Dimply Limited, (collectively “We” or “Our” or “Company”) of The Old Schoolhouse, Enniskerry Road, Kilternan, Dublin, Ireland, company registration number 678661. We are referring to Dimply and we confirm we are committed to protecting and respecting your privacy. This privacy notice (together with the End User Licence Agreement) sets out the basis on which any personal data we collect from you, or that you provide to us, when you use the Dimply Application (App). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of the GDPR Dimply is the data controller.
*Any capitalised terms will take the meaning of those under your agreement for Services or the General Data Protection Regulation (“GDPR”).
Dimply collects and processes the following personal data:
Customer information:
- Contact details
- Date of birth
- Salary
*We do not share this data
Log in data:
Log in data to enable you securely to set up and log into your account.
*We do not share this data
Transaction information:
Some of the App features, such as the “Analysis” feature, help users gain a better overview of their overall financial situation and to optimise their expenses. Users can, for instance, enter and monitor individual saving targets.
*We do not share this data
Mood log data:
If you choose to use this feature, the App can identify up to 16 emotional states at a point in time giving users the ability to have a snapshot of their overall emotional state.
*We do not share this data
Video log data:
By partaking in certain video questionnaires, you may share your personal info (first name, relationship) and that of your partner and dependants regarding income, partners income, assets & liabilities, expenses, existing insurances, financial goals, risk preference, and behavioural profile.
*We do not share this data
Device data:
When you download and use the App, we collect the make and model of your phone, the operating system used by your phone and details of your network operator.
We may link a unique identifier to your mobile phone number
*We do not share this data
Supplier and Service Provider details:
Contact information, bank details, VAT details and tax clearance information
*We do not share this data unless required under a legal obligation
App user statistics:
Location, time, date and details of your visit to the App (as anonymous statistics)
*We do not share this data
Marketing information:
If you have expressed an interest in our Services or requested updates, we will contact you with relevant information until such time as you opt -out of communications
*We only share this data with relevant Service Providers as outlined below.
Legal basis for processing personal data in the (EEA and UK persons only)
Your contract - If you are located in the EEA or UK, our legal basis for collecting and using your personal data will depend on the personal data concerned and the specific context in which we collect it.
Legal obligation - If you have an account, we may need your personal data to perform a contract with you. In some limited cases, we may also have a legal obligation to collect personal data from you. This mainly applied to Suppliers. If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not, as well as of the possible consequences if you do not provide your personal data.
Legitimate interests - We may also collect and use personal data from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests typically include improving, maintaining, providing, and enhancing our technology, products, and services, ensuring the security of the Service and App and supporting our marketing activities.
Consent - We will sometimes use your personal data based upon your consent. We will always tell you where this is the case and ask you to agree before we process your information. This may be where you log in or opt in for marketing activities.
By using our App, you consent to our use of cookies and third-party services, that collect your usage data under a unique identifier, for the purposes of tracking, analysis, and improvement of our App, as well as advertising purposes such as retargeting. You may withdraw your consent to non-essential tracking and analysis at any time.
Your consent for processing health and sensitive data
When you create an account, your personal data—including sensitive data and data related to your mood or health may be stored on your device and is also stored and processed on the App servers. By creating an account with Dimply you explicitly consent that:
Dimply may store and process personal data you provide through creating an account and using the App for the purpose of providing App services to you and of improving the App service features. Such App services may include sending you information and reminders through the App, e.g. via push notification or to the email address you provided to Dimply.
The personal data you provide to Dimply through the account creation process for the purpose of providing our service includes personal data you enter into the App, such as your account data (e.g. your username and email address), and your mood data depending on the data you provide, it may also contain information about your general health.
Dimply may use your mood data to create de-identified sets of data for academic and clinical research purposes, we may transfer this de-identified data to our collaborators to further research. Dimply’s collaborators are individually selected through an internal vetting process. This de-identified research data does not contain any information that would allow the research partner to identify you as an individual.
How do we store your data?
Dimply operates and uses appropriate technical and physical security measures to protect your personal data. We have taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.
Access is only granted on a need-to-know basis on a least privilege basis to staff members whose roles require them to process your personal data and, in certain circumstances, to third party service providers. In addition, our service providers are selected carefully to ensure they have an appropriate level of technical, organisational and security measures in place.
We have established security controls that are in place to prevent, detect and respond to vulnerabilities and data breaches. We work hard to protect you and your information from unauthorised access, alteration, disclosure, or destruction and have several layers of security measures in place, including:
- Locks and security systems;
- Computer passwords and limited access to shared network drives to authorised staff;
- Virus checking;
- Timely patching applied against known vulnerabilities;
- Systems protected from malicious and mobile code;
- Boundary protection in place on all systems with a connection to an untrusted network;
- Network security boundaries defined and enforced to group users, services and information that require different levels of protection
- Software and hardware locked down to restrict unnecessary services;
- Auditing procedures and data integrity checks; and
- Security classification to identify data needing special protection.
Who do we share your personal data with?
We only share your information where it is necessary. We do not sell your data and will not share your information with any third parties for the purposes of direct marketing. Sharing can occur in the following circumstances and with the following organisations:
We may engage third-party services providers to work with us to administer and provide our Services. These third-party services providers have access to your personal data only for the purpose of performing services on our behalf. Where they process personal data, they are known as data processors under the GDPR. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it.
