PRIVACY NOTICE
Dimark
1. WHO WE ARE
Dimark Limited (“Dimark”, “we”) is the controller of the personal information described in this notice. Company number 04996865, registered in England and Wales. Registered office: Unit 4 & 5 Advent Business Park, 14 Advent Way, Edmonton, London N18 3AL. Email info@dimarkltd.co.uk, phone 020 8887 9696. ICO registration number: ZB476754.
This notice applies to Dimark, our app for iPhone, iPad and Android. Business customers use it to apply for a trade account, see our products, place orders and manage that account.
You fill in the application yourself. Dimark staff do not complete it for you in the app, and the app is not used by our sales representatives to register customers.
This notice adds to any other privacy information Dimark gives you about our website and shop.
2. WHO THIS NOTICE COVERS
The app may include information about:
• you, as the person filling in the application and, if we open an account, as the person who signs in;
• the business, including a UK limited company or a sole trader;
• a director or authorised officer;
• shop managers and staff you choose to name; and
• anyone else whose details you put in the application or the account.
If you give us someone else’s details, please show them this notice.
The person who signs also gives a personal guarantee for sums the business owes Dimark. The guarantee is a separate agreement from the trading terms, and the same signature covers both. It is signed electronically as a contract, not as a deed, so we do not ask for a witness.
3. BUSINESS AND ACCOUNT INFORMATION
On an application we may collect:
• trading name and legal name;
• whether the business is a UK limited company or a sole trader;
• what the business sells, and the kind of shop it is;
• company number, and for a sole trader the Self Assessment UTR, start date and business activity;
• VAT number and VAT status;
• registered office, legal address, billing address, shop addresses and delivery points;
• shop and business phone numbers and email addresses;
• the email the shop account should use;
• how many shops you tell us about; and
• notes you add for a delivery, such as which door to use.
If we open an account, the app can show the details held for that account, including:
• your name, email and phone number;
• shop and delivery addresses;
• orders;
• products you have marked as favourites; and
• your choices about offers.
Every customer sees the same product prices. The app does not show a private price list, an account balance, or a named sales representative.
4. PEOPLE CONNECTED WITH THE BUSINESS
Where the application or the account needs it, we may collect:
• full name;
• role, such as director, authorised officer, sole trader, shop manager or staff;
• home address of the person who applies;
• phone number and email address; and
• anything else you type into the application.
A sole trader gives their date of birth. We do not ask a company director for a date of birth.
Information about an identifiable director, sole trader, manager or member of staff is personal information even when it is given for a business.
5. DOCUMENTS AND PHOTOGRAPHS
To check the business we ask for a photograph or copy of:
• proof of identity, such as a passport, driving licence, identity card or biometric residence card;
• proof of home address, such as a utility bill, bank statement or driving licence; and
• proof of business address, such as a business-rates bill, a lease, or an electricity bill for the business.
You can also add photos of the shelves, the shop sign and the shopfront, to help us and our drivers. These are optional.
A bank statement is used only as proof of address. We do not take payment-card numbers, bank-account numbers or direct-debit details in the app.
We do not use identity photographs for facial recognition or biometric identification.
When you photograph a document, the app reads the text on the phone only to check the photo is clear enough to read. Those words are not saved and are not sent to us or to a reading service. A PDF is not read this way.
6. YOUR SIGNATURE
You sign the trading agreement on the screen. We keep:
• the signature;
• who signed, and the date and time;
• the version of the terms and of this notice you were shown;
• your confirmation that the information is correct; and
• your confirmation that we may check the business.
We also keep the IP address and the app version used to send the application, so we can show how the agreement was made.
There is one electronic signature. It covers the trading agreement and the personal guarantee. We do not ask for a witness.
7. LOCATION
You can drop a pin on the shop, and on a different delivery point if the van should not stop at the front door.
If you allow it, the app can use your phone’s location once, to place that pin. You can also move the pin yourself, or leave it and rely on the address you typed.
If you refuse location, or we cannot get it, you can still finish the application.
We record the pin you choose, as latitude and longitude. We do not track you in the background, and we do not keep a continuous record of where the phone is.
8. COMPANIES HOUSE
If you apply as a UK limited company, we may send the company name or company number to Companies House.
