Privacy Notice
dasa is a free, AI-powered tool which allows you to access support regarding your domestic appliances. We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal data when you use our dasa tool. It also explains your rights in relation to your personal data and important information about how we use artificial intelligence (AI) to provide dasa to you.
We collect, use, and are responsible for certain personal data about you. When we do so, we are subject to the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018. We refer to these as data protection laws throughout this privacy notice.
Key Terms
| Term |
Description |
| We, Us, Our |
dasa and our services are owned and operated by NAC (Domestic Appliances) Ltd (our, us or we), a limited company registered in England and Wales (registration number 07531907). |
| Data Protection Team |
You can contact us:
By email: dataprotection@dasa.org.uk
By post: Data Protection Manager, dasa, 4 Calder Close, Calder Park, Wakefield, West Yorkshire WF4 3BA. |
| Personal Data |
Any information relating to an identified or identifiable individual. |
| Special Category Personal Data |
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, sex life, or sexual orientation. |
| Data Subject |
The individual who the personal data relates to. |
Personal Data We Collect About You
dasa is a tool which allows you to ask questions about your appliances and get the help you need. As such, the personal data we collect includes your IP address, device information, and the information you input into the platform. Specifically, we collect and use the following personal data about you:
- Your IP address and device information.
- Any personal data you choose to input into the dasa platform to ask questions. Given the nature of dasa, we do not request specific personal data as part of this service.
Depending on the nature of your query, we may recommend professional help or installers to you, which directs you to our NAC Repairs website. If you click through to NAC, the NAC Privacy Notice will apply, and you should read this before interacting with us to understand more about how NAC processes your personal information.
How Your Personal Data Is Collected
We collect most of this personal data directly from you when you choose to use dasa and ask us questions.
How and Why We Use Your Personal Data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- Where you have given consent.
- To comply with our legal and regulatory obligations.
- For the performance of a contract with you or to take steps at your request before entering into a contract.
- For our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, provided this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests to balance our interests against your privacy rights.
Table of Uses of Personal Data
| What We Use Your Personal Data For |
Our Reasons |
| Providing the dasa offering to you |
To perform our contract with you or to take steps at your request before entering into a contract. |
| Preventing and detecting fraud against you or us |
For our legitimate interest, i.e., to minimise fraud that could be damaging for you and/or us. |
| To enforce legal rights or defend or undertake legal proceedings |
Depending on the circumstances:
— To comply with our legal and regulatory obligations;
— In other cases, for our legitimate interests, i.e., to protect our business, interests, and rights. |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations. |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use |
For our legitimate interests, i.e., to make sure we are following our own internal procedures. |
| Operational reasons, such as improving efficiency, training and quality control |
For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price. |
| Ensuring the confidentiality of commercially sensitive information |
Depending on the circumstances:
— For our legitimate interests, i.e., to protect trade secrets and other commercially valuable information;
— To comply with our legal and regulatory obligations. |
| Statistical analysis to help us manage our business |
For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price. |
| Preventing unauthorised access and modifications to systems |
Depending on the circumstances:
— For our legitimate interests, i.e., to prevent and detect criminal activity that could be damaging for you and/or us;
— To comply with our legal and regulatory obligations. |
| Protecting the security of systems and data used to provide dasa |
To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases, our reasons are for our legitimate interests, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us. |
| Statutory returns |
To comply with our legal and regulatory obligations. |
| Ensuring safe working practices, staff administration, and assessments |
Depending on the circumstances:
— To comply with our legal and regulatory obligations;
— For our legitimate interests, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you. |
| Sharing your personal data with members of our group and third parties |
In connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases, your data will be anonymised where possible and only shared where necessary. Depending on the circumstances:
— To comply with our legal and regulatory obligations;
— In other cases, for our legitimate interests, i.e., to protect, realise or grow the value in our business and assets. |
Our Use of Artificial Intelligence
dasa uses AI to support with your appliance queries. We use OpenAI to help power this solution. Note that any data you input into dasa (we recommend this is not personal data; please see our Terms of Service for more information) will be ingested and stored by us and OpenAI to support broader learning, including developing and improving our and their services, such as when we/they train and improve AI models.
Who We Share Your Personal Data With
We routinely share personal data with:
- Companies within the NAC group.
- Third parties we use to help deliver dasa to you, i.e., our IT vendors and OpenAI integrated into dasa.
- Other third parties we use to help us run our business, e.g., marketing agencies, professional advisors, or website hosts.
We only allow these organisations to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data, and we also impose contractual obligations on them to ensure that they can only use your personal data to provide dasa to you.
Occasionally, we or the third parties mentioned above also share personal data with:
- Our and their external auditors, e.g., in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations.
- Our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.
- Law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations.
- Other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. Usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Where Your Personal Data Is Held
Personal data may be held at our offices and those of our group companies, third-party agencies, service providers, representatives, and agents as described above (see above: ‘Who We Share Your Personal Data With’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring Your Personal Data Out of the UK and EEA’.
How Long Your Personal Data Will Be Kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we generally keep data for a period of seven (7) years following your interaction with dasa in line with statutory limitation periods. Following the end of the relevant retention period, we will delete or anonymise your personal data.
Transferring Your Personal Data Out of the UK and EEA
We generally host personal data in the UK and EEA. However, it is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- The UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries with adequacy regulations is available here.
- In the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries with adequacy decisions is available here.
- There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- A specific exception applies under relevant data protection law.
Your Rights
You have the following rights, which you can generally exercise free of charge:
- Access: The right to be provided with a copy of your personal data.
- Rectification: The right to require us to correct any mistakes in your personal data.
- Erasure: The right to require us to delete your personal data—in certain situations.
- Restriction of Processing: The right to require us to restrict processing of your personal data in certain circumstances, e.g., if you contest the accuracy of the data.
- Data Portability: The right to receive the personal data you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.
- To Object: The right to object:
— At any time to your personal data being processed for direct marketing (including profiling);
— In certain other situations to our continued processing of your personal data, e.g., processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise, or defence of legal claims.
- Not to Be Subject to Automated Individual Decision Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
- The Right to Withdraw Consent: If you have provided us with consent to use your personal data, you have a right to withdraw that consent easily at any time. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.
For more information on each of these rights, including the circumstances in which they apply, please contact us (see ‘Data Protection Team’ for our contact details) or see the Guidance from the UK Information Commissioner’s Office (ICO).
If you would like to exercise any of these rights, please contact us using the details set out at the beginning of this notice, and provide enough information to identify yourself, and any additional identity information we may reasonably request from you.
Keeping Your Personal Data Secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit
www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to Complain
Please contact us if you have any queries or concerns about our use of your personal data (see ‘Data Protection Team’ for our contact details). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator) at
www.ico.org.uk.
Changes to This Privacy Notice
This privacy notice was last updated in August 2024. We may update it from time to time by updating it on our website. Please check periodically for any updates.
Do You Need Extra Help?
If you would like this notice in another format (for example, audio, large print, braille) please contact us (see ‘Data Protection Team’ for our contact details).
