Welcome to the Dashly website, an online service designed and operated by Dashly Ltd (“We”, “Us” and “Our”) which, amongst other things, compares financial products including mortgages and other services that may be available to you depending upon your circumstances. These Terms of Use are intended to explain our obligations as a service provider and your obligations as a user and subscriber. IT IS IMPORTANT THAT YOU READ ALL THE TERMS AND CONDITIONS CAREFULLY.


Who are we and how to contact us

Dashly (“We”, “Us” and “Our”) is a limited company registered in England and Wales under company number 09619788. Our main trading address is Found Studios, 1 Lindsey Street, London, EC1A 9HP. Our VAT number is 26467408.

We are registered with the Information Commissioner's Office (ICO) with registration number ZA308181.

To contact us, please email support@dashly.com.


By using our site you accept these terms

These terms tell you the rules for using our website (www.dashly.com) (our Site). By accessing and using our site, you (also "user" below) agree to be bound by the terms and conditions below and the website privacy policy.

Please review them carefully. If you do not agree to the terms and conditions or website privacy policy then you must not use the website. We recommend that you print a copy of these terms for future reference.


There are other terms that may apply to you.

These terms of use refer to the following additional terms, which also apply to your use of our Site:

  • Our Privacy Policy. See further under clause.
  • Our Acceptable Use Policy, which sets out the permitted uses and prohibited uses of our site. When using our site, you must comply with this Acceptable Use Policy.
  • Our Cookie Policy, which sets out information about the cookies on our site.

We may make changes to these terms

We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time.

These terms were most recently updated on 20th May 2018. Previous versions of these terms can be found archived at.


Access to and Use of Our Site

Setting up an Account

Certain parts of Our Site may require an Account in order to access them. In order to avail of our Services, you must set up an Account on our Site via Registration.You may not create an Account if you are under 18 years of age.

During Registration, the information you provide must be accurate and complete. If any of your information changes at a later date, it is your responsibility to ensure that your Account is kept up-to-date.

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures during Registration, you must treat such information as confidential.

During Registration, you will be asked to provide a password to enable you to log in to your Account. We require that you choose a strong password for your Account, consisting of a combination of lowercase and uppercase letters, numbers and symbols. Each password must kept confidential by its Registered User. If you fail to keep this password confidential, you are entirely responsible for any consequences stemming from such failure. Please see our Privacy Policy.

Account Security and Use

You must notify us immediately if you suspect or become aware that the confidentiality of your Account has been compromised.

We reserve the right to terminate your Account if:

  • it is established that you hold more than one Account;
  • someone else is using your Account;
  • You are disrupting Our Site, breaching these Terms and Conditions, the Privacy Policy, or the Acceptable Use Policy; or
  • You have provided false or incorrect information at the time of Registration.

You must notify us immediately if you suspect or become aware that the confidentiality of your password has been compromised at DPO@dashly.com

Account Deactivation and Reactivation

You may at any time temporarily deactivate your Account. Whilst your Account is deactivated, you will not be able to use any of the Services and you will not receive any notifications from Dashly other than those regarding Policy and Account support. You may reactivate your account at any time. If your account has been deactivated for 5 years we will close your Account and any of your Profile Data will be dealt with in accordance with our Account Closure and Deletion policy below.

Account Closure and Deletion

You may at any time close your Account. Closing your Account will result in the removal of your Profile Data. Closing your Account will also remove access to any areas of Our Site requiring an Account for access. Your Profile Data will be deleted, save for any data which we are required to retain by law, and to comply with our obligations as a firm regulated by the Financial Conduct Authority. For more information, please see our Privacy Policy. If you close your Account, any Customer Content you have created on our Site will be anonymised.

We may make changes to our site

We may update and change our site from time to time to reflect changes to our products, our users' needs and our business priorities or for any regulatory reason.

We may suspend or withdraw our site

Access to our site is made available free of charge. It is your responsibility to make any and all arrangements necessary in order to access Our Site.

We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

Our site is only for users in the UK

Our site is directed to people residing in the England, Scotland and Wales, and for mortgages in respect of properties in those countries. We do not represent that content available on or through our Site is appropriate for use or available in other locations.

Our responsibility for loss or damage suffered by you
  • We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
  • Please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
  • For the provision of our Dashly Mortgage Advice/Brokerage service we are covered by the Financial Services Compensation Scheme (FSCS). You may be entitled to compensation from the FSCS if we cannot meet our obligations. The Scheme for mortgage advising and arranging covers 100% of the first £50,000. Further information about the compensation scheme arrangements is available from the FSCS.

