Privacy Policy

Introduction

This Privacy Policy explains what personal and other information is collected by Digestible Tech Limited t/a Callworthy (a company registered in England with number 11913276 and its registered office at Crown House, 27 Old Gloucester Street, London, England, WC1N 3AX, “we”, “us”, “our”, “Callworthy”) as part of our activities, and how we use that information.

This Privacy Policy explains how we may use personal information that we obtain about you, and your rights in relation to that information.

The EU General Data Protection Regulation (GDPR) as well as the UK Data Protection Act 2018 (“Data Protection Laws”) give you various rights regarding the way in which we store and use your personal information. These are set out below in the section “What are your legal rights in relation to your personal information?” below. You can also get further information about data protection and privacy laws by visiting the Information Commissioner’s web site at: https://ico.org.uk/.

If you have any questions about this Privacy Policy, our practices, or your dealings with Callworthy, please send us an email at info+privacy@callworthy.com.

1. The scope of this Privacy Policy

1.1 This Privacy Policy applies in the following circumstances:

• when you subscribe to Callworthy as a user or enter your details as a call recipient

• when you request information from us or provide information to us, whether in the course of subscribing as a user, entering your details as a call recipient or otherwise

• when you visit our website

• when you sign up to our newsletter

• when you agree to be included in our mailing lists to receive information and other marketing material, whether by email or other methods

1.2 We only use 'necessary' cookies on our website.

2. What information do we collect about you, and how?

2.1 Subscribing to Callworthy as a user

When you subscribe to Callworthy as a user, we collect various personal information which may include your name and contact details (such as your address, email address and telephone numbers), as well as information about your payment card or other payment method.

2.2 Enter your details as a call recipient

TBC once the product has been built.

2.3 When you visit our website

When you visit our website we obtain personal information from your IP address and the operating system and web browser that you use. This enables us to compile statistical data on the use of our website which helps us to improve the user experience.

2.4 When you sign up for our newsletter, request information from us about our services, or provide us with information

In our dealings with you, whether in person, by telephone, letter, email or webchat, you may directly provide us with various types of personal information, including your name and contact details (such as your address, email address and telephone numbers). We may also collect personal information if we are communicating with you on social media sites such as Twitter, Facebook, Instagram or LinkedIn.

2.5 When you agree to receive marketing information

If you agree to receive marketing information your personal information may be stored in our contact database. If you no longer wish to receive any marketing emails from us you can unsubscribe at any time by using the “Unsubscribe” button on the email footer or by contacting info+privacy@callworthy.com.

3. How do we use your personal information?

3.1 We will only use your personal information in compliance with Data Protection Laws. Accordingly we will therefore only process your personal information if:

• it is necessary for the performance of a contract with you

• it is necessary in connection with a legal obligation

• you have given your consent (where necessary) to such use

• if we or a third party have a legitimate interest which is not overridden by your interests or your rights and freedoms

3.2 We may use your personal information for the following purposes:

• if you subscribe to Callworthy, to process your payment and to provide you with our software services

• if you subscribe, to provide you with our newsletter

• if you have opted in to receive marketing communications from us, to send you information about our services and other marketing material

• if you have opted in to receive communications from us, to upload your contact details in a securely encrypted format to Twitter, Facebook, Instagram and LinkedIn. If these platforms determine that you have an account with them then we will show you marketing material and other information that we think will be of interest to you. Note that if any of the social media platforms do not recognise your contact details then your details are promptly deleted

• to process and respond to your requests for information, or to enquiries or any complaints received from you

4. For how long do we keep your personal information?

4.1 We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including for the purposes of complying with any legal, accounting or insurance requirements. If you wish to know more about our retention periods, please contact info+privacy@callworthy.com.

4.2 On expiry of the applicable retention period, we will securely destroy your personal information in accordance with applicable law.

5. How and why do we share your personal information?

5.1 We use third parties who provide services to us or on our behalf, and we will share your information (including personal information) with them. Third parties which may have access to your personal information, and the purposes for which we may share your information, include:

Third party service provider: Stripe Payments Europe, Ltd.

Website: https://stripe.com/gb

Purpose for which we share your information: Processing payments for software products

Third party service provider: The Rocket Science Group LLC d/b/a Mailchimp

Website: https://mailchimp.com/

Purpose for which we share your information: Managing our newsletter and email marketing lists

Third party service provider: Netlify, Inc

Website: https://netlify.com

Purpose for which we share your information: Hosting our website

Third party service provider: Google Ireland Limited (or one of its affiliates)

Website: https://workspace.google.co.uk/

Purpose for which we share your information: Managing email and administrative tasks

Third party service provider: Crisp IM SARL

Website: https://crisp.chat/

Purpose for which we share your information: Providing online chat to prospective and current customers through the website

Third party service provider: Conva Ventures Inc.

Website: https://usefathom.com/

Purpose for which we share your information: Providing web analytics

5.2 Some of your personal information may be stored in a private cloud and managed by a third party service provider.

5.3 In addition we may share your personal information with third parties where:

• you have consented to us doing so (where necessary)

• it is necessary for the purpose of, or in connection with, legal proceedings or in order to exercise or defend legal rights

• it is appropriate to disclose the information to parties with whom we have promotional arrangements (such as jointly hosted events).

5.4 Some of our suppliers and service providers may store or otherwise process personal information outside the UK or the European Economic Area. Where this is the case, we will ensure that your personal information will only be transferred either to countries that have been identified as providing adequate protection, or to a third party where there is a legal transfer mechanism in place to protect your personal information, for example where the supplier or service provider has entered into the European Commission’s Standard Contractual Clauses.

6. How do we keep your personal information secure?

6.1 We use up to date data storage and security to hold your personal information securely in electronic and physical form to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. Our electronic databases require logins and password authentication. Password managers are also used.

6.2 All our directors, employees and third party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.

6.3 However, the transmission of information via the internet is not completely secure. Although we take appropriate and proportionate steps to manage the risks posed, we cannot guarantee the security of your information transmitted to our online services.

7. Third party sites

7.1 Our website may contain links to other sites which are controlled by third parties. You should review these other sites’ privacy policies. We do not accept any responsibility for their use of your personal information.

8. What are your legal rights in relation to your personal information?

8.1 You have the following data protection rights:

• You have the right at any time to withdraw your consent to our processing of your personal information.

• You have the right to be told what personal information we hold about you on our database and how we process that data.

• You have the right to request that we provide you with a copy (in a commonly used electronic format) of all the personal information that we hold about you. Unless you make repeated requests, we will not charge a fee for providing you with a copy of this data.

• You have the right to request that we correct any inaccurate or incomplete personal information that we hold about you.

• You have the right to request that we irretrievably delete all personal information that we hold about you (the so-called “right to be forgotten”). Note that there are limited circumstances in which we are legally entitled to refuse to comply with this request.

• You have the right to request that we transmit all the personal information that we hold about you (in a structured, commonly used and machine-readable form) to another organisation’s IT environment. Note that we are only legally obliged to comply with this request if it is technically feasible for us to do so.

• 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 the UK Information Commissioner’s Office at: https://ico.org.uk/concerns/.

8.2 If you wish to exercise any of the rights set out in Section 8.1 you can do so by sending us an email at info+privacy@callworthy.com.

9. Changes to this Privacy Policy

9.1 We may update this Privacy Policy from time to time in response to changing legal, technical or business developments, so please review it frequently. If we update our Privacy Policy and the amendments involve a material change to the way we collect, use, share, store or otherwise process your personal information then we will take appropriate measures to inform you, consistent with the significance of the changes we make.