Data Policy

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.

1. Who We Are

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:

  • a Data Controller (for example, when processing data relating to our website visitors, prospects, suppliers, and employees); or
  • a Data Processor (when processing personal data on behalf of our clients under a services agreement).

2. Data Protection Law

We process personal data in accordance with:

  • the UK General Data Protection Regulation (UK GDPR);
  • the Data Protection Act 2018; and
  • the Privacy and Electronic Communications Regulations 2003 (PECR), where applicable;
  • the UK International Data Transfer Agreement (IDTA).

3. Personal Data We May Collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

  • Identity data (e.g. name, job title, company name);
  • Contact data (e.g. email address, telephone number, postal address);
  • Website and technical data (e.g. IP address, browser type, device information, pages visited);
  • Marketing and communications data (e.g. preferences for receiving marketing);
  • Any other personal data you voluntarily provide to us via forms, email, or other communications.


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.

4. How We Use Personal Data

We use personal data only where permitted by law. This may include using personal data to:

  • operate and maintain our website;
  • respond to enquiries and requests;
  • provide information about our services;
  • manage client and supplier relationships;
  • carry out marketing and business development activities;
  • comply with legal, regulatory, and contractual obligations.


Where we act as a Data Processor, we process personal data strictly in accordance with our clients’ documented instructions and for no other purpose.

5. Lawful Bases for Processing

Where DACX acts as a Data Controller, our lawful bases for processing personal data may include:

  • consent;
  • performance of a contract;
  • compliance with a legal obligation; and/or
  • legitimate interests, where those interests are not overridden by your rights and freedoms.

6. Data Sharing

We do not sell personal data.

We may share personal data:

  • with trusted third-party service providers who support our business operations (subject to appropriate safeguards);
  • where required by law, regulation, or a competent authority;
  • with clients where we are acting as a Data Processor on their behalf;
  • with sub-processors


As Data Processor we may appoint one or more of the following Sub-Processors whilst carrying out the services:

  • Direct Affinity Europe SL- Business NIF No. B76711258- Address- Avda. Antonio Dominguez 5 Planta 4 Oficina´s 9&10 Zentral Commercial Arona 38660 Santa Cruz de Tenerife
  • Finance Renewals Limited T/A Prospecting Dynamics- Registration Number- 08493600- Address- 1 Fairfield Street, Bingham, Nottingham, NG13 8FB
  • ELS Customer Experience (Pty) Ltd- Registration Number 2012/097419/07- Address- 109 Sunny Road, Lakefield, Benoni, 1501


Any third parties processing personal data on our behalf are required to maintain appropriate security and confidentiality obligations.

7. International Transfers

We do not transfer personal data outside the UK or the European Economic Area (EEA) unless appropriate safeguards are in place, such as:

  • the UK International Data Transfer Agreement (IDTA); or
  • other approved transfer mechanisms in accordance with UK GDPR.

8. Data Security

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.

9. Data Retention

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.

10. Your Rights

Under UK data protection law, you have rights including:

  • the right to access your personal data;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object to processing;
  • the right to withdraw consent at any time (where processing is based on consent).


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.

11. Cookies

Our website may use cookies and similar technologies to improve functionality and user experience.

12. Personal Data Breaches

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.

13. Contact Us

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).

14. Changes to This Policy

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