Privacy Policy

About this policy

Welcome to the privacy policy of Dark Matter Commerce Limited (“We”, “Us”, “Our”). We respect your privacy and are committed to protecting your personal data. 

This policy sets out how We use and protect any personal information that you give Us when you use Our website at (“Our Site”) including any personal data you may provide through Our Site when you sign up to Our newsletter. We are committed to ensuring that your privacy is protected. Should We ask you to provide certain personal information by which you can be identified when using Our Site, then you can be assured that it will only be used in accordance with this policy. 

The trust and confidence of visitors to Our Site is of paramount importance to Us. In particular, We would stress that We do not sell, rent or trade email lists with other companies and businesses for marketing purposes. With this in mind, this policy provides further information regarding Our approach to personal information, how this information is kept secure, and related matters. 

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from May 2023.

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. If you believe that any information We are holding on you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect. This policy is governed by the laws of England and Wales. We both submit to the exclusive jurisdiction of the English courts.  If there is a conflict between a translated version and the English and Welsh version of this policy then, to the extent permitted under applicable law, the English and Welsh version shall prevail.

Who we are and contact details

We are the data controller and are responsible for your personal data.  We have appointed a data protection co-ordinator who is responsible for overseeing questions in relation to this policy.  If you have any questions about this policy, including any requests to exercise your legal rights, please contact the data protection co-ordinator at:

Post: Dark Matter Commerce, Colony, 5 Piccadilly Place, Manchester, M1 3BR.


You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Us in the first instance.

Links to other websites

Our Site may contain links to other websites of interest. However, once you have used these links to leave Our Site, you should note that We do not have any control over that other website. Therefore, We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this policy. You should exercise caution and look at the privacy policy applicable to the website in question.

What we collect

Personal data, or personal information, 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 the following personal information:

  • a) Identity data – including your name, marital status, title, date of birth and gender – this is collected when you fill in forms or by corresponding with Us by post, phone, email or otherwise. This includes personal data you provide when you request marketing to be sent to you or give us feedback or contact us.
  • b) Contact data – information including email address, post address and telephone number – this is collected as above for Identity data.
  • c) Anonymous tracking data – including geographic information utilising Google Analytics – this is collected from third parties (see below for more information on third parties).
  • d) Usage data – including information about how you use Our Site and services – this is collected using cookies (see below).
  • e) Marketing and Communications data – including your preferences in receiving marketing from Us and Our third parties and your communication preferences – this is collected as above for Identity data.
  • f) Technical data – including internet protocol (IP) address, 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 Our Site – this is collected using cookies (see below).


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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. However, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this policy.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • a) Internal record keeping
  • b) We may use the information to improve Our products and services
  • c) We may periodically send promotional emails about new products, special offers or other information which We think you may find interesting using the email address which you have provided
  • d) From time to time, We may also use your information to contact you for customer satisfaction and market research purposes. We may contact you by email, phone or mail
  • e) We may use the information to customise Our Site according to your interests.


We will only use your personal data when the law allows us to. Most commonly, We will use your personal data in the following circumstances:

  • a) Where we need to perform the contract We are about to enter into or have entered into with you.
  • b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests – the interest of Our business in conducting and managing Our business to enable Us to give you the best service and the best and most secure experience. We make sure We consider and balance any potential impact on you (both positive and negative) and your rights 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)
  • c) Where we need to comply with a legal obligation.


Generally, We do not rely on consent as a legal basis for processing your personal data although We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting Us.

Marketing and mailing lists

As part of the registration process for Our e-newsletter, We collect personal information. We use that information for a couple of reasons: to tell you about stuff you’ve asked Us to tell you about; to contact you if We need to obtain or provide additional information; to check our records are right and to check every now and then that you’re happy and satisfied. We don’t rent or trade email lists with other organisations and businesses.

We use a third-party provider, Hubspot, to deliver Our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help Us monitor and improve our e-newsletter. For more information, please see Hubspot’s privacy notice. You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of Our emails or by contacting Us.


When you use Our Guest Wi-Fi We may collect data about:

  • a) your device;
  • b) the volume of data which you use;
  • c) the websites and applications which you access; and
  • d) your usage by access time, frequency and location.


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.


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.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve Our Site in order to tailor it to customer needs. We only use this information for statistical analysis purposes and all information is strictly anonymous.

Overall, cookies help Us provide you with a better website, by enabling Us to monitor which pages found to be useful and are not. A cookie in no way gives Us access to your computer or any information about you, other than the data you choose to share with Us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of Our Site.

Use of third party platforms

Google Analytics

Our platforms use Google Analytics, a web analytics service offered by Google Inc. Google Analytics will make use of small pieces of data, known as cookies, which can be used to track and analyse the manner in which you use and operate our platforms. Such data will be transferred to, and stored on, a server in the USA operated by Google, Inc. Google, Inc. may i) transfer this data to third parties where required by law, or other third party processors used by Google, Inc. You may prevent cookies from being stored in relation to your visit to, and use of, our platforms but do please be aware that this may negatively impact upon the way in which the platforms work.

Social Media

When interacting with Us on social media, your username and public-facing information are available for Us to view. You have the right to request for Us to remove this information, however, please be aware that as the data is transferred from the social networks, it may not be feasible to fully delete the information.


We may also use Facebook’s advertising service known as “Facebook lookalike audiences” if you have informed Facebook of the fact that you use our platforms. Facebook lookalike will allow us to identify new potential consumers and users of our platforms and products on the basis that those new potential users share similar characteristics with you on Facebook – for example, on the basis that both users have “liked” the same Facebook pages. We may, therefore, share your email address and name with Facebook if you have logged into the platforms via your Facebook account, or have downloaded our platforms onto your device through a Facebook advertisement. More information about Facebook lookalike audiences is here.


Our Site uses a LinkedIn tracking code which uses cookies or similar technologies to track visitors of Our Site and gathers information about them related to their LinkedIn profile. We use the information gathered to improve Our website functionality, user experience and content. This data is used to deliver customised content and promotions to users whose behaviour indicates that they are interested in a particular subject area.

For more information about LinkedIn’s privacy policy, click here.

International Transfers

We share your personal data within those third parties listed above. This will involve transferring your data outside the UK.

Many of Our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, We ensure a similar degree of protection is afforded to it by ensuring that We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. 

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with you.

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, regulatory, tax, accounting or other 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.

In some circumstances you can ask Us to delete your data: see Your Legal Rights below for further information.

In some circumstances We will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

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 “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask Us to suspend the processing of your personal data in the following scenarios:

  • a) If you want us to establish the data’s accuracy.
  • b) Where Our use of the data is unlawful but you do not want us to erase it.
  • c) 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.
  • d) You have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to use it.


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. 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.

If you wish to exercise any of the rights set out above, please contact Us.

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 could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.