Kura (CS) Limited (“Kura“, “we” or “us“) respects the privacy of every individual who visits our Website (as defined below) and is committed to protecting and respecting your personal data.
- how we collect and use your data;
- how we look after your personal data; and
- your legal rights relating to your personal data.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
IMPORTANT INFORMATION AND WHO WE ARE
Our Website is not intended for children and we do not knowingly collect personal data relating to children.
Kura (CS) Limited, registered in Scotland (company registration SC476104) is the data controller and is responsible for your personal data.
Title of DPO: Director of People and Culture
Email address: email@example.com
Postal address: Kura (CS) Limited, Citypoint, 21 Tyndrum Street, Glasgow, G4 0JY
Telephone number: 0141 272 1599
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 version was last updated on 25th May 2018 and historic versions can be obtained by contacting us.
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.
THE DATA WE COLLECT ABOUT YOU
Personal data means details which identify you or could be used to identify you such as your name and contact details. It does not include data where the identity of a person has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, employer, job title and place of work.
- Contact Data includes email address and telephone number.
- Technical Data includes the display properties of your computer, internet protocol (IP) address and your 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 our Website.
- Usage Data includes information about how you use our Website and information about your visit including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products you viewed and searched for, page response times, download errors, length of visit of certain pages, page interaction information (such as scrolling, clicks and mouse-overs, methods used to browse away from the page, the content of any forms that you complete on our website and any phone number used to call our customer services number.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
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 other than where this is done as part of our recruitment or employment processes with prior consent.
HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect personal data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Profile Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make use of our Website;
- participate in social media functions which may be available on our Website;
- participate in competitions, promotions or surveys; or
- contact or correspond with us by phone, email or otherwise.
- Third parties. We may receive personal data about you from various third parties as set out below:
- from third parties who have hosted an event sponsored by us that you have attended.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
- to answer any questions you may raise or respond to any comments you may send us;
- 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; and
- 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 post. You have the right to withdraw consent to marketing at any time by contacting us.
You can find out more about these legal bases here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/#ib3.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data.
- Providing services to our clients. We may process personal data to carry out our obligations arising from any contracts entered into between us and our clients (or proposed to be entered into) and to provide our clients with the information and services that they request from us. Legal basis: such processing is necessary for our legitimate interest (where we need to process personal data to provide services to our clients we ask our clients to provide the necessary information to the data subjects regarding its use).
- Respond to communications. We may process your personal data in order to respond to any questions or comments made by you on our Website, via email or telephone. Legal basis: such processing is necessary for our legitimate interest (to respond to our customers who request information regarding our company and/or our services).
- Business requirements. We may process your personal data in order to administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Legal basis: such processing is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and/ or to comply with a legal obligation.
- Advertising. We may process your personal data to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. Legal basis: such processing is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
- Data analytics. We may process your personal data for data analytics purposes in order to improve our Website, products and services, marketing and/or customer relationships and experiences. Legal basis: such processing is necessary for our legitimate interests (to define the types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).
- Recommendations about goods and services. We may process your personal data to make suggestions and recommendations to you about goods and services that may be of interest to you. Legal basis: such processing is necessary for our legitimate interests (to develop our services and to grow our business).
We will get your express opt-in consent before we share your personal data with any company outside the Kura (CS) Limited group of companies for marketing purposes.
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 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 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.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of other transactions.
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 – email@example.com.
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.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the following third parties for the purposes set out in in paragraph 4 above:
- analytics and search engine providers that assist us in the improvement and optimisation of our Website.
- business partners, suppliers and sub-contractors that provide us with hosting, email and IT services.
- advertisers and advertising networks that require the personal data to select and serve relevant adverts to you and others.
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HMRC, regulators and other authorities who require reporting of processing activities in certain circumstances.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
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 only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area.
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 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.
HOW LONG WILL YOU USE MY PERSONAL DATA 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 your 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.
In some circumstances you can ask us to delete your personal data: see request erasure of your personal data below 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 LEGAL RIGHTS
In certain circumstances, you have rights under data protection laws in relation to your personal data including a right to:
- request access to your personal data.
- request correction of your personal data.
- request erasure of your personal data.
- object to processing of your personal data.
- request restriction of processing your personal data.
- request transfer of your personal data.
- right to withdraw consent.
You can find out more about your rights here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of the rights set out above, please contact us by email at firstname.lastname@example.org
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee or alternatively refuse to comply with your request, if your request is clearly unfounded, repetitive or excessive.
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.
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.