PRIVACY POLICY

Who we are?

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Kay Services (UK) Ltd collects and processes your personal data through all means from when you initially contact us to cease being a customer. This includes but not limited to when you request a quotation /proposal from us, become a Kay Services client or cease to become our client. This also includes the use of this website and any data you may provide when you sign up for e.g. to our newsletter or download a guide or take part in a promotion.

This website is not intended or designed to attract children. We do not knowingly collect personally identifiable data from or about any children. If you are a child and wish to ask a question or use this site in any way, which requires you to submit your personal information, please request your parent or guardian to do so on your behalf.

CONTROLLER

Kay Services (UK) Ltd is the controller and responsible for your personal data (collectively referred to as Kay Services (UK) Ltd, ”COMPANY”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

To Kay Services Data Controller

Kay Services (UK) Ltd
27 Old Gloucester Street
London
WC1N 3AX

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.

This privacy policy was last updated on 10-Jun-2024

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.

THIRD PARTY WEBSITE LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of all other websites you visit.

Types of Personal Data We Collect About You

Personal data or personal information means any information relating to an identified or identifiable natural person from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data may include first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data may include invoicing address, email address and telephone numbers.
• Financial Data may include bank account and payment card details.
• Transaction Data may include details about payments to and from you and other details of services you have purchased from us.
• Technical Data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data may include purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Marketing and Communications Data include your preferences in receiving marketing from us and our third parties and your communication preferences.

In order to personalise and improve the quality of our services, when you instruct us to provide personal services we may also ask you about the nature of your business or personal circumstances and how you found us in order that we might gain a clearer understanding of who you are. However, you do not need to provide this information in order for us to provide services to you.

We 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.

IF YOU DO NOT PROVIDE 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 some or all services). In this case, we may have to cancel a service you have with us but will notify you if this is the case at the time.

How Do We Collect Your Personal Information?

These are the main ways we collect your information:

• Engagement Of Our Services - You may give us your Identity, Contact and Financial Data when engaging our services, filling in online forms or by corresponding with us by post, phone, email, and telephone or other electronic medium.
• If you buy a product or service directly from us (e.g. purchase one of our website packages).
• If you reply to our direct marketing campaigns (e.g. filling out our website form).
• Subscribe to our newsletter
• Give feedback.
• Technical interaction - 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. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties.
• Technical Data – we collect this from the following parties: (a) analytics providers, (b) advertising networks (c) search information providers.

How Your Personal Information is used?

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending 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.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will request your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

ACCESS REQUEST

You have the right to request a copy of the personal data that we hold about you at any time. Please note that in most circumstances, we will not make a charge for this, however, this is entirely at our own discretion and we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, 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.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may have to share your personal data with the parties set out below for the purposes outlined in the table above.

• External Third Parties such as service providers acting as processors based within or outside of the EEA who provide services that support our services supplied to you, HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
• Specific third parties listed in the table above.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or mergewith them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and permit them only to process your personal data for specified purposes and in accordance with our instructions.

International Transmission

From time to time and as the business requires we employ under suitable safeguards both technical & legal the services of external third parties and sub-contractors based outside the European Economic Area (EEA) who may be involved in the processing of your personal data. We deal with 3rd parties globally and for specific information please contact us

Personal Information Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have in place procedures to deal with any suspected personal data breach and will notify you if affected and any applicable regulator within 72 hourswhich we are legally required to do so.

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. We also use a secure server hosting location, Firewall protection, controlled access and encryption technology to protect your data. While no system is completely fool proof, we take the security of your personal information very seriously, and our security measures are designed to protect that information in a responsible manner.

How Long We Keep Your Personal Information For?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: See below “ Your Rights…”for further information.

In some circumstances we may 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.

Your Rights Under GDPR

You as an individual have rights as follows:

• The right to be informed about processing of your personal data
• The right to have your personal data corrected in case of inaccuracy and to have incomplete personal information completed.
• The right to object to processing to processing of your personal data
• The right to restrict processing of your personal data
• The right to erasure of your personal data
• The right to request access to your personal data and information about how we process it.
• The right to move your personal data (Data Portability)
• The right to withdraw consent.
• If you wish to exercise any of the rights set out above, please contact us.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.