PLEASE READ CAREFULLY
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We respect your right to privacy and will only process personal information you in accordance with the Data Protection Legislation which for the purposes of this policy shall mean: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 and other applicable privacy laws. Here are the details that Data Protection Legislation says we have to give you as a ‘data controller’:
We take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
When you use or contact our Website, you do so at your own discretion and provide any such personal details requested at your own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed below. Every effort has been made to ensure a safe and secure form to email submission process but we advise users using such form that you do so at your own risk.
As the party responsible for data processing we ensure that the processed data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.
If you fail to provide your personal data
If you choose not to provide the personal information we request, you can still visit most areas of the Website. You have the final decision on whether to proceed with any activity that requests personal information.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
In addition to the above, we may use the information in the following ways:
Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We shall contract with third parties to supply services to you on our behalf. These include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
We currently contract with:
CONTACT / MARKETING:
FINANCE & TRANSACTION:
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If you are already our customer, we will only contact you electronically about things similar to those Services previously sold to you.
If you are a new customer, you will only be contacted if you agree to it.
We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.
We will only use your personal data when the law allows us to. Most commonly, We will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to us and you can let us know at any time by contacting us at [Email Address], and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you
As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email AND/OR telephone with information, news and offers on our Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
We implement a variety of security measures to protect and maintain the safety of your personal information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. When you place orders or access your personal information, we offer the use of a secure server.
We may contract with third-party service providers to assist us in better understanding our Website visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business as authorised by us.
9. Do we disclose the information we collect to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. The term “outside parties” does not include Kalm HPF Ltd. It also does not include our website hosting partners, business partners, suppliers, subcontractors and other third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
We contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of solutions or additional services, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We are also allowed to disclose your information in the following cases:
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
We only keep your data for as long as we need to in order to use it, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see the European Commission: EU-US Privacy Shield
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website.
We have implemented security measures such as a firewall to protect any data and maintain a high level of security.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
If we give you a password upon registration on our Website, you must keep it confidential. Please don’t share it.
We will only use your personal data for the purposes for which we collected it and to enable us to carry out our business with you, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
When you submit information to us, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
Under the GDPR, you have the right to:
You also have rights with respect to automated decision-making and profiling as set out in section 14 below.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We also collect some non-personally identifiable information (ourselves or using third party services) using web analytic tools. We use third-party services that use tracking technologies to capture aggregate usage and volume statistics about interactions on our Website and Services.
14. Automated Decision-making tools
In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
The right described in in this section does not apply in the following circumstances:
Where we use your personal data for profiling purposes, the following shall apply:
Although this Website only looks to include quality, safe and relevant external links, you are advised adopt a policy of caution before clicking any external web links mentioned throughout this Website (if any). (External links are clickable text / banner / image links to other websites).
We cannot guarantee or verify the contents of any externally linked website despite their best efforts. You should therefore be aware that when you click on external links, you do so at your own risk and we shall not be liable for any damages or implications caused by visiting any external links mentioned.
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
You are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to your own privacy and personal details. This Website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by email.
This Website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons, that you do so at your own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
We may share web links through our social media platform accounts to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] (this is an example: http://bit.ly/zyVUBo).
You are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published, many social media platforms are prone to spam and hacking and therefore we cannot be held liable for any damages or implications caused by visiting any shortened links.
18. Questions and feedback
We welcome your questions, comments, and concerns about privacy. Please send us any and all feedback pertaining to privacy, or any other issue at [email protected]
19. Terms and Conditions
Please also visit our Terms and Conditions establishing the use, disclaimers, and limitations of liability governing the use of our Website.
20. Your consent
If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.