Privacy
Disguise Group Privacy Policy
Date: 19 June 2025
Protecting your personal data (your “Data”) is a serious matter for the Disguise Group. Disguise Systems Limited, including any affiliates and subsidiaries (including but not limited to Disguise Technologies Limited and Meptik, LLC) (collectively referred to as “Disguise Group”, “we,” “us,” “our”) respect your privacy and is committed to protecting your Data. This privacy policy will explain how we look after your Data if you are a customer, supplier, professional contact of us, when you use www.disguise.one / www.meptik.com and our affiliated websites, applications, and online services (collectively, our “Websites”), use our hardware or software products, or otherwise provide us with such Data.
It is important that you check back often for updates to this Privacy Policy as it may be updated from time to time, and please read this Privacy Policy, together with any other privacy policy we may provide from time to time, so that you are fully aware of how and why we are using your Data.
This Privacy Policy applies to all your Data collected by the Disguise Group, whether through our Websites or by any other means. If your local legislation requires so, this Privacy Policy may be supplemented by other documentation that we invite you to read carefully.
This Privacy Policy does not apply to third-party websites, plug-ins and mobile applications that may link to the Websites or be linked to on the Websites. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We are not responsible for the actions or privacy practices of third-party websites and applications. Please consult those websites and applications directly to understand their privacy practices.
INFORMATION ABOUT US
Disguise Systems Limited (a company incorporated in England and Wales with company number 09908649) is the controller and entity responsible for deciding how and why your Data is processed. We have appointed a Data Privacy Manager 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 Data Privacy Manager using the details set out at the bottom of this Privacy Policy.
INFORMATION WE COLLECT ABOUT YOU
We collect, process, retain and transfer the following Data:
- Information you give us: Whether you are a supplier or customer (including a prospective customer) we receive and store information you provide us (whether from the telephone, email, when completing product licence information, on our Websites, or at any event such as a tradeshow) including your first name, surname, identification documents (for example passports and driving licences), postal address, phone number, bank account, payment card details, details about payments to and from you, details of products and services you have purchased from us, email address, job title, relevant place of work, marketing and communications preferences and other related details required so that we can provide our goods and/or services.
- Automated technologies or interactions: As you interact with our Websites, we will automatically collect technical and usage data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
- Information from software and hardware: Some of our hardware and software products (including our artificial intelligence (AI) products) will collect information about your hardware or use of our software and share this with us. Most of this information is technical information which will not identify you personally, but the information may include your IP address and product licence information. The information will be used to help us to resolve technical issues, improve the development of our products, and to detect use of fraudulent licence keys. You may be able to deactivate information sharing on certain hardware or software products. Please refer to the options and guides of those products.
- Information from social media: When you interact with us or our Websites on a social media platforms (including but not limited to Facebook, X (formerly known as Twitter), YouTube, Instagram, LinkedIn and Vimeo), we may collect the Data that you make available to us on that page, including your account ID or username and other information included in your posts.
- Information from other sources: We may collect information about you from third parties or collected offline, such as information collected by Disguise at events, through our sales partners, through sponsorship of events including but not limited to webinars, through market research or collected over the phone and adding it to your account information. This information may include, but is not limited to, demographic information that is publicly available, additional contact information, group affiliations and occupational information.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Data but is not considered Data in law as this will not directly or indirectly reveal your identity. For example, we may aggregate your technical and usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your Data so that it can directly or indirectly identify you, we treat the combined data as Data which will be used in accordance with this Privacy Policy.
Where we need to collect Data by law, or under the terms of a contract we have with you and you fail to provide that Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW WE USE YOUR PERSONAL DATA
We use your Data when the law allows us to and to help us personalise and continually improve your experience interacting with us, including fulfilling your orders and requests for information, analysing and compiling trends and statistics, and communicating with you.
Most commonly, we will use your Data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- 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;
- Where we need to comply with a legal or regulatory obligation; and/or
- Where we have obtained your consent.
More specifically, we have set out below, in a table format, a description of the ways we plan to use your Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity |
Lawful basis for processing including basis of legitimate interest
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To register you as a new customer or supplier. For us to do this, we may collect your first name, surname, postal address, email address, phone number, job title and relevant place of work.
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Performance of a contract with you.
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If applicable, before we enter into a contract with your organisation, we may need to screen you and/or the organisation you work for to assist our due diligence process. To enable us to do this, we may need to verify your identity. For us to do this, we may collect your first name, surname, passport and/or driving licence.
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Performance of a contract with you | |
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To process and deliver your order including:
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(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
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To process and deliver your order, including but not limited to: (a) managing payments, fees and charges; (b) collecting and recovering money owed to us; and (c) delivering products or services (including any training course orders) whether undertaken by us or by a third party, such as a sales partner. For us to do this, we may collect your first name, surname, postal address, email address, phone number, bank account details, payment card details, details about payments to and from you, details of products and services you have purchased from us, job title, relevant place of work and marketing and communication preferences.
