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Privacy Policy

Version 1.0 – Effective 1 November 2025

DIDWW Ireland Limited | dpo@didww.com

1. Introduction

This Privacy Policy explains how DIDWW Ireland Limited (“DIDWW”, “we”, “us”, “our”) collects, uses, and protects Personal Data in connection with the contact.center™, including its multi-channel messaging and email marketing automation features, and related business services (“Services”).

2. Who We Are

Data Controller: DIDWW Ireland Limited

Registered address: 11 The Haven, Malahide, Co. Dublin, K36 R983, Ireland

Data Protection Officer (DPO): contactable via the email above.

DIDWW Ireland Limited is established in Ireland and is subject to the EU General Data Protection Regulation (GDPR).

3. Our Role Under GDPR

DIDWW shall act in two distinct capacities:

  • Data Controller: for data we process to operate our business – such as customer account creation, billing, support, marketing, and security. We determine the purpose and means of this processing.
  • Data Processor: for data we process on behalf of our business customers who use the Messaging Platform to send or manage communications. DIDWW shall act strictly under their documented written instructions.

Our obligations in this capacity are governed by our Data Processing Addendum (“DPA”).

If your Personal Data is processed through one of our customers’ accounts (for example, you receive a message sent via the Platform), please contact that customer directly for privacy-related requests, as they remain the Data Controller.

4. Personal Data We Process as Controller

We process the following categories of Personal Data when you use our Services.

Processing Activity

Personal Data Categories

Purpose of Processing

Lawful Basis (Art. 6 GDPR)

Website & Cookies

Cookies, IP address, Browser information

Optimize Customer experience and ensure the functionality of the website.

Consent (Art. 6(1)(a))

Account & Services

Name, Email, Phone, Address, ID/Passport, Business certificate

Create, manage, and verify accounts (KYC); Process payments and deliver Services; Comply with regulatory requirements (e.g., AML).

Contract (Art. 6(1)(b)) / Legal Obligation (Art. 6(1)(c))

Service Usage

Message metadata, Routing data, CDRs/Logs

Deliver and bill for Services; Maintain service performance and reliability; Comply with lawful intercept and numbering rules.

Contract (Art. 6(1)(b)) / Legal Obligation (Art. 6(1)(c))

Support & Security

Name, Email, Phone, Message content, Login data, IP, Device information

Provide customer assistance; Protect platform integrity and prevent abuse.

Contract (Art. 6(1)(b)) / Legitimate Interest (Art. 6(1)(f))

Marketing

Name, Email

Send service updates and marketing content.

Consent (Art. 6(1)(a))

Special Categories of Data: We do not intentionally process any special categories of Personal Data (Art. 9 GDPR).

Automated Decision-Making: We do not perform automated decision-making that produces legal effects.

5. Cookies

We use cookies and similar technologies on our websites and platform interfaces. You can manage your preferences through our cookie banner. Detailed information is available in our Cookie Policy.

6. Processing on Behalf of Customers (Processor Role)

When customers use the contact.center™ platform to send messages or manage contacts, DIDWW shall act as a Data Processor. We process the necessary data solely under the customer’s documented written instructions and only for providing the service.

The categories of Controller Personal Data we process on behalf of the Controller (our customer) include:

  • Contact Information: Names, Surnames, Phone Numbers, Email Addresses, and other custom contact attributes.
  • Message Data: Message content and delivery status reports.
  • Routing Data: Technical metadata required for message delivery.

Email Marketing and Campaign Automation:

When customers use the Messaging Platform to create or send marketing emails, newsletters, or automated campaigns, DIDWW processes message content, contact information, campaign templates, attachments, subject lines, delivery statistics, and engagement data (such as opens, clicks, bounces, and unsubscribes) solely for the purpose of providing the service.

Tracking and Analytics:

Where customers enable campaign tracking or analytics, DIDWW processes event data (for example, open and click rates) on behalf of the customer for performance reporting. These features are customer-controlled and may be disabled at any time.

Automations and Integrations:

The platform allows customers to configure automated workflows (for example, sending messages based on triggers or scheduled events). DIDWW processes the data required to execute these automations only according to the documented customer’s instructions and does not use such data for any independent purpose.

Customer Responsibility:

Customers are solely responsible for ensuring that all message recipients have been lawfully contacted and that applicable consent or other lawful bases have been obtained in accordance with the GDPR, the ePrivacy Directive, and national marketing laws.

Our obligations in this role are governed by our DPA, which forms part of each customer contract. A current list of authorised Sub-Processors is available here and is updated as required.

7. International Data Transfers

All international transfers are conducted under the EU Standard Contractual Clauses (Commission Decision 2021/914/EU) or equivalent lawful mechanisms, including the EU–US Data Privacy Framework where applicable. Jurisdiction-specific terms are described in our DPA.
You can request a copy of these safeguards by contacting dpo@didww.com.

8. Data Retention

We retain Personal Data only for as long as necessary to provide the Services, comply with applicable legal obligations, resolve disputes, and enforce our agreements.

  • Data related to billing and Know Your Customer (KYC) requirements are typically held for up to 7 years to comply with Irish tax and Anti-Money Laundering legislation.
  • Log and message data required for telecom regulatory compliance are held for up to 12 months.
  • Campaign Data – retained for a maximum of one hundred eighty (180) days after delivery.
  • Customer Account and Contact Data – retained for the duration of the account and deleted or returned within thirty (30) days following termination.
  • Telecommunication Logs – retained for the period required by law (typically six to twenty-four months).

When data is no longer required, they are securely deleted or anonymised.

9. Security of Personal Data

DIDWW maintains an Information Security Management System consistent with ISO/IEC 27001:2022, ensuring appropriate technical and organisational measures as detailed in our DPA.

10. Your Rights

Under the GDPR, you may have the right to:

  • Access, rectify, or erase your Personal Data;
  • Restrict or object to processing;
  • Receive your data in a portable form;
  • Withdraw consent at any time (where applicable).

Requests should be sent to dpo@didww.com. If your data are processed under a customer account, please direct your request to that customer.

You also have the right to lodge a complaint with the Data Protection Commission (Ireland) or your local supervisory authority.

11. Updates to This Policy

We may update this Policy from time to time to reflect changes in law or our operations. The effective date will always appear at the top of this page, and significant changes will be announced through appropriate channels. Material changes will also be reflected in the corresponding DPA or Sub-Processor List updates, as applicable.

12. Contact

If you have any questions or concerns regarding this Policy, please contact:

Data Protection Officer
DIDWW Ireland Limited
Email: dpo@didww.com
Address: 11 The Haven, Malahide, Co. Dublin, K36 R983, Ireland

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