Introduction

dload understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.dload.com (“Website”) and will only collect and use your personal information in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

When we talk about ‘personal information’ (also known as ‘personal data’) we mean any information about you that enables you to be identified. Personal information covers obvious things such as your name and contact details, but it also covers less obvious things like IP addresses and location data.

Please read this Privacy Policy carefully and ensure that you understand how we collect and use your personal information before you use the Website.

1. Information About Us

The Website is owned and operated by Dukesy Limited, a limited company registered in England & Wales with company number 13291102, and we trade under the name “dload”.

You can contact us by email at [email protected], or write to us at Dukesy Limited, 206 Brickfields Business Centre, 37 Cremer Street, London, England, E2 8HD.

We are registered with the ICO under number CSN9131994. To learn more about your rights to privacy and data protection, we recommend you visit the Information Commissioner’ Office ("ICO") website at https://ico.org.uk/.

2. What Does This Policy Cover?

This Privacy Policy applies only to your use of this Website. If you visit another website using a link in this Website then your use of that other website will be subject to their privacy policy and not this one.

3. Use of Cookies

3.1 Cookies are small text files placed on your computer or device by Our Website when you visit certain parts of Our Website and/or when you use certain features of Our Website. The cookies we use are:

  • a) ‘Session’. This is used to identify you, allow you to log into the Website and to provide authenticated features.
  • b) ‘Locale’. This controls features available on our Website such as language settings.
  • c) Third party cookies. Google Analytics and Hotjar are third parties that provide us with content and functionality on our Website and use cookies. For more information on these, it is advised to check their cookie policies.

3.2. You may restrict our use of Cookies, but preventing them may mean you are unable to access certain features or services. For more information, see https://www.aboutcookies.org.uk/.

4. What Data Do We Collect and How?

4.1. Depending on how you use the Website, we may collect and hold some or all the personal and non-personal data listed below. Apart from your IP address (which is collected automatically by the Website), we receive all the data from the website where you made your purchase (e.g. eBay).

  • a) IP address
  • b) Email address
  • c) Full name
  • d) Full address (personal)
  • e) Telephone number

4.2 While using the Website, you might also be asked to supply the following additional information for location verification purposes. This information is collected and controlled by our partner, VerifyMy, and is not collected or held by us.

  • a) Postcode
  • b) Address
  • c) Full name
  • d) Date of birth
  • e) IP address
  • f) Location (via latitude and longitude)

You can review VerifyMy’s privacy and security policy here.

5. What Do You Do With My Personal Data?

5.1. Under data protection law, we must always have a lawful basis for collecting and using your personal data. The following table describes what we do with your personal data, and our lawful bases for doing so:

What We Do What Data We Use Our Lawful Basis
Registering your account on the Website and providing our services. Email address. Telephone number. Date of birth. IP address You consent to us doing this
Communicating with you in relation to your use of our services. Email address. Telephone number. Full name You consent to us doing this
Requesting verification of your location from a third party service. Email address. Telephone number. Full name. Full address You consent to us doing this

5.2. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

5.3. We use the following automated systems for carrying out certain kinds of decision-making and profiling:

  • a) Third party VerifyMy uses your personal data to verify the country of your location for validation against product purchase constraints.

If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), please contact us by email at [email protected], or by writing to us at Dukesy Limited, 206 Brickfields Business Centre, 37 Cremer Street, London, England, E2 8HD

5.4. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.

5.5. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

5.6. Where required by law, we may process your personal data without your knowledge or consent. This will only be done in accordance with data protection law and your legal rights.

6. How Long Will You Keep My Personal Data?

6.1. We will not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Your personal data will therefore be kept for a maximum of 24 months since your date of last purchase.

7. How and Where Do You Store or Transfer My Personal Data?

7.1 Your personal data is stored either in the UK or within the European Economic Area (EEA).

7.2. If we share your personal data with third parties (as detailed below in section 8.2) that are based outside of the UK, we will make sure that your data is protected in a similar way to how your data is protected within the UK. We do this in several ways. For example, we may use specific contracts which give personal data the same protection it has in the UK. Alternatively, we ensure that the country to which the personal data is transferred has been deemed by the UK government to provide an adequate level of protection.

7.3. Please contact us for further information about the particular data protection mechanisms used by us when transferring your personal data to another country.

7.4. The security of your personal data is important to us, and to protect your data we maintain technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered by your use of the Website. In setting these, we take into account the likelihood and severity those risks might pose to your rights and freedoms. Those measures include, but are not limited to:

  • a) data stored in our databases is encrypted using the AES256 algorithm.
  • b) all communication between services is encrypted in transit using TLS 1.2+.
  • c) eBay customer data is encrypted using the AES256 algorithm or hashed using SHA256 algorithm when used for querying or displaying.
  • d) We do not store plain text sensitive data in our databases.

8. Do You Share My Personal Data?

8.1. We may share your personal data with other companies in our group for our internal business purposes.

8.2. We may share your personal data with third parties that:

  • a) provide services to us (for example, to support the delivery of, provide functionality for, or help to enhance the security of the Website), or
  • b) process personal data for content customisation, personalisation, ad selection and ad delivery and reporting, measurement purposes, or
  • c) otherwise process personal data for purposes that are described in this Privacy Policy, or
  • d) are notified to you at the point of collecting your personal information.

Our third-party services providers are:

  • Google Analytics
  • Hotjar
  • Sendgrid
  • Twillio
  • VerifyMy
  • Cloudflare
  • GCP
  • Atlassian
  • Zendesk
  • ChannelReply

8.3. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

8.4. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

8.5. You may restrict our use of Cookies. For more information, see https://www.aboutcookies.org.uk/.

9. What Are My Rights??

9.1. Under data protection law, you have the following rights, which we will always work to uphold:

  • a) The right to be informed about what data we hold about you and use of your personal data.
  • b) The right to access the personal data we hold about you.
  • c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
  • d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Note that there are limited circumstances in which we are legally entitled to refuse to comply with this request.
  • e) The right to restrict (i.e. prevent) the processing of your personal data.
  • f) The right to object to us using your personal data for a particular purpose or purposes.
  • g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data (as explained in section 7 below), you are free to withdraw that consent at any time.
  • h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data (in a commonly used electronic format).
  • i) The right to request that we transmit all the personal data that we hold about you (in a commonly used electronic format) 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.
  • j) Rights relating to automated decision-making and profiling.

9.2 For more information about our use of your personal data or exercising your rights as outlined above, please email us at [email protected].

9.3 It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

9.4 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

9.5 If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office https://ico.org.uk/make-a-complaint/. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, either by email at [email protected], or by writing to us at Dukesy Limited, 206 Brickfields Business Centre, 37 Cremer Street, London, England, E2 8HD.

10. Changes to this Privacy Policy

10.1. We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

10.2. Any changes will be immediately posted on the Website, and we recommend that you check this page regularly to keep up to date.

10.3. This Privacy Policy was last updated on 30th October 2023.