Data Controller
The Dworkin Group i.e. Dworkin® includes all companies registered in the territory of the European Union in which Mr Jan Kubes, is the Chief Executive Officer of DWORKIN NL. BV, the holding company which controls the management and policies of Dworkin®.
This Notice details how Dworkin® collects, uses, stores, and protects personal data when you interact with our websites, products, or services, and is issued in accordance with:
- UK GDPR and the UK Data (Use and Access) Act 2025 (DUAA 2025) [UK]
- Regulation (EU) 2016/679 (EU GDPR) [EU].
- California Consumer Privacy Act (CCPA) / CPRA [US].
Where required, local entities act as joint or independent controllers in accordance with Article 26 EU GDPR and its UK equivalent.
What Data do we collect
We may collect and process the following categories of personal data:
- Identity and contact details
(e.g. name, business email address, telephone number) - Business and account information
(e.g. company name, role, contractual references) - Technical data
(e.g. IP address, browser type, device identifiers) - Usage data
(e.g. website interactions and service usage)
We do not intentionally collect special category personal data as defined under Article 9 EU GDPR / UK GDPR.
How we Collect Your Data
We collect personal data:
- Directly from you when you register, place orders, or contact us
- When you complete surveys or provide feedback
- Automatically through website technologies, including cookies
- Indirectly from trusted partners or publicly available sources, where permitted by law
How will we use your data
We process personal data only where a lawful basis applies under Article 6 EU GDPR and Article 6 UK GDPR, including:
- Contractual necessity – to provide requested products or services
- Legal obligation – compliance with tax, accounting, and regulatory duties
- Legitimate interests – business operations, security, and improvement of services
(balanced against your rights and freedoms) - Consent – where required for marketing or optional communications
Where consent is used as the lawful basis, it may be withdrawn at any time without affecting prior lawful processing.
Purposes of Processing
We use personal data to:
- Deliver and manage products and services
- Administer customer and business accounts
- Communicate operational and service‑related information
- Improve systems, websites, and customer experience
- Prevent fraud and secure our IT environment
- Comply with legal and regulatory obligations
Data Storage
Dworkin® securely stores your data on our data server farm in the Netherlands. This has multiple redundant backup systems and security measures in place to prevent loss of data.
Dworkin® will only keep your personal data for as long as is required to complete our business transaction and to satisfy legal obligations for governmental and tax purposes.
When and if your data is no longer required it will be securely deleted from our servers during our annual clean up and maintenance schedule.
Personal data is retained only for as long as necessary to:
- Fulfil contractual and operational purposes
- Meet statutory, tax, and regulatory requirements
Marketing Communications
Dworkin® would like to send you information about products and services that we think you might like.
If you have agreed to receive marketing you have the right to opt out at any time You have the right at any time to request that Dworkin® stop contacting you for marketing purposes.
- If you no longer wish to be contacted for marketing purposes please click here
- Under UK PECR (Privacy and Electronic Communications Regulations) and DUAA 2025 (UK) and EU ePrivacy rules (EU), marketing is only sent where lawful.
Data Sharing and Disclosure
We may share your personal data:
- Within the Dworkin Group, for internal administration
- With vetted processors and service providers, under written data processing agreements
- Analytics - Where used on our website, analytics and performance may collect or process technical information. This technical information may include such data as IP address, device/browser information, cookie identifiers or page interactions. For more information on how this data is used, you can may refer to Googles privacy policy
- With credit reference and fraud‑prevention agencies, where necessary
We do not sell personal data and do not disclose it for third‑party direct marketing.
International Transfers
Personal data may be transferred outside the UK, USA, or EEA.
Such transfers are safeguarded using:
- UK International Data Transfer Agreements (IDTAs) [UK]
- UK Addendum to EU Standard Contractual Clauses [UK/EU]
- EU Standard Contractual Clauses (SCCs) [EU]
- Adequacy decisions where applicable
Your Data Protection Rights
- The right of access – You have the right to request Dworkin® for copies of your personal data that they may hold.
- The right to rectification – You have the right to request that Dworkin® corrects or makes corrections to complete any information they hold about you
- The right to erasure – You have the right to request that Dworkin® erases your personal data, under certain conditions
- The right to restrict processing – You have the right to request that Dworkin® restricts processing of your personal data under certain conditions
- The right to object to processing – You have the right to object to Dworkin® processing your personal data under certain conditions
- The right to data portability - You have the right to request that Dworkin® transfers the data that the have collected, to another organisation or directly to you, under certain conditions
- The right to complain - under UK GDPR and the UK Data (Use and Access) Act 2025 (DUAA 2025) in the first instance you should forward any requests to our Data Protection Officer at dpo@dworkin.eu
In the unlikely event that you wish to exercise any of your statutory rights, Dworkin® will always follow the permitted requirement to respond to you within 30 days.
Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Enable core website functionality
- Improve performance and usability
- Analyse usage and compatibility
Cookie controls are available via your browser settings.
Further information: https://www.allaboutcookies.org
External Links
Our websites may link to third‑party websites.
This Privacy Notice applies solely to Dworkin® websites and services.
How to Contact us
Data Protection Officer
Email: dpo@dworkin.eu
Tel: +420 224 238 497
Dworkin spol. s r. o.
Rohanské nábřeží 657/7
180 00 Prague 8
Czech Republic
Supervisory Authorities and Escalations
United Kingdom
Information Commissioner’s Office (ICO)
https://www.ico.org.uk
European Union (Lead Authority – Netherlands)
https://autoriteitpersoonsgegevens.nl
Autoriteit Persoonsgegevens
You may lodge a complaint with the authority relevant to your habitual residence, place of work, or alleged infringement.
