PRIVACY AND GDPR POLICY
BACKGROUND:
KS7
London Limited understands that your privacy is important to you and that you
care about how your personal data is used. We respect and value the privacy of everyone who visits this website,
https://www.KS7.co.uk (“Our Site”) and will only collect and use personal data in ways that are
described here, and in a way that is consistent with [our] OR [my] obligations and your rights under the
law.
Please
read this Privacy and GDPR Policy carefully and ensure that you understand it. Your
acceptance of Our Privacy and GDPR Policy is deemed to occur if you continue
using Our Site. If you do not agree to Our Cookie Policy, please stop using Our
Site immediately.
1.
Definitions and Interpretation
In this Policy the following terms shall have
the following meanings:
|
“Account” |
means an account required to access and/or use
certain areas and features of Our Site; |
|
“Cookie” |
means a small text file placed on your computer
or device by Our Site when you
visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and |
|
“Cookie Law” |
means the relevant parts of the Privacy and
Electronic Communications (EC Directive) Regulations 2003;] |
2.
Information
About [Us] OR [Me]
Our Site
is owned and operated by KS7 London Limited, a limited company registered in England under company number 12124764.
Registered address: 5 Braemore Court, Cockfosters Road, Barnet, England, EN4 0AE, UK.
Data Protection Officer: Kunwar Sood.
Email address: info@ks7.co.uk
Telephone number:
+44 (0) 20 .3129 8742
We are
a member of Information Commissioner’s Office
3.
What
Does This Policy Cover?
This
Privacy Policy applies only to your use of Our Site. Our Site may
contain links to other websites. Please note that we have no control over how your data is collected, stored, or used
by other websites and we advise you
to check the privacy policies of any such websites before providing any data to
them.
4.
What Is Personal Data?
Personal data is defined by the General Data
Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data
Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any
information relating to an identifiable person who can be directly or
indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any
information about you that enables you to be identified. Personal data covers
obvious information such as your name and contact details, but it also covers
less obvious information such as identification numbers, electronic location
data, and other online identifiers.
5.
What
Are My Rights?
Under the Data Protection Legislation, you
have the following rights, which we will
always work to uphold:
a)
The right to be informed about our
collection and use of your personal data. This Privacy Policy should tell you
everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part
15.
b)
The right to access the
personal data we hold about you.
Part 13 will tell you how to do this.
c)
The right to have your personal
data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details
in Part 15 to find out more.
d)
The right to be forgotten, i.e.
the right to ask us to delete or
otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out
more.
e)
The right to restrict (i.e. prevent)
the processing of your personal data.
f)
The right to object to us using your personal data for a
particular purpose or purposes.
g)
The right to withdraw consent.
This means that, if we are relying
on your consent as the legal basis for using your personal data, you are free
to withdraw that consent at any time.
h)
The right to data portability.
This means that, if you have provided personal data to us directly, we are using it
with your consent or for the performance of a contract, and that data is
processed using automated means, you can ask us for a copy of that personal data to re-use with another service or
business in many cases.
i)
Rights relating to automated decision-making
and profiling. We do not use your
personal data in this way.
For more information about our use of your personal data or
exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is
kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us
informed as long as we have that
data.
Further information about your rights can
also be obtained from the Information Commissioner’s Office or your local
Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have
the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to
resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6.
What Data Do You Collect and
How?
Depending upon your use of Our Site, we may collect and hold some or all of
the personal and non-personal data. Please
also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy <<insert link>>]. We do not collect any ‘special category’ or ‘sensitive’ personal data AND/OR personal data relating to
children AND/OR data relating to
criminal convictions and/or offences.
7.
How Do You Use My Personal Data?
Under the Data Protection Legislation, we
must always have a lawful basis for using personal data.
With your permission and/or where permitted
by law, we may also use your
personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message with
information, news, and offers on our services.
You will not be sent any unlawful marketing or spam. We will always work to
fully protect your rights and comply with
our obligations under the Data Protection Legislation and the Privacy and Electronic
Communications (EC Directive) Regulations 2003, and you will always have the
opportunity to opt-out. We
will always obtain your express opt-in consent before sharing your personal
data with third parties for marketing purposes and you will be able to opt-out
at any time.
Any Third Parties whose content appears on Our
Site may use third-party Cookies, as detailed below in Part 14. Please refer to
Part 14 for more information on controlling cookies. Please note that we do not control the activities of such
third parties, nor the data that they collect and use themselves, and we advise you to check the privacy
policies of any such third parties.
If at any point you wish to query any action
that we take on the basis of this or
wish to request ‘human intervention’ (i.e. have someone review the action
themselves, rather than relying only on the automated method), the Data
Protection Legislation gives you the right to do so. Please contact us to find out more using the details in
Part 15.
We will only use your personal data for
the purpose(s) for which it was originally collected unless we reasonably believe that another
purpose is compatible with that or those original purpose(s) and need to use
your personal data for that purpose. If we
do use your personal data in this way and you wish us me to explain how the new purpose is compatible with the original,
please contact us me using the
details in Part 15.
If we need to use your personal data for a
purpose that is unrelated to, or incompatible with, the purpose(s) for which it
was originally collected, we will
inform you and explain the legal basis which allows us to do so.
In some
circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent.
This will only be done within the bounds of the Data Protection Legislation and
your legal rights.
8.
How Long Will You Keep My
Personal Data?
We will
not keep your personal data for any longer than is necessary in light of the
reason(s) for which it was first collected.
9.
How and Where Do You Store or
Transfer My Personal Data?
We will
store or transfer some of your personal data within the UK. This means that it
will be fully protected under the Data Protection Legislation.
AND/OR
We store
or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and
Liechtenstein. This means that your personal data will be fully protected under
the Data Protection Legislation, GDPR, and/or to equivalent standards by law.]
