Privacy Policy

D-COM (“Company,” “we,” “us,” or “our”) is an execution consultancy. We take ownership of high-stakes business initiatives and deliver them alongside our clients, including work involving AI and automation. This Privacy Policy explains how we collect, use, disclose, and safeguard information in connection with our website at d-com.ai (the “Site”) and the services we provide to clients (the “Services”).

We do not operate a self-service platform, and there is no account to create on the Site. Most information we hold comes from people who contact us and from clients who engage us. If you do not agree with this policy, please do not use the Site or send us information.

1.Information we collect

Information you provide directly

Contact and enquiry information: your name, email address, organization, role, and anything else you choose to include when you email us or otherwise get in touch.
Engagement information: contact details, billing information, and correspondence relating to a prospective or active engagement.

Information we receive during an engagement

Client Materials: business data, documents, systems access, and other materials a client provides so that we can perform the Services. These may contain personal information about the client’s employees, customers, or other individuals.
Work product: the analyses, plans, models, code, and other Deliverables we produce, together with the working notes and records associated with them.

Where we handle personal information contained in Client Materials, we do so on the client’s behalf and on their instructions. Under GDPR terminology, the client is the controller of that information and we act as a processor. Individuals whose information appears in Client Materials should direct requests to the relevant client; we will assist that client in responding.

Information collected automatically

Server logs: our web hosting provider records standard technical information such as IP address, browser type, operating system, requested pages, and timestamps. We use this for security and to keep the Site running.
Cookies: see Section 7 below.

2.How we use information

We use the information we collect to:

Respond to enquiries and communicate with you about a prospective or active engagement.
Perform, manage, and improve the Services, including producing Deliverables.
Issue invoices and process payments.
Operate, secure, and maintain the Site.
Detect, investigate, and prevent fraudulent, unauthorized, or illegal activity, and enforce our Terms of Service.
Send administrative communications and, where you have asked for them or applicable law permits, occasional updates about our work. You can opt out of these at any time.
Comply with legal, regulatory, and professional obligations.

3.AI tools and your information

We use AI and automation tools, including third-party models, in delivering the Services. This section explains what that means for your information.

We do not use Client Materials, or the content of your communications with us, to train AI models — ours or anyone else’s — except with the client’s express written permission.
Where we use third-party AI providers to process information on our behalf, we select providers whose terms prevent them from using that data to train their own models, and we configure their services accordingly. We tell clients which tools an engagement relies on when they ask.
An engagement agreement may set additional or stricter data handling requirements. Where it does, those requirements control.
Systems we build and deploy for a client are operated under that client’s own policies and agreements once handed over, not this one.

4.How we share information

We do not sell your personal information. We may share information with:

Service providers: vendors who perform functions on our behalf, such as cloud hosting, email, document storage, accounting, and payment processing, bound by confidentiality and data protection obligations.
AI and technology providers: third parties whose models, software, or infrastructure we use to deliver the Services, on the terms described in Section 3.
Partners and subcontractors: where an engagement agreement permits us to staff the work with a partner firm or subcontractor, and subject to equivalent confidentiality obligations.
Professional advisers: our lawyers, accountants, insurers, and auditors, where necessary and subject to professional duties of confidence.
Legal requirements: when required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of the Company, our clients, or others.
Business transfers: in connection with a merger, acquisition, or sale of assets, subject to this policy continuing to apply.
With your consent: in any other circumstance, with your explicit consent.

5.Data retention

We retain personal information for as long as necessary to provide the Services, comply with legal, tax, and professional obligations, resolve disputes, and enforce agreements.

Client Materials are retained for the period set out in the applicable engagement agreement. Where none is specified, we return or delete them on the client’s written request, subject to any copies we are required to keep by law or that persist in routine backups until those backups expire. You may request deletion of your own personal information as described in Section 8.

6.Data security

We implement administrative, technical, and physical safeguards designed to protect information, including encryption in transit and at rest, access controls limited to personnel who need the information to do their work, and periodic review of our practices. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security. Please do not send sensitive information to us by unencrypted email; we will arrange a secure channel on request.

7.Cookies and tracking technologies

The Site does not set advertising or analytics cookies and does not use third-party tracking or advertising technologies. Our hosting provider may set cookies that are strictly necessary to serve and secure the Site. If we introduce analytics or other non-essential cookies in future, we will update this policy and provide any consent mechanism required in your jurisdiction.

8.Your privacy rights

Depending on your location, you may have the right to:

Access the personal information we hold about you.
Correct inaccurate or incomplete information.
Delete your personal information (“right to be forgotten”).
Restrict or object to certain processing.
Port your data to another provider.
Withdraw consent where processing is based on consent.
Opt out of sale or sharing of personal information. We do not sell or share personal information, so there is nothing to opt out of at present.

To exercise these rights, contact us at hello@d-com.ai. We may need to verify your identity before fulfilling a request, and we will respond within the period required by applicable law. If your information reached us inside a client’s materials, we will refer your request to that client, who is responsible for deciding how to respond.

California (CCPA/CPRA): California residents have the rights described above and the right not to be discriminated against for exercising them. We do not sell personal information or share it for cross-context behavioral advertising.

9.International data transfers

We are based in the United States. If you are located elsewhere, your information may be transferred to and processed in the United States or in other countries where our service providers operate, which may have different data protection laws. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses to protect transferred data.

10.Third-party links

The Site links to the websites of our partners and to other third-party sites. We are not responsible for the privacy practices of those third parties, and this policy does not apply to them. We encourage you to review their privacy policies.

11.Automated decision-making

We do not make decisions producing legal or similarly significant effects about individuals through solely automated means. Our Deliverables may include AI-generated analysis and recommendations, and are reviewed by our personnel before delivery. Decisions to act on our recommendations are made by the client. We strongly recommend consulting a legal, taxation, or other licensed professional before implementing recommendations that carry regulatory, financial, or employment consequences.

12.Children

The Site and the Services are directed to businesses and are not intended for children. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, contact us and we will delete it.

13.Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy with a new “Last Updated” date, and, where required by law, through additional notice.

14.Contact us

If you have questions or concerns about this Privacy Policy or our data practices, contact us at hello@d-com.ai.

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