They will not share your personal information with any organisation apart from us unless instructed to do so. They will hold it securely and retain it for the period we instruct. The information we collect is covered by this privacy notice, and the information any third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you make on third-party site or platform will not apply to our use of the information we have collected directly through our applications.
We use the following service providers:
- Google Cloud Platform to store data https://cloud.google.com/terms/cloud-privacy-notice
- Plaid to enable users connect their bank accounts to the
- App https://plaid.com/overview-privacy/
- Apple Inc for notifications https://www.apple.com/legal/privacy/en-ww/
- Mailchimp for communicating with you https://mailchimp.com/legal/privacy/
- Mixpanel for analytics https://mixpanel.com/legal/privacy-policy/
App Analytics: When you visit the App, we use a third-party service, Google Analytics, to collect standard statistical information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the app. This information is anonymised and only processed in a way that does not directly identify anyone.
Business contact information relating to stakeholders may be shared with a relevant third party if it is reasonably expected that such information will only be used by the third party to contact you for legitimate business purposes related to your job responsibilities.
Where required, we share your personal information with Garda Síochána and law enforcement agencies in order to assist with the detection, investigation prevention and prosecution of crime.
We may disclose your information to a third party as part of a merger or transfer, or in the event of a bankruptcy. If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.
In the event of a merger, acquisition or asset sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our website, of any changes in ownership, uses of your personal information, and choices you may have regarding your personal information.
If there is a sale or merger, this Privacy notice will no longer apply. The new company's privacy practices will apply to your personal data.
How long do we retain your personal data?
We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected and processed in compliance with this privacy notice. To determine the retention period for personal data, we will take into consideration the purposes for which they were collected, as well as the nature and sensitivity of the information and the applicable legal requirements. We conduct periodic reviews of the data we retain and will safely delete data to the extent it is no longer required to be retained by us.
Additionally, we may process personal data for a specific purpose where we have obtained your consent.
Marketing
We would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies. You have the right to have us remove you from our marketing distribution lists at any time. If you currently receive marketing information from us that you would prefer not to receive in the future, please unsubscribe or email us at: privacy@dimply.ai.
Automated Individual Decision-Making, Including Profiling
Your personal data is not subject to any decisional process based solely on automated processing, which have a legal or similarly significant effect on you.
In order to provide the service, the App uses profiling. Profiling analyses aspects of an individual’s personality, behaviour, interests and habits to make predictions or decisions about them. Any profiling will not have a legal or similarly significant effect on you
What are your data protection rights?
We would like to make sure you are fully aware of all of your data protection rights. Every person we collect personal data or is entitled to the following:
Access: you may contact us at any time to request access to your personal data, and we will confirm to you whether we are processing your personal data and for what purposes, as well as provide details of the categories of personal data concerned, the specific pieces of data concerned, the recipients of the personal data, the retention periods (where possible) and your rights.
Rectification: if any of your personal data that we hold appears to be inaccurate or incomplete, you may ask us to correct or complete it at any time.
Erasure: you may ask us to have your personal data erased if it is no longer necessary for us to keep it in connection with the purposes for which it was collected or if the processing/storing of such personal data is otherwise unlawful. However, we must keep track of certain information in order to comply with legal obligations, and/or to handle any claims or litigation.
Restriction: you may ask us to limit the way in which we process your personal data (i.e., require us to continue to store your personal data but not to process it without your consent), for example where you think the personal data, we hold is inaccurate, for a period enabling us to verify the accuracy of personal data, or where you have objected to our processing.
Objection: you may object to our processing of your personal data on grounds relating to your specific situation, where we are processing your personal data to pursue our legitimate interests.
Portability: you may ask us to send you your personal data in an electronic, structured, commonly-used and machine-readable format and have your personal data transmitted directly from us to another data controller, where technically feasible without hindrance where the processing is carried out by automated means and is based on your consent or is necessary for the performance of a contract to which you are party.
Withdrawal of your consent: you may withdraw your consent at any time, where the processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before it was withdrawn. You also have the right to contact us at any time if you wish to complain about our processing of your personal data and you may lodge a complaint at any time with a supervisory authority.
No Discrimination: you have the right not to receive discriminatory treatment by us for the exercise of your privacy rights.
Email us at privacy@dimply.ai
Changes to our privacy notice
Dimply keeps its privacy notice under regular review and places any updates on the App. This privacy notice was updated on 01 Mar 2024.
Contact us
The primary point of contact for all issues arising from this privacy notice, including requests to exercise data subject rights, is our Privacy Officer. You can get in touch by emailing us at privacy@dimply.ai.
Once we receive a request from you, we will respond within at most 1 month, but usually a lot quicker. Before actioning these requests, we will need to positively identify you.
Data Protection Commission (DPC)
If you’re not happy with our reply to any complaint or you think our processing of your data doesn’t comply with data protection law, you can make a complaint to the Data Protection Commissioner’s Office (DPC). Just use these details:
E-mail: info@dataprotection.ie
Address: Data Protection Commission, 21 Fitzwilliam Square Dublin 2, D02 RD28 OR
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23
Telephone number: +353 (0)761 104 800 or Lo Call Number 1890 252 231
Cookies
Please see our separate cookie policy for all information relating to our cookie practices.
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