DOJO PRIVACY POLICY FOR CONSUMERS
We are WalkUp Limited. Dojo is a trading name of WalkUp Limited.
Our registered office address is The Brunel Building, 2 Canalside Walk, London W2 1DG and our company number is 10993703.
We are registered with the Information Commissioner's Office (ICO), the data protection regulator in the UK, to use personal data and our registration number is ZA485977.
We are committed to protecting and respecting your privacy.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using it.
When you visit our website, or use any of our applications; or provide information to us via our website, or any of our applications, you are accepting and consenting to our processing of your information in accordance with this Privacy Policy, our Cookie Policy, our Website Terms and Conditions and any other contract we may have with you.
This Privacy Policy applies to any of our or our group’s processing activities in relation to our ‘consumer’ products and services. If you are using any of ‘business-to-business’ product, please see our Privacy Policy for Business, which describes how and why we process any personal data in respect of any activities in connection with our ‘business-to-business’ products and services.
The personal data we hold about you needs to be accurate and current. Please keep us informed if this information changes during your relationship with us. You can get in touch with us at dataprotection@dojo.app or by phone on 0800 103 2959.
If you have any questions about this Privacy Policy or how we handle privacy, please contact us at dataprotection@dojo.app or by phone on 0800 103 2959.
You have the right to make a complaint to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at dataprotection@dojo.app or by phone on 0800 103 2959.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address, telephone numbers and bank account details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, the type of mobile device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. We may also collect information store on your device used to access the App such as contact information, friends lists, login information, photos, videos or other digital content and check ins.
Usage Data includes information about how you use our website, app, products and services including but not limited to traffic data, weblogs and other communication data.
Location Information where we use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the supply of our services to you but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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Purpose/Activity |
Lawful basis for processing including basis of legitimate interest |
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To register you as a new customer |
Performance of a contract with you |
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To process and deliver services to you |
Performance of a contract with you |
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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) 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) |
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To enable you to partake in a prize draw, competition, referral programme or complete a survey |
(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) |
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To administer and protect our business and our Website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(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 |
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To deliver relevant Website and App content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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) |
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To use data analytics to improve our Website, App products/services, marketing, customer relationships and experiences |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
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To make suggestions and recommendations to you about goods or services that may be of interest to you |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
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To make available your basic contact details to our partners (such as restaurants and retail outlets) for the purposes of contact tracing under the NHS Test and Trace service or similar system in relation to Covid-19 (or any other pandemic) |
(a) Necessary for the legitimate interests of our partners (to protect their businesses and comply with government guidance and legislation) (b) Necessary to protect your vital interests and those of other natural persons (c) Necessary to comply with a legal obligation (d) Necessary for a task carried out in the public interest |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or requested services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website or App and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service experience or other transactions.
You can set your browser to refuse all or some browser cookies, or to alert you when websites or applications set or access cookies. If you disable or refuse cookies, please note that some parts of our Website and App may become inaccessible or not function properly.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
When we transfer your information outside of the UK and EEA (as applicable), we will:
If we transfer your information outside the UK or the EEA in other circumstances (for example, because we have to reveal the information to help prevent or detect a crime), we’ll make sure we share that information lawfully.
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
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Your right to: |
What this means |
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ask us to send you (or someone you nominate) a copy of the information we hold about you |
We provide this privacy notice to explain how we use your personal data |
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access your personal data with us |
If you make a ‘data subject access request’ to us, we will provide a copy of the personal data we hold about you. We can’t give you any information about other people, information which is linked to an ongoing criminal or fraud investigation, or information which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers |
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ask us to correct or delete any incorrect or incomplete information we hold about you (we will correct any information we believe is incorrect or incomplete) |
You can have incomplete or inaccurate information corrected. Before we update your records with us, we may need to check the accuracy of the new information you have provided |
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ask us to stop using your information |
We will stop using your information if there is no legal reason for us to continue to hold or use it |
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object to any automated decision-making |
In the event that you request the deletion of personal data or for the use of personal data to be restricted, we reserve the right to no longer provide services and products to you under any applicable contract |
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ask us to transfer certain personal data to you or to another organisation, including service providers, in a format they can use where this is technically possible (known as the ‘right to data portability’) |
We will transmit personal data in structured, commonly used and machine readable formats |
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ask us to transfer a copy of some of your information to you or to another organisation, including service providers, where this is technically possible |
We will transmit personal data in structured, commonly used and machine readable formats |
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withdraw any permission you have previously given to allow us to use your information |
If you have given us any consent we need to use your personal data, you can withdraw your consent at any time by contacting us at: dataprotection@dojo.app or by phone on 0800 103 2959 |
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ask us to stop or start sending you marketing messages at any time |
Please get in touch with us on dataprotection@dojo.app or by phone on 0800 103 2959 to do this |
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.
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.
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.