Who we are
Digiten Michal Heichel is a sole-trader business established in Poland and the controller responsible for the personal data described in this policy.
Business address: Adama Mickiewicza 33/82, 60-837 Poznań, Poland.
Email: connect@digiten.co.uk.
Websites: digiten.co.uk and optiten.com.
Digiten and Optiten are brands of the same business. Optiten is not a separate legal entity. This policy applies to both brands. References to “we”, “us” and “our” mean Digiten Michal Heichel.
Scope of this policy
This policy covers visitors to our websites, people requesting content or information, prospective customers, customers’ business contacts and people who communicate with us, including through LinkedIn.
Where we process personal data on a client’s instructions when delivering services, the client’s privacy information and our agreement with that client govern that processing. Separate privacy information may apply to recruitment or employment.
What personal data we collect
Identity and professional details: your name, job title, employer, business sector, professional profile, business contact details and country or business location.
Enquiries and relationship information: information submitted through forms, requested resources, correspondence, meeting notes, service interests and the status of our discussions with you.
Prospecting information: the source of your details, information about your organisation’s publicly identifiable technology use, such as Piano, and our assessment of how our services may relate to your professional responsibilities.
Preferences and campaign records: subscription and consent records where applicable, objections, unsubscribe requests, suppression records, messages sent, delivery failures and replies.
Technical and engagement information: IP address, browser and device information, website activity and, where tracking is enabled lawfully, email opens, link clicks and associated dates, times and identifiers.
The information collected depends on how you interact with us and the services and features in use. Please do not send sensitive personal information through general enquiry forms unless we specifically request it through an appropriate channel.
Where personal data comes from
We collect information directly when you contact us, complete a form, request content or services, subscribe to communications, or interact with us on LinkedIn or other business channels.
We also obtain professional contact information from Apollo.io and publicly available sources, including LinkedIn profiles and company websites. We may combine this with information about your organisation, including its industry and technology use, to identify relevant business contacts.
Information may also be collected through our websites and email technologies as explained below. Availability on a public website or in a business contact database does not mean that you have consented to marketing.
When we obtain your personal data indirectly, we provide privacy information within the period required by law: generally within one month, or at our first communication or first disclosure to another recipient if earlier. You can ask us about the source of the information we hold about you.
Why we use personal data and our lawful bases
Enquiries, requested content and business relationships: we use relevant contact details and correspondence to respond to you, provide requested resources, prepare proposals and manage relationships. We rely on our legitimate interests in running our business and responding to enquiries. Where you personally enter into a contract with us, or request steps before doing so, we rely on contractual necessity for the processing needed for that purpose.
Business research and prospecting: we use professional information to identify organisations and people who may benefit from our services. Where appropriate, we rely on our legitimate interests in developing relevant business relationships, after considering necessity, reasonable expectations and the impact on individuals.
Marketing: we rely on consent where required, or legitimate interests where applicable law permits marketing on that basis. Our interest is to promote relevant services and develop business relationships. Legitimate interests do not override a legal requirement for prior consent to a particular communication.
Website and email engagement: we use engagement information to understand interest and improve communications. Where consent is required for tracking or access to information on a device, consent is required before that activity. For other permitted measurement, any reliance on legitimate interests is subject to the applicable legal requirements and the impact on individuals.
Security and administration: we process information to protect our systems, prevent abuse, manage access and resolve problems, relying on our legitimate interests in secure and reliable services. Device access remains subject to separate cookie and similar-technology rules.
Legal compliance and rights: we process information to meet applicable legal obligations, including responding to data-protection requests. Where necessary, we rely on legitimate interests to establish, exercise or defend legal claims and to maintain records preventing unwanted marketing.
Marketing and your choices
Our communications may concern services, industry insights, resources and relevant business opportunities offered under the Digiten or Optiten brand. We may identify prospective customers through Apollo.io, LinkedIn and company research and contact appropriate business contacts where applicable law permits.