AND/OR
We store or transfer some or all of your
personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
These are known as “third countries” and may not have data protection laws that
are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to
ensure that your personal data is treated just as safely and securely as it would
be within the UK and under the Data Protection Legislation as follows:
10.
Do You Share My Personal Data?
In some
limited circumstances, we may be legally required to share certain personal
data, which might include yours, if we are
involved in legal proceedings or complying with legal obligations, a court
order, or the instructions of a government authority.
If any of
your personal data is shared with a third party, as described above, we will take steps to ensure that your
personal data is handled safely, securely, and in accordance with your rights, our
obligations, and the third party’s obligations under the law, as described above
in Part 9.
If any
personal data is transferred outside of the EEA, we will take suitable steps in
order to ensure that your personal data is treated just as safely and securely
as it would be within the UK and under the Data Protection Legislation, as explained
above in Part 9.
In some
limited circumstances, we may be legally required to share certain personal
data, which might include yours, if we are
involved in legal proceedings or complying with legal obligations, a court
order, or the instructions of a government authority.]
11.
How Can I Control My Personal Data?
11.1
In addition to your rights
under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site,
you may be given options to restrict our
use of your personal data. In particular, we aim to give you strong controls on our use of your data
for direct marketing purposes (including the ability to opt-out of receiving
emails from us which you may do by
unsubscribing using the links provided in our emails OR at the point
of providing your details).
11.2
You may also wish to sign up to
one or more of the preference services operating in the UK: The Telephone
Preference Service (“the CTPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the CTPS”). These may help to
prevent you receiving unsolicited marketing. Please note, however, that these
services will not prevent you from receiving marketing communications that you
have consented to receiving.
12.
Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use
all features and functions available on Our Site you may be required to submit
or allow for the collection of certain data.]
You may restrict our use of Cookies. For more
information, see Part 14 and our Cookie
Policy <<Insert Link>>.
13.
How
Can I Access My Personal Data?
If you want to know what personal data we
have about you, you can ask us for
details of that personal data and for a copy of it (where any such personal
data is held). This is known as a subject access request”.
All subject access requests should be made in
writing and sent to the email addresses shown in Part 15.
There is not normally any charge for a
subject access request. If your request is ‘manifestly unfounded or excessive’
(for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will
respond to your subject access request within 72-hours and, in any case, not
more than one month of receiving it. Normally, we aim to provide a complete
response, including a copy of your personal data within that time. In some
cases, however, particularly if your request is more complex, more time may be
required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14.
How Do You Use Cookies?
14.1
Our Site may place and access
certain first party Cookies on your computer or device. First party Cookies are
those placed directly by Us and are used only by Us. We use Cookies to
facilitate and improve your experience of Our Site and to provide and improve
Our services. We have carefully chosen these Cookies and have taken steps to
ensure that your privacy and personal data is protected and respected at all
times.
14.2
By using Our Site, you may also
receive certain third party Cookies on your computer or device. Third party Cookies
are those placed by websites, services, and/or parties other than Us. Third
party Cookies are used on Our Site for Google Analytics Cookies to collect
information about how visitors use this site. For more details, please refer to
section 4 below.
14.3
All Cookies used by and on Our
Site are used in accordance with current Cookie Law. We may use some or all of
the following types of Cookie:
14.3.1 Strictly Necessary Cookies
A Cookie falls into this category if it is
essential to the operation of Our Site, supporting functions such as logging
in, your shopping basket, and payment transactions.
14.3.2 Analytics Cookies
It is important for Us to understand how you
use Our Site, for example, how efficiently you are able to navigate around it,
and what features you use. Analytics Cookies enable us to gather this
information, helping Us to improve Our Site and your experience of it.
14.3.3 Functionality Cookies
Functionality Cookies enable Us to provide
additional functions to you on Our Site such as personalisation and remembering
your saved preferences. Some functionality Cookies may also be strictly
necessary Cookies, but not all necessarily fall into that category.
14.3.4 Targeting Cookies
It is important for Us to know when and how
often you visit Our Site, and which parts of it you have used (including which
pages you have visited and which links you have visited). As with analytics
Cookies, this information helps us to better understand you and, in turn, to
make Our Site and advertising more relevant to your interests. Some information
gathered by targeting Cookies may also be shared with third parties.
14.3.5 Third Party Cookies
Third party Cookies are not placed by Us;
instead, they are placed by third parties that provide services to Us and/or to
you. Third party Cookies may be used by advertising services to serve up
tailored advertising to you on Our Site, or by third parties providing
analytics services to Us (these Cookies will work in the same way as analytics
Cookies described above).
14.3.6 Persistent Cookies
Any of the above types of Cookie may be a
persistent Cookie. Persistent Cookies are those which remain on your computer
or device for a predetermined period and are activated each time you visit Our
Site.
14.3.7 Session Cookies
Any of the above types of Cookie may be a
session Cookie. Session Cookies are temporary and only remain on your computer
or device from the point at which you visit Our Site until you close your
browser. Session Cookies are deleted when you close your browser.
14.4
For more details of the
personal data that We collect and use, the measures we have in place to protect
personal data, your legal rights, and our legal obligations, please refer to
our Privacy Policy <<https://www.ks7.co.uk/privacy.html>>.
15.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection,
including to make a subject access request, please use the following details:
Email address: info@ks7.co.uk
Telephone number: +44 (0) 20 3129 8742.
16.
Changes
to this Privacy Policy
We may
change this Privacy Notice from time to time. This may be necessary, for example,
if the law changes, or if we change our business in a way that affects
personal data protection.
Any changes
will be immediately posted on Our Site and you will be deemed to have accepted
the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly
to keep up-to-date. This Privacy Policy was last updated on <<insert date>>.