Your Obligations

By using the Site, you agree that:

  • You will not do anything that affects the integrity or security of this website or causes or may cause harm, damage or unreasonable inconvenience to other users of this website or us;
  • You will not gather, extract, download, reproduce and/or display or advertise on any other website, other online or off-line service or otherwise, any material on or from this website, including but not limited to information relating to insurance prices, whether that information has been gained by the use of spiders, data mining, trawling or other 'screen scraping' software or system used to extract data.

If you do any such acts, we may take such action as we deem appropriate, including denying you access to our Site, bringing legal proceedings against you and disclosing such information to appropriate legal and/or regulatory bodies.


The Service

We provide two services:

  1. Dashly Financial Comparison
  2. Dashly Mortgage Advice/Brokerage("Services")

Dashly Financial Comparison

The Dashly Financial Comparison service enables you to compare a number of prices for products and services, as well as product information from the whole mortgage market, based on your Profile Data. This will enable you make an informed decision before proceeding to your chosen provider for further information.

When providing this service, we are acting as an independent online financial comparison search provider. We offer access to the full range of mortgage products available in the England, Scotland and Wales markets, as applicable to you. When it comes to our providers, we offer impartial and independent comparison.

We will provide recommendations for financial products to you on our Site, and will also send you notifications from time to time, in the form of comparison results, ranked according to the potential savings we believe may be available to you, based on your Profile Data.

If your Profile Data was inaccurate, not up-to-date, or your needs or circumstances have changed since you last updated your Profile Data, then you should update your Profile Data so that we can provide you with accurate recommendations, or speak to a mortgage advisor. We will notify you if your updated Profile Data changes our recommendations to you.

Dashly also relies upon the availability of third party systems and websites, including Lenders. At times some or all financial products may not be available to you due to problems with third party websites or connectivity. Wherever possible, we will try and notify you of this and email you to let you know when your Comparison Results are ready.

The Comparison Results will provide financial product links, which will take you to third-party websites. Any transactions entered into by You and a third-party provider will be governed by that third-party’s terms and conditions. We have no control over the contents of those sites or resources.

Each entry on the Comparison Results is for the purposes of illustration and is not an offer from a Lender to provide you with that product. The Lender will require more detailed information from You before it can assess whether it is willing to provide you with the product. Before the lender gives you a binding offer you will be provided with a detailed explanation of the terms of the mortgage.

The Dashly Financial Comparison service is free for You to use. We may receive a fee and/or commission from a third-party product or service provider in relation to products or services which have been made available to you through our Dashly Financial Comparison service.


Dashly Mortgage Advice / Brokerage

We can also provide a free mortgage advisory service to You. When providing this service, we are acting as a mortgage intermediary. We can offer you access to a range of mortgage products from a panel of lenders in the UK mortgage market. Our Dashly Mortgage Advice service may only be applied for by individuals and not for business purposes, with the exception of any Buy-to-let mortgages.

If you meet the relevant criteria, we will send you a selection of mortgages based on your Profile Data, and any discussions which we have had with you. Please take time to review such selection. Where we have recommended mortgage products to you, these are provided by third party Lenders.

Fees and Key Facts
  • The Dashly Financial Comparison service is free for You to use. We may receive a fee and/or commission from a Lender in relation to a mortgage product or related services, which have been made available to you through our Dashly Financial Comparison service. The amount of commission paid to us by the Lender will be notified to you prior to you entering into that product with the Lender.
  • You will receive a key facts illustration European Standardised Information Sheet (ESIS) when considering a particular mortgage, which will tell you about any fees relating to that mortgage.
  • You have the right to request an ESIS for any mortgage we recommend.
  • We do not handle funds or monies on your behalf.
Mortgage Application
  • Dashly will guide you through the stages of the mortgage application process.
  • Once we have submitted your application to your chosen Lender, we will send you an email to confirm that we’ve done that. We will then work with you and liaise with your lender to complete the process. Completion is the drawdown of your mortgage – when the money is in yours or your solicitor’s bank account. We will continue to keep you informed throughout the mortgage process, either by text, email, phone call or letter.
Discontinuance and Other Application Elements
  • If you start a mortgage application and do not finish it we will send you a range of reminders offering tips and advice on how to complete your mortgage application.
  • Our calls with you may be recorded and used for training and regulatory purposes.