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(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to recover debts due to us). (c) Consent. |
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To provide requested content, products and services to you (including free software trials and general enquiry forms based on our Websites). For us to do this, we may collect your first name, surname, email address, phone number, job title, relevant place of work and marketing and communication preferences.
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To manage warranty claims, servicing activities and queries regarding our goods or services provided to you. For us to do this, we may collect your first name, surname, postal address, email address, phone number, bank account details, payment card details, details about payments to and from you, details of products and services you have purchased from us, job title and relevant place of work.
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(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to provide aftercare services to you). |
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To manage our relationship with you which will include: (a) communicating with you about your account or transactions; (b) notifying you about changes to our terms or Privacy Policy; (c) asking you to leave a review or take a survey or feedback form (for example, as a result of our training); and (d) send you information about features and enhancements on our Websites. For us to do this, we may collect your first name, surname, postal address, email address, phone number, bank account details, payment card details, details about payments to and from you, details of products and services you have purchased from us, technical and usage data, job title, relevant place of work and marketing and communication preferences.
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(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services). (d) Consent. |
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To send newsletters, offers and promotions for our products and services, third party products and services or special events by e-mail, text, or another medium. For us to do this, we may collect your first name, surname, postal address, email address, phone number, job title, relevant place of work and marketing and communication preferences.
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(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business). (c) Consent.
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To administer newsletters, contests, sweepstakes, promotions and surveys. For us to do this, we may collect your first name, surname, postal address, email address, phone number, job title, relevant place of work and marketing and communication preferences.
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To serve you advertisements on selected third party websites that make their advertising space available to us by using retargeting cookies. For us to do this, we may collect your first name, surname, postal address, email address, phone number, technical and usage data, job title, relevant place of work and marketing and communication preferences.
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| To administer, operate and protect our business and our Websites (including but not limited to troubleshooting, data analysis, testing (including processing beta list of customers who assist with testing software developments, system maintenance, support, reporting and hosting of data). For us to do this, we may collect any of the Data we collect from data subjects discussed above. |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation, sale, asset transfer or group restructuring exercise). (b) Necessary to comply with a legal obligation.
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. For us to do this, we may collect your first name, surname, postal address, email address, phone number, technical and usage data, job title, relevant place of work and marketing and communication preferences.
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To use data analytics and perform statistical, demographic and marketing analysis of users and purchasing patterns to improve our Websites, products/services, marketing, customer relationships and experiences. For us to do this, we may collect your technical and usage data and marketing and communication preferences.
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To make suggestions and recommendations to you about services that may be of interest to you. For us to do this, we may collect your first name, surname, postal address, email address, phone number, job title, relevant place of work and marketing and communication preferences.
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(a) Necessary for our legitimate interests (to develop our products/services and grow our business). (b) Consent. |
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To invite you to seminars or events, or send you information about features and enhancements to our Websites, or to tell you about developments at Disguise or in our industry more generally or marketing for services or goods in general. For us to do this, we may collect your first name, surname, postal address, email address, phone number, technical and usage data, job title, relevant place of work and marketing and communication preferences.
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(a) Necessary for our legitimate interests (to develop our products/services and grow our business). (b) Consent. |
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To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal. For us to do this, we may collect any of the Data we collect from data subjects discussed above.
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Necessary to comply with a legal obligation. |
We may use the information from one page of the Websites on other pages of the Websites, and we may combine information gathered from multiple pages of the Websites into a single record. We also may use or combine information that we collect from software or hardware reports, or offline, or from third-party sources for many reasons, including to enhance, expand, and check the accuracy of our records. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
We will only use your 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.
In addition, we may process your Data without your knowledge or consent where this is required or permitted by law.
MARKETING
We may use your Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You may receive marketing communications from us if you have requested information from us or purchased goods or services from us or the Data has been lawfully transferred to us for such purpose and, in each case, you have not opted out of receiving that marketing on the basis that this is within our legitimate interests to do so.
We will get your express opt-in consent before we share your Data with any third party outside of the Disguise Group for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us using the details below at any time.
HOW WE SHARE YOUR INFORMATION WITH OTHERS
We may share your Data with third parties as described below. In addition, we may share information that does not specifically and personally identify you, such as aggregate information, device identifiers or other unique identifiers to third parties.
Internal third parties, meaning other companies within the Disguise Group who act as controllers and/or processors and provide IT and system administration services and undertake leadership reporting.
Third-Party Service Providers: We engage third-party service providers to perform functions on our behalf such as: hosting, marketing, social media integration, and analytics. For example, we use third parties to process payments made to us and assist with product fulfilment and other operations. These third parties may have access to your Data when needed to perform their functions. If we share information with these third parties that personally identifies you, such as your name, address, or phone number, we will require the third parties to maintain the confidentiality and security of your Data, and they will be restricted from using, selling, or distributing such personally identifiable information in any way other than to provide the requested services to the Websites or as otherwise required or expressly permitted by law.
Businesses in the supply chain: including our suppliers, customers and any other person involved to enable us to perform our obligations or related matters pursuant to our business contracts.