Requesting a resource, appearing in Apollo.io, having a public professional profile or working for an organisation using a particular technology does not by itself constitute consent to marketing. Where consent is required, it must be obtained before sending. Downloading content does not by itself amount to agreeing to unrelated marketing.
You can object to direct marketing at any time, free of charge. Use the unsubscribe option in a marketing email, reply asking us to stop, or email connect@digiten.co.uk. This also covers profiling related to direct marketing.
Unless you expressly request a narrower preference, a request to stop marketing applies to both Digiten and Optiten. We retain the minimum information needed on a suppression list to prevent further marketing, rather than simply removing every record of your objection.
You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Marketing opt-outs do not prevent necessary non-marketing correspondence about services you request, existing contracts or legal obligations.
Contact management, email delivery and social platforms
Mautic: we use self-hosted Mautic on premises in Poland to manage contacts, tags, lead stages, communications and marketing activity. We may update records manually following correspondence. Mautic also supports email and website engagement tracking, as described below.
Mailgun: emails sent through Mautic are delivered using Mailgun. Relevant email addresses, message content and delivery information are processed to provide that service. Some outreach is sent manually through our business email accounts rather than through Mautic.
Apollo.io: we use Apollo to find and research professional contacts and support prospecting. Apollo operates its own business contact database and may act as an independent controller for that database. Its own privacy information explains its processing and your rights in relation to Apollo: Apollo privacy policy.
LinkedIn: we use LinkedIn for professional research and business interactions. LinkedIn also processes personal data for its own platform purposes under its privacy policy.
An objection made to us applies to our processing. To exercise rights directly against an independent platform, you may also contact that platform. Using a service provider does not remove our responsibility for our own use of your information.
Email tracking and Mailtrack
Mautic can record whether an email is opened and whether links are clicked. We also plan to use Mailtrack, provided by Mailsuite, for selected manually sent campaigns. Where used, Mailtrack can record email opens and, depending on the features enabled, link clicks.
Open tracking generally uses a small image associated with an email. Loading it can produce an event linked to the recipient or message. Click tracking can use identifiable links to record when a link is followed. Records may include a message or recipient identifier, time, IP address and browser or device information, depending on the tool and configuration.
These records help us understand engagement and improve follow-up and communications. Open and click records are not definitive proof that a person read an email: email security tools and privacy features may load images or follow links automatically.
Permission to receive marketing is separate from permission for tracking. Where applicable law requires consent to email tracking, that tracking must not operate without the required consent. This policy itself does not provide consent. You may contact connect@digiten.co.uk to withdraw tracking consent or object to engagement processing based on legitimate interests.
Your email application may allow you to block remote images; doing so can reduce open tracking but does not necessarily prevent other forms of tracking. Unsubscribing from marketing stops future marketing messages and their associated tracking.
Website cookies, tracking and form security
Our websites use cookies and similar technologies for operation, security and, where enabled, analytics and marketing measurement. Mautic website tracking can record page visits and associate activity with a contact where an identifier, form submission or email interaction allows that association.
Technologies requiring consent must only be used after the necessary consent has been obtained. Strictly necessary technologies and any other statutory exceptions are subject to the conditions of applicable law. Consent to website tracking does not automatically provide consent to email tracking or marketing.
You can control cookies through your browser and, where available, the website’s cookie settings. Browser controls are additional tools and do not replace our obligation to obtain consent where required. You can also contact us about withdrawing consent. Blocking essential technologies may affect website functions.
We use Google reCAPTCHA on website forms to help prevent spam and automated abuse. It may analyse IP addresses, browser and device information and interaction patterns. Our security purpose does not automatically exempt every cookie or device-access operation from consent requirements. Google’s processing is explained in its privacy policy and terms of service.
Segmentation and decisions
We may group contacts by employer, role, country, service interests and relationship stage, and use relevant engagement information to help select communications and prioritise follow-up. This may amount to profiling for direct-marketing purposes. You have the right to object to that profiling.
Our use of contact tags and lead stages is for organising business relationships and follow-up, rather than making decisions producing legal or similarly significant effects solely by automated means.