Your Profile Data

You can upload Profile Data documents to your Account. The documents will need to be of sufficiently legible quality so that we can review the contents. We use automation, including OCR, to process the content of your uploads and pre-populate sections of your Profile Data. You must review all pre-populated sections following upload, as any errors due to lower quality scans are your responsibility and may reduce the accuracy of any services provided to you based on those uploads.

Whenever you upload content to our Site, or make contact with other users of our site, you must comply with the content standards set out in our Acceptable Use Policy. You warrant that any upload does comply with those standards, and you will be liable to us and indemnify us for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.

We have the right to remove any posting you make on our site if, in our opinion, your post does not comply with the content standards set out in our Acceptable Use Policy .

You are solely responsible for retaining original copies of all Profile Data uploaded to our Site, and we are not liable for any loss of data, or other consequential losses, for any loss of documents uploaded to our site.

You may be entitled to rights separate to these Terms and Conditions under English consumer law or other legislation.


Rights you are giving us to use material you upload

When you upload or post content to our site, you grant us the following rights to use that content:

  • A licence to process the content in order to provide you with our services.
  • For our Dashly Mortgage Advice/Brokerage a licence to provide mortgage application data, including elements of your Profile Data to Lenders, as part of your mortgage application.

We are not responsible for viruses and you must not introduce them

We do not guarantee that our site will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.


Intellectual Property

How you may use material on our site

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged.

You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.


Disclaimers

Unless you are using our Services, nothing on our Site is intended to be, or should be construed as:

  1. An invitation, offer or inducement to you or any other person to engage in investment activities or any other type of financial arrangement; or
  2. Advice on the merits of, or a recommendation in relation to, any particular product or product provider.

Insofar as is permitted by law, We make no representation, warranty, or guarantee that Our Site will meet your requirements, that it will not infringe the rights of third parties, that it will be compatible with all software and hardware, or that it will be secure. If, as a result of Our failure to exercise reasonable care and skill, any digital content from Our Site damages your device or other digital content belonging to you, you may be entitled to certain legal remedies. For more details concerning your rights and remedies as a consumer, please contact your local Citizens Advice Bureau or Trading Standards Office.


Our trade marks are registered

"DASHLY" and the Dashly Logo are UK registered trade marks of Dashly Limited. You are not permitted to use them without our approval.


Rules about linking to our site

  • You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.
  • You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
  • You must not establish a link to our site in any website that is not owned by you.
  • Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.
  • We reserve the right to withdraw linking permission without notice.
  • The website in which you are linking must comply in all respects with the content standards set out in our Acceptable Use Policy.

If you wish to link to or make any use of content on our site other than that set out above, please contact help@dashly.com.


Complaints

Dashly welcomes and encourages feedback of all kinds from our customers. If you have a Complaint about our services, our customer service, or about our staff, not only do we want to resolve it to your satisfaction but we also want to learn from it in order to improve our business and customer experience in the future.

If you have any questions or complaints about the services, please contact us. You can write to us at support@dashly.com and Customer Services, Dashly Ltd, Found Studios, 1 Lindsey Street, London, EC1A 9HP..

It is our policy to resolve Complaints quickly and fairly, where possible without recourse to formal investigations or external bodies. In particular, the aims of this Complaints Policy are:

  • To provide a clear and fair procedure for any customers who wish to make a Complaint about Dashly, our services, our customer service, or about our staff;
  • To ensure that everyone working for or with Dashly knows how to handle Complaints made by our customers;
  • To ensure that all Complaints are handled equally and in a fair and timely fashion;
  • To ensure that important information is gathered from Complaints and used in the future to avoid such a situation arising again.
  • When making a Complaint, you will be required to provide the following information in as much detail as is reasonably possible:
  • Your name, address, telephone number and email address (We will contact you using your preferred contact method as your Complaint is handled);
  • If you are making a Complaint about a particular staff member of ours, the name and, where appropriate, position of that staff member;
  • Further details of your Complaint including, as appropriate, all times, dates, events, and people involved;
  • Details of any documents or other evidence you wish to rely on in support of your Complaint;
  • Details of what you would like us to do to resolve your Complaint and to put things right.

(Please note that whilst we will make every reasonable effort to accommodate such requests, we are not bound to take any action beyond that which we may be contractually or otherwise legally obliged to take.)

If your Complaint concerns a product or service that you have purchased through either of our Services, you can complain directly to the relevant product or service provider responsible for supplying the product or service about which you wish to complain.