Professional advisers: including lawyers, bankers, auditors and insurers who provide, for example, consultancy, banking, legal, insurance and accounting services.
Business Partners: We may share information that personally identifies you with business partners, including our certified sales partners, who provide products and services that we think you may be interested in.
Sale, Assignment or Change of Control: We may change our ownership or corporate organisation from time to time. We may transfer to another entity or its affiliates or service providers and some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, investment (whether equity or debt) or financing transaction. Under such circumstances, we will request the acquiring party to follow the practices described in this Privacy Policy with respect to previously collected information. Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.
Law Enforcement, Legal Process, and Emergency Situations: We may also use or disclose your Data if required to do so by law to (a) conform to applicable law or comply with a legal process served on us; (b) protect and defend our rights, property, products or services, the Websites or our users; and/or (c) act to protect the personal safety of us and other people including but not limited to our customers, suppliers, business partners, users of the Websites or the public.
INTERNATIONAL TRANSFERS
The Data provided by you may be transferred internationally within the Disguise Group in the UK and USA and third parties also based in those jurisdictions for its processing subject to the requirements established by the legislation applicable in each country or region, and to the international agreements, where the different Disguise Group entities operate.
In this regard, the relevant entity within the Disguise Group, either as Data Processor and/or Data Controller, will protect your Data if it is transferred internationally in accordance with the Disguise Group’s security standards and the applicable legislation in this matter.
Whenever we transfer your Data internationally, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Data to countries that have been deemed to provide an adequate level of protection for personal data;
- Whenever we transfer your Data outside of the UK, we endeavour to ensure that the recipient complies with the requirements set out in the UK data protection legislation; and
- Where we use certain third party processors, we may use specific contracts approved for use in the UK which give Data the same protection it has in the UK, for example the international data transfer agreement or the EU’s international data transfer addendum.
We believe that in many situations, such as when we transfer contact details to our sales partners, that this is necessary for the performance of a contract and to ultimately provide you with a high level of services and goods. Otherwise, if we cannot transfer such Data in that way, then our sales partners may be unable to contact and/or deliver services to you.
By submitting your Data to us, you agree to us transferring your personal data to the UK and USA for the purpose of us carrying out our services.
If you are a resident of the UK or EEA, and you do not want your Data to be transferred to or stored outside of the UK or EEA then please do not use our products. By providing your information to us, you agree and consent to us transferring to, and storing your information at, a destination outside the UK or EEA.
DATA RETENTION
We will only retain your Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and in any event for a maximum period of five (5) years. 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 Data, we consider the amount, nature, and sensitivity of the Data, the potential risk of harm from unauthorised use or disclosure of your Data, the purposes for which we process your Data and whether we can achieve those purposes through other means and the applicable legal requirements.
For more details of our specific retention periods, please contact our Data Privacy Manager.
HOW TO ACCESS AND MODIFY YOUR INFORMATION
If you have an online account with us, you can update your account information through your account.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during your relationship with us.
CHOICES ABOUT HOW YOUR INFORMATION IS USED AND SHARED
Further to the rights you have set out above, we will follow the option(s) you select when you are asked to register or fill in a form on our Websites regarding how your contact information is used and shared.
While you cannot opt-out of receiving notifications and other communications regarding your account or your transactions, you can opt-out of receiving promotional and other marketing emails from us by: (1) using the “unsubscribe” feature in our marketing e-mails or (2) contacting the Data Privacy Manager on the contact details above.
CONTACT US
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your legal rights are as follows:
- Request access to your Data (commonly known as a data subject access request). This enables you to receive a copy of the Data we hold about you and to check that we are lawfully processing it;
- Request correction of the Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected;
- Request erasure of your Data. This enables you to ask us to delete or remove Data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Data where you have successfully exercised your right to object to processing (see below);
- Object to processing of your 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 Data for direct marketing purposes;
- Request restriction of processing of your Data. This enables you to ask us to suspend the processing of your Data in certain circumstances, for example if you want us to establish its accuracy or the reason for processing it;
- Request the transfer of your Data to you or to a third party; and
- Withdraw consent at any time where we are relying on consent to process your Data, although this may mean we are unable to provide certain benefits or assistance to you.
If you wish to exercise your data protection rights, please contact us in the following ways:
- Address: Data Privacy Manager, Disguise Systems Limited, 88-89 Blackfriars Road, London, United Kingdom, SE1 8HA
- Telephone Number: +44 (0)20 7234 9840
- Email address: marketing@disguise.one
You also 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.
OTHER IMPORTANT INFORMATION
Minors: Our Websites are intended for users ages 13 and older only. Accordingly, we will not knowingly collect or use any Data from children that we know to be under the age of 13. If we become aware of Data in our database that was collected from a child under the age of 13, we will delete such information.
Your California Privacy Rights: If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us and our related companies to third parties for the third parties' direct marketing purposes. To make such a request, please send your request, by mail or email, to:
- Address: Data Protection Officer, Disguise Systems Inc., 421 COLYTON ST., BUILDING 1, LOS ANGELES CA 90013, United States
- Email address: marketing@disguise.one