, device identifiers, and similar).
• Profile Data (e.g. username, password, preferences, feedback, survey responses).
• Usage Data (e.g. information about how you use our website, products, and services).
• Marketing & Communications Data (e.g. your preferences for receiving marketing).

We also use Aggregated Data (statistical or demographic data) for analysis. Aggregated Data may be derived from your personal data but is not considered personal data if it does not identify you. If we combine or connect Aggregated Data with your personal data so that you can be identified, we treat the combined data as personal data.

We do not intentionally collect any Special Category Data (e.g. health, biometric, or data about your beliefs) or data about criminal convictions/offences.

If you fail to provide personal data

Where we need personal data by law or under a contract with you and you do not provide it when requested, we may not be able to perform the contract (for example, to provide goods or services). We will notify you if this applies.

3. How we collect your personal data

• Direct interactions — you may give us Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise (e.g. enquiries, purchases, support requests, surveys, or competitions).
• Automated technologies — as you interact with our site, we automatically collect Technical Data about your device and browsing actions via cookies, server logs, and similar technologies.
• Third parties/public sources — we may receive personal data from:
  • Analytics providers (e.g. Google Analytics, Google LLC, USA);
  • Search information providers;
  • Payment and delivery providers (Contact, Financial, and Transaction Data);
  • Data brokers/aggregators (Identity and Contact Data);
  • Public sources (e.g. Companies House, the Electoral Register).

4. How we use your personal data (lawful bases)

We will only use your personal data when UK law allows. The lawful bases we rely on are: performance of a contract, legitimate interests (balanced against your rights), legal obligation, and consent (for non-essential cookies/marketing).

We do not sell your personal data.

Purposes for which we use your data

You can withdraw consent at any time for marketing/non-essential cookies by updating your preferences (see Cookies below) or by contacting us.

5. Marketing preferences

You will receive marketing if you requested information or purchased services and did not opt out. We obtain your explicit opt-in consent before sharing your data with third parties for their own marketing.

Opting out: you can stop marketing messages at any time using the unsubscribe link in our emails or by contacting us. This does not affect service messages.

6. Cookies & tracking technologies

We use cookies and similar technologies. Non-essential cookies (e.g. analytics, advertising) are used only with your consent. You can refuse some or all cookies via our cookie banner or browser settings. Blocking essential cookies may impact site functionality.

• Strictly necessary — required for core site functions (e.g. security, log-in).
• Performance/analytics — help us understand how the site is used.
• Functionality — remember your preferences.
• Targeting/advertising — make content/ads more relevant to you.

Manage preferences:

Example cookies we use

• Google Analytics (Google LLC, USA): audience measurement (page views, sessions). Retention and exact cookies depend on your consent settings.

7. Disclosures of your personal data

We may share your data with:

• Internal third parties — group companies (if any) providing IT/admin services and leadership reporting.
• External third parties — service providers acting as processors (IT, hosting, payments, analytics), professional advisers (lawyers, bankers, auditors, insurers), and UK authorities/regulators (e.g. HMRC) where required.
• Business transfers — if we sell/merge our business or assets; the new owner may use your data as set out in this policy.

We require all processors to respect data security and to process your data only on our instructions.

8. International transfers

Some providers are located outside the UK (e.g. in the EEA or USA). Where we transfer your data internationally, we ensure a similar level of protection by using appropriate safeguards, such as:

• UK adequacy regulations/decisions (where available);
• The UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses;
• The UK-US Data Bridge (for certified US organisations).

For details of the specific mechanism used for a given transfer, please contact us.

9. Data security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or loss. Access is limited to people with a business need-to-know and subject to confidentiality. We have procedures to deal with suspected personal data breaches and will notify you and any applicable regulator where legally required.

10. Data retention

We keep your personal data only for as long as reasonably necessary to fulfil the purposes we collected it for, including for legal, regulatory, tax, accounting, or reporting requirements, or to resolve disputes. We consider the amount, nature, sensitivity, potential risk of harm, purposes, and alternatives when setting retention.

By law, we keep basic customer information (Identity, Contact, Financial, and Transaction Data) for six years after you cease being a customer for tax purposes.

In some cases you can ask us to delete your data (see Your Legal Rights). We may anonymise your data (so it can no longer identify you) for research/statistics; in that case we may use the information indefinitely without further notice.

11. Your legal rights

Under data protection law, you may 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 where we rely on legitimate interests, and to direct marketing;
• Request restriction of processing;
• Request data portability;
• Withdraw consent where we rely on consent (e.g. non-essential cookies/marketing).

No fee usually required

You will not normally pay a fee. We may charge a reasonable fee or refuse to act if a request is unfounded, repetitive, or excessive.

What we may need from you

We may request specific information to verify your identity and ensure your right to access your data (or exercise other rights).

Time limit to respond

We aim to respond within one month. If your request is particularly complex or you have made several requests, we will keep you updated.

12. Automated decision-making

We do not carry out automated decision-making that has legal or similarly significant effects on you. If this changes, we will inform you, explaining the logic involved and potential consequences, and your rights.

13. Third-party links

This site may include links to third-party websites, plug-ins, and applications. Clicking those links may allow third parties to collect or share data about you. We are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every site you visit.

14. Glossary

Lawful bases

Legitimate Interests — our interests in running our business, providing services securely, improving and marketing them, and protecting against fraud, balanced against your rights and freedoms.

Contract — processing necessary to perform a contract with you or to take steps at your request before entering into one.

Legal obligation — processing necessary to comply with UK law.

Consent — you have given clear consent for the processing (e.g. for non-essential cookies/marketing). You can withdraw consent at any time.

Third parties

Internal Third Parties — other group companies (if any) acting as joint controllers or processors, which may be based in the UK, EEA, or elsewhere, and which provide IT/system administration and leadership reporting.

External Third Parties — service providers acting as processors (IT, hosting, analytics, payments), professional advisers (lawyers, bankers, auditors, insurers), and public authorities/regulators in the UK.

15. Contact details & complaints

• Full name of legal entity: DBETA Limited
• Email: legal@dbeta.co.uk
• Telephone: +44 20 7164 6988
• Data Protection Lead: legal@dbeta.co.uk

You have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection: ico.org.uk. We would appreciate the chance to resolve your concerns first — please contact us.