DTB Enterprises Ltd (“DTB”, “we”, “us” or “our”) is committed to protecting your personal information and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share and protect personal data when you:

• visit our website;

• make an enquiry;

• book or purchase a service;

• purchase a package, digital resource or physical product;

• contact us by email, phone, WhatsApp, online form or social media;

• work with us through our services for organisations, professionals or learners;

• make a travel enquiry or request travel-related support; or

• otherwise interact with DTB Enterprises Ltd.

We handle personal data in accordance with applicable UK data protection law, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

1. Who we are

DTB Enterprises Ltd
Company number: 16100656
Registered in England and Wales

DTB Enterprises Ltd is registered with the Information Commissioner’s Office (“ICO”).

DTB currently provides services across:

• Organisations;

• Professionals;

• Learners;

• Travel; and

• digital and physical products offered through the DTB Store.

General enquiries: hello@dtbenterprises.co.uk
Data protection enquiries: data@dtbenterprises.co.uk
Travel enquiries: travel@dtbenterprises.co.uk

Registered address:
82A James Carter Road
Mildenhall
Bury St. Edmunds
Suffolk
IP28 7DE

If you have questions about this Privacy Policy or how we use your information, please contact us using the details above.

2. The personal data we collect

We only collect personal data that is relevant to providing our services, managing enquiries, processing transactions, keeping appropriate records and operating the business.

Information you provide directly

Depending on how you interact with DTB, this may include:

• your name;

• email address;

• telephone number;

• postal address where required;

• billing and payment information;

• booking and appointment details;

• information submitted through website forms or Microsoft Forms;

• information provided by email, phone, WhatsApp or social media;

• details about your goals, circumstances, preferences or requirements;

• information relevant to consultancy, professional development, learner support or travel planning;

• CVs, applications, professional profiles or other documents you ask us to review;

• information about sessions, packages or previous services;

• order and delivery information for products;

• information relating to complaints, disputes, feedback or customer-service matters;

• safeguarding or welfare information where relevant and appropriate.

Information collected automatically

When you use our website, we may collect technical information including:

• IP address;

• browser type;

• device type;

• operating system;

• pages viewed;

• dates and times of access;

• referral information; and

• cookies and similar technologies.

For more information, please see our separate Cookie Policy.

Information received from third parties

We may receive limited personal data from third parties where necessary to provide or administer our services.

These may include:

• website and hosting providers;

• online form providers;

• booking and scheduling platforms;

• practice-management or CRM systems;

• payment processors;

• accounting and invoicing platforms;

• email and cloud-storage providers;

• e-commerce and fulfilment providers;

• travel platforms, suppliers and booking partners.

3. Special category and sensitive personal data

Some of the services we provide may involve information that is more sensitive.

Depending on the circumstances, you may choose to disclose information relating to matters such as:

• physical or mental health;

• disability;

• neurodivergence;

• racial or ethnic origin;

• religious or philosophical beliefs;

• sexual orientation;

• sex life;

• trade union membership; or

• other sensitive personal circumstances.

These categories of information receive additional protection under UK data protection law. Where DTB processes special category data, we will identify both an appropriate lawful basis under Article 6 UK GDPR and, where required, an additional condition under Article 9. Information Commissioner's Office

We will only collect or use this information where it is relevant and proportionate to the service or situation.

We do not use special category data for unrelated marketing purposes.

4. Personal data relating to children and young people

DTB’s services are primarily intended for adults.

However, some Learner services may be provided to individuals under the age of 18, for example support relating to education, college or university applications, apprenticeships, study skills or academic development.

Where we work with a child or young person, we may process:

• their name and contact details;

• details of a parent, guardian or responsible adult;

• education-related information;

• information relevant to the support requested;

• safeguarding or welfare information where necessary.

We will take particular care when handling children’s personal data and will provide information about its use in a clear and appropriate way. Children have the same core data-protection rights as adults, although how those rights are exercised may depend on age, understanding and the circumstances. Information Commissioner's Office

Where appropriate, we may involve or obtain information from a parent, guardian or responsible adult.

5. How we use your personal data

We may use your personal data to:

• respond to enquiries;

• assess whether DTB can provide appropriate support;

• arrange consultations, bookings or appointments;

• deliver consultancy, professional development, learner support or travel-related services;

• prepare for sessions or meetings;

• maintain appropriate client and service records;

• manage packages, bookings and appointment history;

• provide summaries, recommendations, action points and related materials;

• review CVs, applications, documents or other materials supplied by you;

• process payments;

• issue invoices and receipts;

• fulfil digital or physical product orders;

• provide customer support;

• communicate about bookings, orders, services or changes;

• manage complaints, disputes or legal matters;

• meet safeguarding responsibilities;

• meet accounting, insurance, tax, regulatory and legal obligations;

• improve our systems, website and services;

• prevent fraud, misuse or security incidents;

• send marketing communications where permitted by law.

