Privacy Notice
Last updated: 21st June 2023
Decofy respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our services (including our website).
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
General
When you use our services, we and other organisations may collect some information about you and the devices that you use to access them. You may choose to share your information with us (for example, where you contact us by email to ask a question about our services) and some information is collected automatically using cookies.
If you do provide us with information, it is important that you inform us of any changes so that we can keep the information which we hold about you up-to-date and ensure it remains accurate. We will co-operate with authorities as required by disclosing any details which we hold to them (which may include your identity, contact details, and information about any devices used to access our services).
Quick links
We recommend that you read this Privacy Notice in full to ensure you are fully informed.
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What does Decofy do?
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What personal information does Decofy collect and why?
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Who does Decofy share my personal information with?
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Legal basis for processing personal information
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Cookies and similar tracking technology
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How does Decofy keep my personal information secure?
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Collection of information from minors
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International data transfers
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Data retention
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Your data protection rights
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California Residents
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Virginia Residents
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Controls for do-not-track features
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Updates to this Privacy Notice
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How to contact us
What does Decofy do?
Decofy® is the world’s first mobile shopping platform for paint and wallpaper brands, powered by Adaptive Artificial Intelligence. We are a pioneering and award-winning Deep Tech and mobile commerce company, exclusively serving the consumer coatings industry.
Our headquarters are located at the Cambridge Science Park, home to some of the UK’s most innovative and research intensive companies.
For more information about Decofy, please see https://decofy.com
What personal information does Decofy collect and why?
The personal information that we may collect about you broadly falls into the following categories:
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Information that you provide voluntarily
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We may ask you to provide personal information voluntarily: for example, to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide it.
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Information that we collect automatically
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When you use our services, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
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The information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), and other technical information. We may also collect information about how your device has interacted with our service, including webpages accessed and links clicked. Collecting this information enables us to better understand the users of our services, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our services.
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Some of this information may be collected using cookies and similar tracking technology, as explained below.
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Information that we obtain from third party sources
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We may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
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The types of information we collect from third parties include statistics and usage patterns and we use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you and the services we provide to you.
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In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if this is permitted by applicable data protection laws.
If you provide us with information about someone else, please ensure you have the person’s permission to do so for the purposes detailed in this Privacy Notice. By providing personal data relating to another person, you confirm that you have their consent to do so, or are entitled to consent to the processing on their behalf (for example for children where you have parental responsibility).
Who does Decofy share my personal information with?
We may disclose your personal information to:
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our group companies, and third party services providers who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our services), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
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any competent law enforcement body, regulatory, government agency, court, or other third party where we believe disclosure is necessary: (i) as a matter of applicable law or regulation; (ii) to exercise, establish or defend our legal rights; or (iii) to protect your vital interests or those of any other person;
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an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and
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other persons if you have consented to the disclosure.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only: (i) where we need the personal information to perform a contract with you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Our legitimate interests include, for instance, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make these clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.
Cookies and similar tracking technology
We use cookies and similar tracking technology to collect and use personal information about you, including to serve interest-based advertising.
How does Decofy keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information about you that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
Where we have given you (or where you have chosen) credentials which enable you to access certain parts of our services (such as usernames and passwords), you are responsible for keeping these confidential.
The transmission of information via the internet is not completely secure. Although we will do what we reasonably can to protect your personal data, we cannot guarantee the security of any personal data that you disclose online. You accept the inherent security implications of using the internet and we will not be responsible for any breach of security unless we have been be in breach of applicable laws, and then only to the limits set out in any relevant terms and conditions.
Our services may contain links to and from the services of our partner networks, advertisers, affiliates and members of our corporate group. If you follow a link to any of these, please note that they should have their own privacy policies/ terms of use, and we do not accept any responsibility or liability for them. Please check their privacy notices before you submit any personal data to them.
Collection of information from minors
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dpo@decofy.com.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. Our data servers are located in Ireland where the General Data Protection Regulation (GDPR) is directly applicable.
We may also transfer or disclose your personal information to our service providers, professional advisers, and to such other persons as we consider necessary for the administration of the services and our business. We will ensure all appropriate technical and organisational measures are in place when sharing personal data in accordance with this Privacy Notice.
Data retention
We retain personal information we collect from you where we have an ongoing legitimate need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These include:
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If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
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In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
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You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the unsubscribe or opt-out link in the emails we send you. To opt-out of other forms of marketing, then please contact us using the contact details provided below.
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Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
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Whilst we would prefer you to come to us first with any complaints, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
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We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
California Residents
California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a 'resident' as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as 'non-residents'.
If this definition of 'resident' applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
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Receiving help through our customer support channels;
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Participation in customer surveys or contests; and
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Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
If you are using an authorised agent to exercise your right to opt out we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.
Decofy Limited has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Decofy Limited will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
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Depending on the circumstances, you have a right to know:
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whether we collect and use your personal information;
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the categories of personal information that we collect;
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the purposes for which the collected personal information is used;
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whether we sell or share personal information to third parties;
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the categories of personal information that we sold, shared, or disclosed for a business purpose;
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the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
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the business or commercial purpose for collecting, selling, or sharing personal information; and
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the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
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You may object to the processing of your personal information.
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You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
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You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
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You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at dpo@decofy.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Virginia Residents
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
'Consumer' means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
'Personal data' means any information that is linked or reasonably linkable to an identified or identifiable natural person. 'Personal data' does not include de-identified data or publicly available information.
'Sale of personal data' means the exchange of personal data for monetary consideration.
If this definition 'consumer' applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with Decofy Limited and our Services.
Your rights with respect to your personal data
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Right to be informed whether or not we are processing your personal data
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Right to access your personal data
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Right to correct inaccuracies in your personal data
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Right to request deletion of your personal data
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Right to obtain a copy of the personal data you previously shared with us
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Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')
Decofy Limited has not sold any personal data to third parties for business or commercial purposes. Decofy Limited will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice.
If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at dpo@decofy.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.
Controls for do-not-track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if this is required by applicable data protection laws.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
Post
Data Privacy Officer
Decofy Limited
184 The Bradfield Centre, Cambridge Science Park
Milton Road, Cambridge
Cambridgeshire, CB4 0GA
United Kingdom
The data controller of your personal information is Decofy Limited.
