We are DOHE Europe Ltd (“DOHE”, “we” or “our”), a company registered in England and Wales under company number 14914518 with registered address C/O Buckworths 1-3 Worship Street, 2nd Floor, London, England, EC2A 2AB. We take the privacy of your information very seriously. This notice is designed to tell you about our practices, as data controller, regarding the collection, use and disclosure of personal data which may be collected in person from you, obtained via our website or collected through other means such as by an online form, email, or telephone communication.   

DOHE is a start-up accelerator that connects start-ups with coaches/experts to assist founders with their growth and provides various other information, training and services to start-ups. As part of our project, we may enroll start-ups in our accelerator programmes which aim to provide coaching, training and education in order to fuel the growth of their start-ups.

This privacy notice will explain how we collect, use and share the personal data we collect from you in the course of operating our business and when you use our website, but this notice does not apply to information we hold in relation to our employees and staff, or in respect to personal data which we hold as “processor” (see the heading “Important Note” below). In this notice “you” refers to any individual whose personal data we hold or process (other than our employees or contractors). This notice applies to our coaches and other self-employed suppliers who are providing services to startups on our programmes, and to employees of our business suppliers, but not to contractors who are providing services directly to us (for whom the staff policy will apply). 

This notice is governed by the Data Protection Act 2018 and by the retained UK law version of the EU General Data Protection Regulation as incorporated into UK law under the European Union (Withdrawal) Act 2018 (“GDPR”), and any other applicable data or privacy legislation. 

This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.

Personal data we collect and how we process this data

Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:

• Contact and registration information of founders/key staff members of our start-up clients who: 1) have registered with us or whose details have been passed to us on behalf of their employer or organisation for whom they work; 2) submit an enquiry to us; or 3) subscribe to any newsletter or other relevant subscription product. Contact information may include your name, surname, company name, job title/role, email address, address, telephone number (“Start-Up Contact Information”) and registration information may include your location/address (“Start-Up Registration Information”). Please note that this information may be collected via third parties. 

If you subscribe to a newsletter or other regular information we provide, we will process your Contact Information on the basis that you have consented to this and will only send our newsletter to you for as long as you continue to consent.

• Programme information which we collect in the course of providing our accelerator programmes, which may include documents prepared by you as part of the programme, recordings of interviews, meetings and coaching sessions, transcripts or summaries of interviews, meetings and coaching sessions (“Programme Information”).

We process Programme Information to provide our services on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services.

• Contact, registration and financial information of coaches/experts who are enrolled in our programme to assist our start-up clients. Contact information may include your name, surname, company name, job title/role, email address, business address (“Coach Contact Information”). Registration information may include your business address/location (“Coach Registration Information”). 

We refer to Start Up Contact Information and Coach Contact Information collectively as “Contact Information” in this notice and we refer to Start Up Registration Information and Coach Registration Information as “Registration Information”) in this notice. 

We process Contact Information and Registration Information to provide our services and communicate with you (including with respect to customer care and support) on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services.

• Information which we hold because you are a supplier or contact of ours (“Supplier Information”) and which we process during the course of providing our services to you or the provision of services to us. 

We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.

• We may hold aggregated and anonymised data based on your use of the services for our statistical (or other business) purposes in accordance with the section “Sharing your information” below. To the extent such aggregated data is shared with third parties, it will not contain any personal data.
• A record of any correspondence or communication between you and us (“Communication Information”). 

We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.

• Financial information which we hold in the context of providing/receiving services from you (“Financial Information”) such as billing and banking information. 

We process this information when we provide or receive services (as the case may be) on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.

• Marketing information. We may hold information about you in order to provide information about our services. This may include names, job titles, email addresses, phone numbers, addresses, and other information (“Marketing Information”). 

We process this information in order to improve our services, communicate with you about our services or for market research purposes, on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receiving the information.

We may collect information from you directly, from the organisation for whom you work (such as your contact information and job title/role) or from another third party. If we obtain your personal data from a third party, your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this privacy notice.