Who may receive personal data
Personal data may be accessed by authorised people working for our business and service providers supporting website hosting, IT, business email, email delivery, contact management and security. The services described above receive the information needed for the functions used. Hosting Mautic in Poland does not mean that all associated email and platform processing takes place in Poland.
Depending on the service and purpose, a provider may process information on our instructions or act as an independent controller for its own processing. Where providers act on our instructions, applicable data-processing terms are required.
We may disclose relevant information to professional advisers, competent authorities or courts where necessary for advice, compliance with law or the establishment, exercise or defence of legal claims.
International transfers
Some external services may process personal data outside Poland and the European Economic Area (EEA), including in the United States. Where UK data-transfer rules apply, processing outside the UK may also constitute a restricted transfer.
Transfers requiring protection must be covered by a valid legal mechanism. Depending on the recipient and applicable law, this may be an adequacy decision or appropriate contractual safeguards, such as the European Commission’s Standard Contractual Clauses, with supplementary measures where necessary. Where required under UK law, the relevant UK transfer instrument must also apply.
You can contact connect@digiten.co.uk for information about the destinations and safeguards relevant to your data and to request a copy of applicable safeguards, subject to necessary redactions protecting confidential information and others’ rights.
How long we keep personal data
Retention depends on the purpose and category of information, rather than simply on whether a record exists in a marketing system.
Enquiries and prospective contacts: retention is determined by the status and age of the enquiry, the last meaningful interaction, whether the person still holds a relevant role, the accuracy of their details and whether there remains a justified business purpose. Information should be removed or anonymised when that purpose no longer exists.
Customer and contract records: retention reflects the duration of the relationship, applicable accounting and tax requirements and relevant legal limitation periods.
Engagement and technical records: retention is limited by the period needed to assess the relevant campaign, maintain security or investigate a specific issue. Identifiable tracking information should not be kept solely because the contact record remains active.
Consent and suppression records: we retain sufficient evidence to demonstrate permission where relied upon, and the minimum information needed to honour objections and avoid re-contact for as long as that remains necessary.
Withdrawal of consent or an objection ends the relevant marketing processing. It does not necessarily require deletion of records needed for suppression, legal obligations or legal claims. Backup copies may remain until their scheduled replacement and remain subject to appropriate access restrictions. Contact us for retention information relating to your specific data.
Your data protection rights
Under the EU GDPR and, where applicable, UK data-protection law, you may have rights to access your personal data, correct inaccurate information, request erasure, restrict processing and receive certain data in a portable format. The conditions and exceptions depend on the right and the processing involved.
You may object to processing based on legitimate interests for reasons relating to your particular situation. Your right to object to direct marketing, including related profiling, is unconditional. You may also withdraw consent at any time.
To exercise your rights, email connect@digiten.co.uk or write to our business address. We may request information reasonably needed to confirm identity. We normally respond within one month. Where a lawful extension is necessary, we explain the reason and applicable timeframe.
Providing information for marketing is voluntary. If you do not provide information needed to answer an enquiry or fulfil a contract, we may be unable to provide that response or service. You do not have to agree to optional marketing to contact us.
Complaints
You can raise concerns with us at connect@digiten.co.uk. You also have the right to complain directly to a competent data-protection authority without first contacting us.
In Poland, the supervisory authority is the President of the Personal Data Protection Office (UODO): how to lodge a complaint. In the EEA, you may also complain to the authority in your place of habitual residence, work or the alleged infringement. Where applicable, you can complain to the UK Information Commissioner’s Office: ICO complaints.
Security
We use technical and organisational measures appropriate to the risks to protect personal data against unauthorised access, loss, alteration and disclosure. No internet transmission or storage system can be guaranteed completely secure.
Changes and contact details
We may update this policy when our activities or legal requirements change. The revision date appears at the top of this page. Where required, we will provide additional notice of material changes or seek fresh consent.
For questions about this policy or personal data processed under either brand, contact:
Digiten Michal Heichel
Adama Mickiewicza 33/82
60-837 Poznań, Poland
connect@digiten.co.uk.