This Privacy & Data Protection Policy explains how Chirple Limited trading as Direct Affinity CX (“DACX”, “we”, “us”, “our”) collects, uses, stores, shares and protects personal data when you visit our website, engage with our marketing campaigns, or otherwise interact with us.
This policy is designed to support references in campaign documentation and to align with our role as a Data Processor under client Data Processing Agreements, and where applicable, as a Data Controller for our own business activities.
Legal entity: Chirple Limited t/a Direct Affinity CX
Company number: 11138788 (England & Wales)
Registered office: Dufton & Kellner, Barnston House, Wirral, England, CH60 0EE
For the purposes of UK data protection law, DACX may act either as:
We process personal data in accordance with:
Depending on how you interact with us, we may collect and process the following categories of personal data:
When we act as a Data Processor, the categories of personal data processed are determined by our clients and described in the relevant services agreement and data processing agreement.
We use personal data only where permitted by law. This may include using personal data to:
Where we act as a Data Processor, we process personal data strictly in accordance with our clients’ documented instructions and for no other purpose.
Where DACX acts as a Data Controller, our lawful bases for processing personal data may include:
We do not sell personal data.
We may share personal data:
As Data Processor we may appoint one or more of the following Sub-Processors whilst carrying out the services:
Any third parties processing personal data on our behalf are required to maintain appropriate security and confidentiality obligations.
We do not transfer personal data outside the UK or the European Economic Area (EEA) unless appropriate safeguards are in place, such as:
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure. These measures are proportionate to the nature of the data and the risks involved and include access controls, staff training and secure systems.
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting or reporting requirements.
Where we act as a Data Processor, personal data is retained and deleted in accordance with our contractual obligations and client instructions.
Under UK data protection law, you have rights including:
If DACX is acting as a Data Processor, requests relating to these rights should be directed to the relevant Data Controller (our client). We will support them as required.
Our website may use cookies and similar technologies to improve functionality and user experience.
We have procedures in place to detect, report and investigate personal data breaches. Where legally required, breaches will be reported to the Information Commissioner’s Office (ICO) and affected individuals.
If you have any questions about this policy or how we handle personal data, please contact:
Email: info@directaffinityeurope.com
Post: Data Protection Enquiries, Chirple Limited, Dufton & Kellner, Barnston House, Wirral, England, CH60 0EE
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
We may update this policy from time to time. Any changes will be published on this page, with the updated revision date shown above.
Last updated: January 26th, 2026
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