We cannot answer complaints on behalf of a Lender or other third party, nor accept responsibility for any such complaints. The complaint handling policy for such parties will be set out on their websites, and we recommend that you visit the website of the product or service provider and follow this complaints handling policy.

We will seek to resolve your Complaint as soon as possible. We will send you an acknowledgement of your Complaint to you within five business days of its receipt. In this acknowledgement we will advise you of the person who will be dealing with your complaint.

If eight weeks have elapsed since the receipt of your Complaint without resolution, we will send you a notification setting out why we are still not in a position to issue a decision on your Complaint and advising you of when we expect to be able to do so.

You may after eight weeks, or if you are unhappy with our response to your complaint, contact the Financial Ombudsman Service who may be contacted at Exchange Tower, London, E14 9SR or by telephone on 0800 0234567. Their website is at www .financial-ombudsman.org.uk

All Complaints and information relating thereto are treated with the utmost confidence. Such information will only be shared with those staff of Dashly who need to know in order to handle your Complaint.

Which country's laws apply to any disputes?

If you are a consumer, please note that these terms of use, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.


Definitions

  • Account: means an account required for a User to access and/or use certain areas of Our Site
  • Registered User: means a user who has completed Registration.
  • Registration: means the act by a user of creating an Account.
  • Broker: means a mortgage broker or advisor.
  • Lender: means a provider of mortgage funding.
  • Customer Content: any reviews, posts, testimonials and other content generated by a Registered User.
  • Profile Data: means all of: the information provided by you on Registration, as updated by you in your Account; any uploads to your Account; any Fact Find information provided by You and any financial and suitability discussions which you have with our Staff.
  • “you” and “your” means the person who proposes to use or is using this website.
  • “product or service provider” means the Broker, Lender, bank, building society or other financial institution or any other third party providing any financial service or product identified on this website or made available via this website.
  • “quote” means the details of particular Lender’s offerings whose mortgage products are identified as being of relevance to you and are shown to you by comparison against other Lenders. Quotes are selected for your attention by reference to a number of factors including but not limited to your Experian credit score, the value of the mortgage you are seeking and affordability assessment based upon the information you have provided. In providing you with a quote we are not able to guarantee the availability of the product, the service or the price set out as you will need to deal with the product or service provider direct to make a purchase.
  • “writing” includes emails and text messages. When we use the words "writing" or "written" in these terms, this includes emails.

Dashly is committed to protecting the privacy and confidentiality of personal information in our possession and control. This Privacy Notice explains the measures we take to fulfill these commitments and describes the manner in which we collect, use, discloses and otherwise treats personal information through our website available at dashly.com, including all subpages and successor pages (collectively referred to as the “Website”) as well as through other interactions with our clients and prospective clients.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.


  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights
  10. Glossary

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Dashly collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our service, newsletter, mailing list or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 your data. This privacy notice supplements the other notices and is not intended to override them.

Your acceptance of this Privacy Policy is deemed to occur upon your first use of our Site. You will also be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately.

Controller

Dashly Ltd is the controller and responsible for your personal data (collectively referred to as "Dashly", "we", "us" or "our" in this privacy notice).

We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise (your legal rights), please contact the data privacy manager using the details set out below.

Contact details

Dashly Ltd
Privacy Officer
Found Studios
1 Lindsey Street
London
EC1A 9HP.
dpo@dashly.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (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.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 20th May 2018.

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.

Third-party links

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


2. The data we collect about you

We ask our clients for no more personal information than necessary

Dashly needs to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal and regulatory obligations. Understanding a customers needs and wants, financial position and family circumstances enables us to ensure that all recommendations are suitable. This is both a regulatory requirement and good business. Dashly is committed to protecting our customers privacy and the confidentiality of their personal information in our possession. We may collect process store and transfer the following information about you;

  • The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone numbers, email addresses, birth date, investment knowledge and objectives. We also collect optional beneficiary information (e.g. spouse’s name and occupation, children’s and dependents’ names and ages).
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, optional government issued identifiers for I.D. verification purposes such as national insurance, passport and driving licence numbers.
  • Contact Data includes address history, email address and telephone numbers.
  • Financial Data includes bank account details, residential status, your income and outgoings, credit history including details of any history of bankruptcy or county court judgements, account details of any mortgages held, property and asset values, and, if the lender requires, direct debit details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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 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.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

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.

If you fail to provide personal data

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 a product or service you have with us but we will notify you if this is the case at the time.


