Website Privacy Policy (Updated September 2026)

Introduction

Welcome to the Distinctive System's privacy policy.

Distinctive Systems Limited (DSL, we, our or us) respects your privacy and is committed to protecting your personal data. This privacy policy informs you how we look after your personal data when you visit our website (regardless of where you visit it from), purchase or subscribe to use our software, enter into a contract for software support or maintenance or provide us with data via secure file transfer. This privacy policy also tells you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CONTACT DETAILS
11. COMPLAINTS
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
13. THIRD PARTY LINKS

1. Important information and who we are

Purpose of this privacy policy

This privacy policy gives you information on how DSL collects and processes your personal data through your use of this website, including any data you may provide through this website, provide to us when you purchase or subscribe to use our software or contract with us for software support or maintenance or give to us via email.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Data Controller

DSL is the data controller and is responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the information set out in the contact details section (Paragraph 10).

2. The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, title and username or similar identifier.
• Contact Data includes postal address, email address and telephone numbers.
• Financial Data includes bank account details, credit card and debit card details.
• Transaction Data includes details about payments to and from you and details about products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and our products and services.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve our website and our service offering.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• • complete the ‘contact us’ form on our website;
  • purchase or subscribe to use software products from us including signing up for any of our Apps;
  • enquire about purchasing or subscribing to use our software products;
  • contract with us for software maintenance or support;
  • request marketing to be sent to you; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website and our products and services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie tool for further details.
• Third parties or publicly available sources. We may receive Technical Data about you from the following parties:
• • analytics providers such as Google based outside the EU; and
  • search information providers such as Google or Bing based outside the EU.
• Financial Data is collected from customers in order to set up direct debit payments.
• Transaction Data relates to information to products and services quoted for or purchased from us or from other users of our software through our Connect database. 
• Identity and Contact Data is collected from publicly available sources such as Companies House based inside the UK.
• Location Data is collected from use of our products and services (including our apps) which may be integrated with map services provided by Google.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us (using the contact details in paragraph 10) if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out below. 

Direct Marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical and Usage Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by:

(a)        following the opt-out links on any marketing message sent to you; or

(b)        by contacting us at the details set out in paragraph 10.

Where you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (e.g. relating to software updates or updates to our standard contracts).

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. However, if you are based outside of the UK and contact us from a country which is best serviced by our subsidiaries in the USA or Australia we reserve the right to share your personal data with Distinctive Systems Inc or Distinctive Systems (Australia) Pty Ltd (as appropriate).

Cookies

For more information about the cookies we use, please see our cookie tool.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties  being our subsidiaries:

• Distinctive Systems Pty Limited acting as joint controllers and who is based in Australia and provides software and support to customers located in Australia and New Zealand; and
• Distinctive Systems Inc. acting as joint controllers and who is based in the USA and provides software and support to customers located in USA, Canada and the Caribbean.

External Third Parties

• Service providers including Microsoft Azure and Storm Internet acting as processors based in the UK who provide cloud storage services. You can read Microsoft’s privacy policy by clicking on this link: https://www.microsoft.com/en-gb/privacy/privacystatement. You can read Microsoft’s privacy policy by clicking on this link: https://www.storminternet.co.uk/legal/securitypractices/
• IT providers including Microsoft who are based outside of the EU who provide secure data transfer and other IT services (see privacy policy above).
• IT Services which our software integrates including Google Maps. You can read Google’s privacy policy by clicking on this link: https://policies.google.com/terms?hl=en-US
• Providers of business services including:
• • Docusign (you can read their privacy policy by clicking on this link: https://www.docusign.com/en-gb/privacy);
  • Freshdesk (you can read their privacy policy by clicking on this link: https://support.freshdesk.com/support/solutions/articles/50000000206-freshworks-privacy-update); and
  • Campaign Monitor (you can read their privacy policy by clicking on this link: https://www.campaignmonitor.com/trust/privacy-hub/ )
• Users of Coach Manager Connect who are based in the UK in order to provide the ‘Where is My Coach?’ feature.
• Professional advisers controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, Driver and Vehicle Licensing Authority, regulators and other authorities acting as joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. You can read the DVLA’s privacy policy by clicking on this link https://www.gov.uk/government/publications/dvla-privacy-policy/dvla-privacy-policy and HMRC’s privacy policy by clicking on this link: https://www.gov.uk/government/publications/data-protection-act-dpa-information-hm-revenue-and-customs-hold-about-you/data-protection-act-dpa-information-hm-revenue-and-customs-hold-about-you
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, companies in the USA which have signed up to the Data Privacy Framework;
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact the DPO at the contact details set out in paragraph 10.

Where appropriate we may share your personal data with our US subsidiary Distinctive Systems Inc. We ensure your personal data is protected by requiring Distinctive Systems Inc to follow the same set of procedures when processing your personal data. Distinctive Systems Inc is a participant in the Data Privacy Framework which provides equivalent protection to personal data and which has been approved by the ICO. 

When acting as data controller we will not share your personal data with Distinctive Systems (Australia) Pty Ltd, our subsidiary in Australia.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (using the contact details in paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:

Email address: GDPR@distinctive-systems.com 

Telephone number: 01904 692269

Postal address: Amy Johnson Way, York, YO30 4XT

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 15th September 2026.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us for example, a new postal address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.