Legal

Privacy Policy

1. Introduction

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. This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It provides you with information about how we collect and use your data; how we look after your personal data; and your legal rights relating to your personal data.

2. Important information and who we are

Purpose of this privacy policy. This privacy policy (together with our terms and any other documents referred to in it) provides information on how we collect and process your personal data through your use of our website at wearekura.com (“Website”) or when you interact with us at an event or on social media, including any personal data you may provide when you contact us. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions, so that you are fully aware of how and why we are using your personal data. Our Website is not intended for children, and we do not knowingly collect personal data relating to children.

Data Controller. Kura (CS) Limited, registered in Scotland (company registration SC476104) is the data controller and is responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

3. Contact information

Title of DPO: Chief Culture Officer
Email: [email protected]
Postal address: Kura (CS) Limited, Citypoint, 21 Tyndrum Street, Glasgow, G4 0JY
Telephone: 0141 272 1087

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.

4. Changes to the privacy policy and your duty to inform us of changes

We recommend that you check our Website from time to time to inform yourself of any changes to this privacy policy. If we decide to make any significant changes we will notify you by email. It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.

5. Third-party links

Our 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 personal 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 policy of every website you visit.

6. 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 as 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 IP address, browser type and version, time zone setting and location, 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 your visit.
  • 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 (such as race or ethnicity, religious beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic and biometric data), nor any information about criminal convictions and offences other than as part of our recruitment or employment processes with prior consent.

7. 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 and Contact Data by corresponding with us by post, phone, email or otherwise, including when you use our Website, participate in social media functions, competitions, promotions or surveys, or contact us.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical and Usage Data using cookies, server logs and similar technologies. Please see our cookie policy for further details.
  • Third parties. We may receive personal data about you from third parties, for example from those who have hosted an event sponsored by us that you attended.

8. 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 raise or respond to comments; 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. You have the right to withdraw consent to marketing at any time by contacting us.

9. Purposes for which we will use your personal data

We may process your personal data to: provide services to our clients; respond to your communications; manage our relationship with you; administer and protect our business and Website; deliver relevant website content and advertising; carry out data analytics to improve our Website, products and services; and make recommendations about goods and services that may be of interest to you. We may process your personal data for more than one lawful ground depending on the specific purpose.

10. Third-party marketing

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. You will receive marketing communications from us if you have requested information from us or provided your details when entering a competition or registering for a promotion, and, in each case, you have not opted out.

11. Opting out

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. 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.

12. Cookies

Our Website uses cookies to provide a better service and to distinguish you from other users. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our Website may become inaccessible or not function properly. For detailed information, see our cookie policy.

13. 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 compatible reason. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis. 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.

14. Disclosures of your personal data

We may share your personal data with third parties including analytics and search engine providers; business partners, suppliers and sub-contractors that provide hosting, email and IT services; advertisers and advertising networks; professional advisors including lawyers, bankers, auditors and insurers based in the UK; third parties to whom we may sell, transfer or merge parts of our business; and HMRC, regulators and other authorities. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

15. International transfers

We do not transfer your personal data outside the UK and European Economic Area.

16. Data 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. We limit access to your personal data to those who have a business need to know, 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 where we are legally required to do so.

17. Data retention

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, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm, the purposes for which we process it, and the applicable legal requirements.

18. Your legal rights

In certain circumstances, you have rights under data protection laws in relation to your personal data, including the 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;
  • withdraw consent.

If you wish to exercise any of the rights set out above, please contact us by email at [email protected].

19. 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 refuse to comply with your request, if your request is clearly unfounded, repetitive or excessive.

20. 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.

21. 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.

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