Destini Global LLC is the controller of the Personal Data collected. This means it determines how and why to process your Personal Data. Although the product locator appears on the website or in the application of our client, the product locator service is provided by Destini and our affiliates and service providers.
Collection of Personal Data
We collect your Personal Data in the following ways:
- Information that you provide to us. You may enter information, such as a post code or address, or products that you are interested in locating, in connection with using the product locator.
- We do not require you to provide your name in order to use the product locator. However, we may collect your name and email address where the product requested is not available, so that we can notify you if and when the product becomes available.
- You may provide us with an email address for yourself, a friend, family member or other third party so we can send information that you request to that email address. We will use that email address only for the purpose of notifying the recipient of the email, that a product is available. The recipient of the email may contact us to remove the email address from our systems, and we provide information regarding how to remove the email address in the email that we send.
- Information that we obtain from your use of the product locator. When you use the product locator, we may obtain information about products you are searching for and shop locations that are relevant to you.
- Information you allow us to collect. If you allow us, we will automatically collect the location of your device to auto populate the post code field in the search function. If you wish to disable access to the location services, you can do so by making changes in your device using the settings feature.
We are unable to identify you personally using only the Personal Data we obtain from your use of the product locator. It is not until you provide us with your name and email address (if you choose), that we can link the Personal Data we have obtained about you, to you personally.
Use of Personal Data
We will only use your Personal Data when the law allows us to. The purposes for which Destini collects and uses your Personal Data are set out in the table below, together with the corresponding legal basis that we rely on for collecting and using such data:
|To provide the product locator service to you||Necessary for our legitimate interests (to provide a service requested by you)|
|To monitor your use of the product locator so that we can understand how you use the product locator and make improvements to the product locator and our other services accordingly||Necessary for our legitimate interests (to analyse usage of the product locator to better understand our products, services and business in general, to identify shop locations which are relevant to you and products that are of interest to you)|
|To provide reports to our clients. These reports include information on the search behaviour of users at the post code level and information users voluntarily submit through fillable forms in the product locator
|Legitimate interests (to fulfil the obligations we have in our contracts with clients (i.e. the producers of the products))|
Disclosure of Personal Data
We may share your Personal Data with the parties set out below for the purposes set out in the table above.
- Our clients for reporting purposes, as stated in the table above.
- We may be required to disclose Personal Data in connection with a legal or regulatory proceeding, or in connection with enforcing our rights or defending ourselves in a legal or regulatory process. In such cases, we will review each request on a case-by-case basis and only comply if and to the extent we determine the request is lawful. When reviewing the lawfulness of a request, we take into account all applicable laws, including the laws of other jurisdictions, where applicable.
Retention of your Personal Data
We will retain your Personal Data for so long as necessary to fulfil the purpose for which we collected your Personal Data, and to comply with applicable legal and regulatory requirements. Generally, we keep your Personal Data for the duration of our relationship with our clients. This allows us to provide historical reports to our clients and to identify cyber-attacks, if one were to occur.
Your Personal Data is primarily stored in digital media, and when we no longer need to retain your Personal Data we will dispose of your Personal Data, whether stored in digital media or in hard copies, in a secure manner.
International transfers of your personal data
Destini is based in the United States. This means your Personal Data will be transferred to and stored in the United States. If you are based outside the United States, this involves transferring your Personal Data to a country where data protection laws may not be equivalent to those in the country you are based.
If you are based in the UK, we are obliged to inform you that the UK Government has not decided that the data protection laws in the United States are adequate.
The legal basis for transferring your data in this way is that the transfer is necessary in order to provide the requested service to you.
Your rights over your personal data
Destini would like to make sure you are fully aware of your data protection rights. If you are based in the UK, you are entitled to the following rights over your Personal Data:
- The right to access: You have the right to request copies of the Personal Data we hold about you.
- The right to rectification: You have the right to request that Destini correct any Personal Data about you that is inaccurate. You also have the right to request that Destini complete the Personal Data we hold about you where you believe it is incomplete.
- The right to erasure (‘right to be forgotten’): You have the right to request that Destini erases your Personal Data, under certain conditions.
- The right to restrict processing: You have the right to request that Destini restricts the processing of your Personal Data, under certain conditions.
- The right to object to processing: You have the right to object to Destini’s processing of your Personal Data, under certain conditions.
- The right to data portability: You have the right to request that Destini transfers the Personal Data we have collected about you to another organisation, or directly to you, under certain conditions.
- The right to withdraw consent: Where we rely on your consent to process your Personal Data (for example where you post Personal Data to a social media account), you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us using the details set out below. Destini will endeavour to respond to you without undue delay and in any event within one month of receipt of the request.
If you have questions regarding this privacy statement or the personal information we process, you may contact us at any of the following methods:
- By email: firstname.lastname@example.org; or
- By post:
Destini Global LLC
222 W. Hubbard Street Suite 300
Chicago, IL 60654
Attn: General Counsel.
For the purposes of Article 27 of the UK GDPR, we have appointed Reed Smith LLP as our UK Representative. Reed Smith are authorised to receive communications relating only to our UK personal data practices on our behalf. Reed Smith can be contacted using the following contact details:
Cynthia O’Donoghue, Partner
c/o Reed Smith LLP
The Broadgate Tower
20 Primrose Street
London EC2A 2RS
+44 (0)20 3116 9494
Contact Supervisory Authority
If you are based in the UK, you have the right to make a complaint about us to a Supervisory Authority.
Should you wish to report a complaint or if you feel that Destini has not addressed your concern in a satisfactory manner, you can complain to the Information Commissioner’s Officer as the UK’s Supervisory Authority, the details for which are here: https://ico.org.uk/make-a-complaint/
Notice of Changes