Companies House may return the company name, company number, registered office, company status and the names of current directors. We show these in the form so you can check them and choose the director, or other authorised officer, who is applying.
9. BUSINESS CREDIT
The app does not carry out a credit-reference search, collect a credit score, or decide the application.
A person at Dimark decides every application. It is not decided automatically.
Where we assess whether to supply the business on credit, authorised Dimark staff may use a business-information service such as Creditsafe. That review can include the business’s financial standing, a business credit score, a recommended limit, payment history, insolvency information and county court judgments.
These checks are on the business. They are not a consumer credit check on you as a private individual.
If you are a sole trader, information about the business may also be information about you, because you trade in your own name.
Creditsafe explains its own use of business information in its privacy notice.
10. OFFERS AND OTHER MESSAGES
Offers are optional and are switched off until you turn them on. You choose separately whether to receive offers by email, by text message and on WhatsApp.
You can withdraw that permission at any time. Stopping offers does not close the account, and it does not undo messages already sent while you had agreed.
We send these offers only with your consent, whether the business is a sole trader or a limited company. You can tell us to stop at any time.
Offers shown inside the app, such as special prices, are the same for every customer. You see them whatever you choose here.
When an application is approved, Shopify emails you a link to set up the shop account. That message is part of opening the account. It is not an offer, and it is sent whether or not you opt in to offers.
We keep the signed agreement. If you ask for a copy, on the application form or later, we email it to you.
The app records your choices. It does not itself send the offer emails, text messages or WhatsApp messages.
11. YOUR SHOP ACCOUNT, ORDERS AND FAVOURITES
If we approve the application, we open a customer account on our Shopify shop with the email you gave us, your shop addresses, and your offer choices. You then sign in to Dimark with that account. The same account is used on our website.
While you use the app we process:
• your name, email and phone number;
• the addresses you add or edit;
• your orders, including what you bought, quantities and delivery details;
• products you mark as favourites, saved on your Shopify account so the website shows the same list; and
• messages you send us, including a report of a problem with an order.
A problem report can include what went wrong, which products and how many, a short message, photographs, and the app version. We keep a resolved report, including its photographs, for 7 days after it is resolved, then we delete it.
Payment is taken in Shopify’s checkout, or by bank transfer arranged with us outside the app. Card details are entered in Shopify’s checkout. They are not sent to Dimark’s own server and are not stored by the app.
12. SIGNING IN, AND WHAT STAYS ON THE PHONE
You sign in with your email and password. The app sends them over an encrypted connection to Dimark’s server, which asks Shopify to check them. We do not store your password, and we do not write it in our logs. Shopify emails you a link if you ask to set a new one.
After you sign in, the app keeps a session in the phone’s secure storage so you can stay signed in. It is removed when you log out, and it expires if it is not renewed.
On the phone we also keep:
• your basket, so it is still there when you come back;
• recent product searches; and
• the application while you are filling it in.
The basket and recent searches stay on that phone. Favourites are kept on your Shopify account, not only on the phone.
We do not put a device identifier on the phone to approve or revoke that handset, and we do not record the name of the phone.
We do record the app version with an application and with a problem report. Our server also uses the IP address of a request, for a short time, to limit repeated attempts and to protect the service. It does not write that IP address in its logs. The IP address saved with an application is deleted with that application.
13. HOW WE COLLECT INFORMATION
We get information:
• from you, when you apply, sign in, order, edit your account or report a problem;
• from documents and photos you take or choose;
• from Companies House;
• from the address and map services in section 22;
• from Creditsafe, where our office makes a business credit assessment;
• from the shop account and orders already held for you; and
• from the operation of the app, such as the time of a request and the IP address.
14. WHY WE USE IT
Depending on the circumstances, we use personal information to:
• consider your application and decide whether to open an account;
• check the business and the documents you provide;
• prevent and detect fraud;
• assess business credit, where we offer it;
• keep the signed agreement;
• run your account, take and deliver orders, and issue invoices and credit notes;
• collect payment;
• keep accounting, tax and VAT records;
• show you your orders, addresses and favourites;
• deal with delivery and with problems you report;
• answer questions and data-protection requests;
• send the account-setup email, and a copy of the agreement if you ask for it; and
• send offers where you have allowed them, or where the law allows us to contact a limited company.