We do not sell your personal data.

6. Our lawful bases for processing personal data

Depending on the circumstances, we may rely on one or more of the following lawful bases.

Contract

Where processing is necessary:

• before entering into a contract with you; or

• to provide a service or product you have requested or purchased.

Legitimate interests

Where processing is reasonably necessary for the legitimate operation of DTB, provided those interests are not overridden by your rights and freedoms.

This may include:

• responding to enquiries;

• managing client relationships;

• maintaining appropriate records;

• improving services;

• operating business systems;

• preventing fraud;

• protecting DTB’s legal or commercial interests.

Legal obligation

Where processing is necessary to comply with legal, tax, accounting, regulatory or other statutory obligations.

Consent

Where we specifically rely on your consent, for example for:

• certain marketing communications;

• optional cookies; or

• particular processing activities where consent is the appropriate lawful basis.

Where processing is based on consent, you may withdraw that consent at any time.

Vital interests

In limited circumstances where processing is necessary to protect someone’s life or physical safety.

Different processing activities may rely on different lawful bases.

7. Recordings, transcription and AI-assisted tools

DTB may use digital tools to support accessibility, accurate record keeping, administration and service delivery.

This may include tools used for:

• meeting transcription;

• note preparation;

• summarisation;

• drafting;

• organisation;

• administrative support; and

• preparation of follow-up materials.

Examples may include AI-assisted tools and transcription services.

Where a meeting or session is being recorded or transcribed, we will inform participants where appropriate.

Audio or transcript material is generally treated as working material rather than as the permanent client record.

Unless there is a legitimate reason to retain it for longer, recordings and transcripts will normally be deleted once they are no longer needed for:

• accurate note preparation;

• completion of agreed outputs;

• service administration;

• safeguarding;

• complaint or dispute handling; or

• another identified lawful purpose.

Relevant information may instead be retained within the formal client or service record.

Where personal data is processed using AI-assisted tools, DTB will consider:

• the sensitivity of the information;

• whether all of the information is necessary;

• appropriate security and confidentiality arrangements; and

• whether data can be minimised before use.

DTB does not currently use solely automated decision-making that produces legal or similarly significant effects on individuals. UK GDPR places additional requirements on this kind of automated decision-making. Information Commissioner's Office

8. Who we share personal data with

We only share personal data where it is necessary, relevant and proportionate.

Depending on the service, this may include sharing information with:

• payment-processing providers such as Stripe or PayPal;

• website and hosting providers;

• booking and scheduling providers;

• practice-management and CRM providers;

• online form providers;

• email, cloud-storage and collaboration providers;

• accounting and finance platforms;

• e-commerce, fulfilment or delivery providers;

• professional advisers such as accountants, legal advisers, insurers or IT providers;

• travel platforms, suppliers or booking partners;

• regulators, courts, safeguarding bodies, law-enforcement agencies or public authorities where required or justified by law.

We may use providers such as Microsoft 365, Hostinger, Xero, Acuity, Zanda and similar services as part of our business operations.

We may change providers from time to time. This policy therefore describes categories of providers rather than attempting to maintain a complete list of every system we use.

We do not allow service providers to use your personal data for their own unrelated marketing unless they have an independent lawful basis to do so.

9. Travel enquiries and bookings

Where you make a travel enquiry or ask us to help arrange travel, we may collect information including:

• names of travellers;

• contact details;

• travel dates;

• destinations;

• departure points;

• budget;

• accommodation preferences;

• accessibility or mobility requirements;

• dietary or other relevant requirements;

• passport or identification information where required later in the booking process;

• information relating to children travelling with you;

• other information necessary to research, arrange or administer travel.

Travel-related information may be shared with:

• InteleTravel;

• relevant travel suppliers;

• airlines;

• cruise operators;

• accommodation providers;

• tour operators;

• transport providers;

• booking systems; or

• other organisations involved in fulfilling your requested travel arrangements.

Some of these organisations may act as independent data controllers for the information they receive. Their own privacy policies will then apply to their use of your personal data.

We will only share information that is reasonably necessary for the travel enquiry or booking.

10. Payments and financial information

Payments may be processed through third-party payment providers such as Stripe or PayPal.

DTB does not normally receive or store full payment-card details where payment is processed directly by a third-party provider.

We may retain information relating to:

• transactions;

• invoices;

• payment status;

• refunds;

• payment references; and

• accounting records.

These records may need to be retained for tax, accounting and legal purposes.

11. International transfers

Some of our technology, software or service providers may store or process information outside the United Kingdom.

Travel enquiries may also require personal information to be shared with organisations outside the UK.