3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • sign up for our services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:
    • Technical Data from:
      • analytics providers and website experience recording services such as Google, Mixpanel and FullStory based inside and outside the EU;
      • advertising networks or providers such as Facebook, DoubleClick based inside the EU; and
      • search information providers based the EU.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
    • Identity and Contact Data from CallML (as part of the anti-money laundering checks we’re required to undertake).
  • Joint Mortgage applicants. If you’re a joint mortgage applicant, please ensure that any other joint applicants have given their consent to their personal data being processed as set out in this Privacy Notice. Whenever a joint application is made, we will assume that the main applicant has secured the express consent for any necessary processing set out in this Privacy Notice, from all other joint applicants.

4. How we use your personal data

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:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Click [here] to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.

Purposes for which we will use your personal data
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.

Purpose / Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
Performance of a contract with you
To process and deliver your order including:
  1. Manage payments, fees and charges
  2. Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. 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)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
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)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
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)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can control your choices through the following personal data control mechanisms:

Promotional offers from us

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 purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting dpo@dashly.com 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 a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information see section 11 below.

Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.


5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • [[Specific third parties [listed in the table in [paragraph 4] above] OR such as [SPECIFIC THIRD PARTIES]].]
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.


6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).


7. Data security

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.


8. Data retention

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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.


10. Cookies

Our Site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

All Cookies used by and on our Site are used in accordance with current Cookie Law.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings

Except for essential cookies, all cookies will expire after 12 months.


11. Glossary

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of our Site;
“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in our Group based in the United Kingdom and who provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

When it comes to keeping your data and information secure, we never rest. We’ve built bank-grade security measures into the system to make sure you can use Dashly with confidence.


Data Security

Secure data transmission: When you load a page in your browser, or upload something to Wave, all that information is encrypted while it’s moving over the internet. We lock up your data with up to 256-bit TLS encryption, the strength of protection you get with online banking and shopping. We also support a wide variety of cyphers — another kind of code — for our communications, to ensure the highest level of encryption possible, based on your browser.

Secure data storage: Your accounting data is stored on servers that have strict physical access protocols, meaning there are rules in place limiting access to only the people who need it to do their jobs. The facilities are controlled with 24/7 monitoring, and the technology is digitally protected.

Security Testing: Wave uses many layers of security testing. We test our systems internally, but that’s not enough in our opinion. We also regularly bring in third-party security firms such as Netitude and TrustArc to perform vulnerability assessments and penetration tests against our systems.

Transparency: We’re not asking you to just take our word for it that we keep your data secure. We want you to understand exactly how it’s done. That’s why we’ve written, a very clear and understandable Privacy Policy.


Mobile Security

Passwords are encrypted when they’re collected, when they’re sent to our servers, and we never store them without encrypting them first. In fact, all communications between our apps and our servers are encrypted using Transport Layer Security (TLS) — the replacement for Secure Sockets Layer (SSL) — the highest level of security protocols available. Beyond that, we don't store any sensitive information, such as account numbers, on the device ever.


Fraud Prevention

We’ve built an internal risk system that uses a wide variety of tools and insights to protect you and your customers from fraud. We’ve integrated several third-party security and anti-fraud service providers to create a layered approach to risk detection, for the highest level of protection. And our team of risk analysts monitor high risk and out-of-pattern behaviour to keep our platform safe.

We’ve got your back when it comes to chargebacks. Our team is trained to coach you in best business practises to make sure you’re collecting the right information up front to protect your business from chargebacks. In the event that you do receive a chargeback (it happens!) our experts have the experience necessary to build your best case.


GDPR

As a company, Dashly complies with the General Data Protection Regulation (GDPR). We take customer data privacy seriously, ensuring that:

  • Personal data is properly collected, stored, and documented.
  • Any usage of personal data is communicated with the proper consent.
  • All new vendors, assets and activities pertaining to processing personal data are subject to a review of privacy, security and compliance.
  • Relevant processes are followed for transfers of personal data outside the European Union.

Account Verification

Dashly uses Auth0.com to safeguard our users accounts, with default email verification at account creation time and during password resets. Auth0 has been built on tested, verified identity standards, including LDAP, SAML, OAuth, OpenID, OpenID Connect, and JSON Web Tokens (JWTs) - all of the common and most popular identity standards. Auth0 participates in standards organisations like the OpenID Foundation making it easy for Dashly to leverage these powerful standards to shield our own applications and APIs.


Do you have additional questions about the security of Dashly? If so, please don’t hesitate to contact us. We’d be happy to tell you more about the many steps we take to ensure the security of your sensitive information.