We do not use your information to build advertising profiles or to personalise what you see in the app.
15. OUR LEGAL REASONS
The reason depends on the information and the purpose.
Contract. We use information where we need it to consider your application, open the account, supply goods and run the account.
Legal obligation. We keep information where tax, accounting or other law requires it.
Legitimate interests. We use information where we need it to check a business, prevent fraud, assess business credit, keep accurate records, deliver orders, protect our systems, and run the business. We consider whether those interests are outweighed by your rights.
Consent. We ask for consent for optional offers, from every business. You can withdraw consent at any time. That does not affect use that was already lawful.
16. WHAT WE NEED FROM YOU
We need the business details, the identity document, the proofs of address and your signature to consider an account. If you do not provide what we reasonably need for those checks, we may be unable to open the account.
Offer choices, extra shop photos, and the map pin are optional.
17. THIS NOTICE DURING THE APPLICATION
Before we collect the application, the app shows a short summary and this full notice.
We save the version of this notice with the application, so we can show which wording you were given. The signed agreement also records that version.
This notice is separate from the trading terms, from your confirmation that the information is correct, and from your offer choices.
18. HOW LONG WE KEEP IT
The application. 30 days after we decide, whether we approve it or not, we delete the application and what came with it: identity and address documents, shop photos, home addresses, a sole trader’s date of birth, the signature, and the IP address saved with it.
If we open an account, we then keep only:
• your shop account (business name, contact names, phone numbers, email, shop addresses, favourites and offer choices), for as long as the account is open;
• the signed agreement, for 6 years after the account closes, as evidence of the contract; and
• orders and invoices, for 6 years after the end of the financial year they belong to, as tax and accounting law requires.
A problem report, and its photographs, is kept for 7 days after we mark it resolved, then deleted.
Deleting the app, or clearing the basket on the phone, removes only that phone’s copy. It does not delete the account, the orders, or an application we still hold.
We may keep something for longer where the law requires it, money is still owed, or we need it to deal with a claim. When we no longer need personal information for a lawful purpose, we delete it or make it anonymous.
19. WHO WE SHARE IT WITH
Access inside Dimark is limited to people who need the information for their work.
We may also share information with:
• Shopify, which holds the shop account, favourites, orders and checkout;
• Cloudflare, which stores application files and problem-report photographs for the periods in section 18;
• our own server host, Hetzner;
• Google, for address suggestions, and for the map on Android;
• Apple, for the map on iPhone and iPad, and for voice search on those devices;
• Companies House, for the company search in section 8;
• Creditsafe, where our office assesses business credit;
• delivery companies, normally only the business name and the delivery address;
• email, text-message or WhatsApp providers, where we send a message you have asked for or that the account requires;
• accountants, insurers, solicitors, debt collectors and payment providers, where that account or order needs them; and
• the police, HMRC or another authority, where the law requires it.
Where a provider processes personal information for us, we require it to use the information only for the agreed purpose, protect it, and follow data-protection law.
We do not sell personal information, and we do not share it with advertising networks.
20. OUTSIDE THE UK
Some providers store or reach information outside the United Kingdom. Our Hetzner server is in Finland. Shopify, Cloudflare, Google and Apple may process information in the European Economic Area, Canada, the United States or elsewhere.
Where UK law treats this as a restricted transfer, we use a lawful safeguard. That may be UK adequacy regulations, the UK–US Data Bridge, or UK-approved contract clauses.
Cloudflare storage of these files is not limited to the UK or the EU.
21. CAMERA, PHOTOS AND VOICE SEARCH
The camera is used to scan a barcode, and to photograph a document, the shop, or a problem with an order. A barcode scan is used to find the product. We do not keep a photograph of the scan.
If you choose an existing picture, we use only the picture you select. We do not upload your photo library.
The app does not record video or audio continuously.
Voice search is optional. If you allow the microphone, the phone turns what you say into text and we use that text as a product search, in the same way as words you type. We do not keep the recording. On iPhone and iPad the speech service is Apple’s, and on many Android phones it is Google’s. Those companies process the audio under their own terms.
22. SERVICES THE APP USES
The app does not include third-party advertising, analytics or crash-reporting tools.
