Purpose of this Privacy Notice
This privacy notice provides information, for the purposes of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as it forms part of domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 (the “UK GDPR”), the UK Data Protection Act 2018 (the “DPA”) and other applicable national data protection laws, concerning how Kolleno processes and protects your personal data that we may receive as part of your interactions with Kolleno.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
Kolleno Limited is the controller and responsible for your personal data (collectively referred to as “Kolleno“, “we“, “us” or “our” in this privacy notice).
We collect a certain amount of personal data about you, which may include your name, email address, telephone number, website tracking information and information you provide us in the Contact Us form.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Purposes for processing your personal data
We may process your personal data as follows:
• communicate with you and respond to your enquiries;
• send you promotional and marketing materials, newsletters or other related communications (including making suggestions and recommendations to you about services that may be of interest to you);
• conduct research, analysis and website tracking to improve the quality of our marketing and the experience of and relationships with our customers;
• communicate with you about operational changes to our products, services and website, such as changing this privacy notice;
• comply with our legal obligations and to exercise our legal rights;
• administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
• detect, investigate, report, and seek to prevent financial crime and to manage risk for us and our customers;
• develop, manage and improve our products, services and the website (including conducting research and analysis) and to test new products, services, and features of the website;
• run our business in an efficient and proper way, including in respect of our financial position, business capability, corporate governance, audit, strategic planning and communications;
• monitor and/or record your communications with us for quality control, training and security purposes; and
• exercise our rights in agreements and contracts to which we are a party.
What is the legal basis of the processing?
When we process your personal data, we may rely on:
• Performance of a contract: to the extent such processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into any such contract.
• Legitimate interests: to the extent such processing is necessary for the purposes of the legitimate interests we pursue to the extent we have concluded that our processing is not overridden by your interests or fundamental rights or freedoms that require the protection of personal data. Examples of this might include website tracking and marketing or advertising.
• Consent: where we have obtained your consent to the relevant processing activity. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can change your marketing preferences at any time by clicking on the unsubscribe option at the bottom of our marketing emails. We will endeavour to give effect to your preference changes as soon as possible but please note that it can sometimes take up to 7 days for a change to become effective due to the way in which our systems are configured.
Who will your personal data be shared with?
We may share your personal data with any third parties that help us provide services, with legal or other professional advisors.
Any such transfers will be in compliance with our obligations as a controller under the UK GDPR, the DPA and other applicable national data protection laws. Some of these persons may process your personal data in accordance with our instructions and others will themselves be responsible for their use of your personal data.
We do not transfer your personal data of the UK.
We will never sell your personal data and in all cases, Kolleno will ensure that your personal data is only disclosed for the purposes set out above and in compliance with applicable data protection laws.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of compliance 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 personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:
• the right to know what personal data we process and a right of access to such personal data;
• the right to request any incomplete or inaccurate personal data to be corrected;
• the right to object to our processing of your personal data;
• the right to require us to delete your personal data in some limited circumstances;
• the right to object to our processing of some or all of your personal data on grounds relating to your particular situation which are based on legitimate interests, at any time (and require such personal data to be deleted). If you object, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for such processing which override your interests, rights and freedoms or where it is necessary for the establishment, exercise or defence of legal claims; and
• a “data portability” right to require us to transfer your personal data to you or to a new service provider in a structured, commonly used and machine-readable format.
If you wish to exercise any of the rights referred to above, please contact us using the details set out under “Contact details” below.
If you have any questions about this privacy notice, please email us at email@example.com .
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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We use the following cookies:
• Strictly Necessary Cookies: These are cookies that are required for the operation of our website and include, for example, cookies that enable you to log into secure areas.
• Performance Cookies: These allow us to recognise and count the number of visitors and traffic sources so we can measure and improve the performance of our website.
• Functionality Cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
• Targeting Cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed to make our site and marketing more relevant to your interests.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.