As part of operating our programmes, we may record video and audio during coaching sessions, interviews, or other interactions. These recordings may contain personal data, such as your image, voice, and any information you may disclose during the session. We collect and use these recordings for the purposes described above. Please note that your privacy rights apply in full to any recordings which we collect. 

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:

• Following an enquiry with us, we will remove your Contact Information and Communication Information from our systems after a period of 2 years unless you subsequently subscribe to our services with us.
• In respect of records relating to a contract with us - 7 years from either the end of the contract or the date you last used our services (whichever is later).
• In respect of Marketing Information – 2 years from the last date on which you have interacted with us.

For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required. 

If you wish to request that data we hold about you is amended or deleted, please see below for your privacy rights.

Sharing your information

We may disclose information to third parties in the following circumstances:

• We may work with other professionals and providers in providing and delivering our services to you, such as Microsoft and other service technology providers.
• In order to enforce any terms and conditions or agreements for our services that may apply.
• If we are sub-contracting services to a third-party we may provide information to that third party in order to provide the relevant services.
• We may disclose information to our group companies (as the case may be).
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
• As part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation.
• To protect our rights, property and safety, or the rights, property and safety of our users or other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If we do supply your personal data to a third party we will take steps to ensure that your privacy rights are protected and that such third party complies with the terms of this notice. 

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

• protecting our servers by both hardware and software firewalls;
• locating our data processing storage facilities in secure locations;
• encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
• when necessary, disposing of or deleting your data so it is done so securely;
• regularly backing up and encrypting all data we hold.

We will ensure that our employees and staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees or staff of third parties working on our behalf are aware of their privacy and data security obligations. 

This notice and our procedures for handling personal data will be reviewed as necessary.

Third party links

Our website may contain links to other sites that are not operated by us. This notice applies to our services only so if you click on a third-party link, we strongly advise you to review that site’s privacy policy.

We have no control over and are not responsible or liable for the content, privacy policies or practices of any third-party sites or services.

Your privacy rights

With respect to your personal data, you have:

• The right to be informed - a right to know about our personal data protection and processing activities, details of which are contained in this notice
• The right to access - the right to request a copy of any personal data that we have about you
• The right to rectification - the right to request a correction of any errors in or update of the personal data that we have about you
• The right to erasure (also referred to as the ‘right to be forgotten’) - the right to request that your personal data is deleted from our records
• The right to restrict processing- the right to request that we no longer process your personal data in certain ways, whilst not requiring us to the delete the same data
• The right to object to processing - the right to request that your personal data will not be processed
• The right to data portability - the right to request that your personal data be transferred or exported to another organisation
• The right to withdraw consent - the right to withdraw any permission you have given us to process your personal data
• Rights in relation to automated decision making and profiling- the right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you
• The right to request that your personal data will not be used to contact you for direct marketing purposes

All Subject Access Requests and other requests or notifications in respect of your above rights must be sent to us in writing via our Contact Details below.

We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data breaches

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the Information Commissioner’s Office (ICO) (as necessary).

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Transferring your information outside the EEA

We will not transfer your personal data in a systematic way outside of the European Economic Area or UK (together referred to as the “European Area”) but there may be circumstances in which certain personal data is transferred outside of the European Area, in particular:

• We may transfer your personal data to our affiliated entity, DOHE Global PTE Ltd, which is incorporated in Singapore.
• From time to time, some of our data processors (including third party payment processors or server providers), may be based outside of the European Area. In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request. 
• If you use our services while you are outside the European Area or if you are based outside of the European Area, your information may be transferred outside the European Area in order to provide you with our services or communicate with you.
• We may communicate with individuals or organisations outside of the European Area in providing our services. Those communications may include personal data (such as contact information).
• From time to time your information may be stored in devices which are used by our staff outside of the European Area (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the European Area, and the third country or international organisation in question has not been deemed by the UK Secretary of State to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. 

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal data or how it is handled, you can do so via our contact page or by email to jeena@dohegroup.com or post to JEENA KIM, 22 BISHOPSGATE, LONDON, EC2N 4BQ, UK.

Complaints

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.