Apple. The app runs on iPhone and iPad. Apple’s map is used when you place a pin. Voice search on those devices uses Apple’s speech recognition.
Google. If you type an address, the search is sent to Google Places through our server, limited to the UK, the Isle of Man, Jersey and Guernsey. We send only the text needed to find the address. We do not send your name, phone number, email, identity documents or orders to Google for this search. On Android, the map is Google’s, and voice search may use Google’s speech recognition.
Companies House. A company name or number may be sent for the search in section 8.
Cloudflare. Application files and problem-report photographs are stored with Cloudflare R2 for the periods in section 18. Catalogue photographs may also be loaded from storage we use with Cloudflare.
Hetzner. Our server is in Finland. The app uses it for signing in, the application, products, orders and related requests. To see whether it can reach us, the app contacts this server.
Shopify. Shop accounts, favourites, orders, checkout and many product photographs are provided through Shopify.
23. PAYMENTS
The app does not collect or show payment-card numbers, bank-account details or direct-debit details.
Card payment happens in Shopify’s checkout. Bank transfer is arranged from the invoice, outside the card form. A bank statement uploaded with an application is proof of address only.
24. SENSITIVE INFORMATION
We do not ask the app to collect information about health or disability, race or ethnicity, religion or philosophical beliefs, political opinions, trade-union membership, sexual orientation, or criminal convictions.
A description of the goods a shop sells, such as Halal, South Asian or East Asian ranges, describes the business and the products it wants. It is not a record of anyone’s race, ethnicity or religion.
25. TRACKING AND ADVERTISING
The app does not show third-party advertising, and it does not include advertising, analytics or crash-reporting kits. It does not use an advertising identifier, it does not track you across other companies’ apps or websites, and we do not sell information about customers.
26. NOTIFICATIONS
The app does not send push notifications.
27. CHILDREN
Dimark is for businesses. It is not directed at children, and it is not for opening a trade account for a child.
28. HOW WE PROTECT INFORMATION
We use measures designed to protect personal information against unauthorised access, loss, misuse or alteration. They include encrypted connections, sign-in before account information is shown, secure storage of the session on the phone, private storage in the app, a dedicated server, and access limits so that application documents are available to authorised staff.
No method of storage or transmission is completely secure. We use safeguards appropriate to the information.
29. YOUR RIGHTS
Depending on the reason we hold the information, you may have the right to:
• receive a copy of your personal information;
• correct it, or complete it;
• ask us to delete it, in some cases;
• ask us to restrict how we use it, in some cases;
• object to certain uses, including direct marketing;
• ask for certain information in a portable form; and
• withdraw consent, where we rely on consent.
These rights are not absolute. We may need to keep information where the law requires it, where it is needed for tax or accounting, where an account or an unpaid invoice still needs it, where we need it to prevent fraud, or where we need it for a legal claim.
We normally reply within one month. If a request is complex, or we have many requests, we may take up to two further months, and we will tell you if we do.
30. ASKING US TO DELETE INFORMATION
In the app, open your account and choose Delete my account. That prepares an email to info@dimarkltd.co.uk. You can also write to that address yourself.
Sending the email does not delete the account immediately. We review the request, confirm it with you, and then close the account where we are required or allowed to.
Orders, invoices and other records we must keep for tax, accounting or a legal claim can be kept for the periods in section 18. The signed agreement can be kept for 6 years after the account closes.
Removing the app from your phone does not delete information we hold, or information held in Shopify.
31. COMPLAINTS
If you are concerned about how we handle your information, contact us using section 33 and we will look into it.
You can also complain to the Information Commissioner’s Office, the UK regulator for data protection: ico.org.uk, 0303 123 1113. Contacting us first does not affect that right.
32. CHANGES TO THIS NOTICE
We may update this notice if the app, our providers, our use of information, or the law changes.
The current version is shown in the app. We record which version you were shown with your application and on the signed agreement. We will tell you in the app or by email if a change matters to you.
33. CONTACT US
Dimark Limited, company number 04996865, Unit 4 & 5 Advent Business Park, 14 Advent Way, Edmonton, London N18 3AL, United Kingdom.
Email info@dimarkltd.co.uk
Phone 020 8887 9696