Where personal data is transferred internationally, we will take reasonable steps to ensure that an appropriate legal transfer mechanism applies.

This may include:

• UK adequacy regulations;

• the UK International Data Transfer Agreement;

• an approved UK Addendum;

• another appropriate safeguard; or

• a permitted exception where applicable.

12. How long we keep personal data

We keep personal data only for as long as necessary for the purpose for which it was collected and to meet applicable legal, regulatory, safeguarding, insurance and business requirements.

As a general guide:

Enquiry records

Enquiries that do not result in an ongoing relationship will normally be retained for a shorter period unless there is a legitimate reason to keep them.

Client and service records

Client and service records will normally be retained for up to seven years after the end of the working relationship.

A longer or shorter retention period may apply where justified by:

• the nature of the service;

• legal requirements;

• insurance requirements;

• safeguarding considerations;

• professional standards;

• an unresolved complaint;

• a dispute; or

• potential legal proceedings.

Children and young people

Records relating to children or young people may need to be retained for longer than ordinary adult records where safeguarding, legal or other professional considerations make this appropriate.

Financial records

Accounting and financial records will normally be retained for at least the period required by law, typically six years or longer where necessary.

Order records

Records relating to purchases, fulfilment and refunds may be retained for as long as necessary for accounting, contractual, consumer-law and dispute purposes.

Marketing records

Marketing records will normally be retained until:

• you unsubscribe;

• you withdraw consent where consent is relied upon;

• you object to marketing; or

• we determine that the information is no longer required.

We may retain limited suppression information after you opt out so that we can ensure you are not added back to marketing communications accidentally.

Recordings and transcripts

Recordings and transcripts will normally be retained only for as long as necessary to prepare records, summaries or outputs, unless there is a clear reason to retain them longer.

Where personal data is no longer required, we will securely delete, anonymise or otherwise dispose of it appropriately.

13. Your data protection rights

Depending on the circumstances, you may have the right to:

• be informed about how your personal data is used;

• request access to the personal data we hold about you;

• request correction of inaccurate or incomplete personal data;

• request deletion of your personal data;

• ask us to restrict the way we use your personal data;

• object to certain processing;

• request portability of certain personal data;

• withdraw consent where we rely on consent; and

• raise concerns about how your personal data is handled.

Some of these rights are subject to legal conditions or exemptions.

To exercise your rights, please contact: data@dtbenterprises.co.uk

We may need to verify your identity before responding.

You also have the right to complain to the Information Commissioner’s Office if you are unhappy with how we have handled your personal data.

14. Cookies and analytics

Our website may use cookies and similar technologies for purposes including:

• essential website functionality;

• security;

• analytics;

• performance monitoring;

• embedded services;

• user preferences.

Where required, we will obtain consent before using non-essential cookies or similar technologies.

You can find more information in our separate Cookie Policy.

15. Marketing communications

We may send information about DTB services, resources, products or updates where:

• you have asked to receive them;

• you have opted in; or

• we are otherwise permitted to contact you under applicable law.

You can unsubscribe or opt out at any time using the unsubscribe option included in marketing communications or by contacting us.

We will not sell your personal data to third-party marketers.

16. Security

We take reasonable technical and organisational measures to protect personal data from:

• unauthorised access;

• accidental loss;

• misuse;

• alteration;

• disclosure;

• destruction.

Measures may include:

• password protection;

• multi-factor authentication;

• secure cloud systems;

• encryption where appropriate;

• access controls;

• secure devices;

• software updates;

• limiting access to individuals who genuinely need it.

No electronic storage or transmission method can be guaranteed to be completely secure, but we take proportionate steps to reduce risk.

17. Safeguarding, legal claims and disclosures

There may be circumstances where confidentiality cannot be maintained because information needs to be used or disclosed for:

• safeguarding;

• protection of life or physical safety;

• prevention or detection of crime;

• legal proceedings;

• regulatory requirements;

• insurance matters;

• defence or establishment of legal claims.

Where possible and appropriate, we will only disclose the minimum information necessary.

18. Third-party links and external services

Our website, emails or communications may contain links to third-party websites, booking platforms, suppliers or services.

Where you choose to use an external service, its own privacy policy and terms may apply.

DTB is not responsible for the privacy practices of organisations we do not control.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

• our services;

• our systems;

• our suppliers;

• legal or regulatory requirements; or

• the way DTB operates.

The latest version will be published on our website with the date of the most recent update shown at the top.

We expect to review this policy periodically and whenever there is a significant change to our services or data-processing activities.

20. Contact us

If you have questions about this Privacy Policy or want to exercise your data-protection rights, please contact:

DTB Enterprises Ltd

Email: data@dtbenterprises.co.uk

Registered address:
82A James Carter Road
Mildenhall
Bury St. Edmunds
Suffolk
IP28 7DE

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