Updated 23rd January 2020
1 – Definitions and Interpretation
In this Policy, the following terms shall have the following meanings: “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below; “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and “We/Us/Our” means Kisiel Ltd, a limited company registered in England under company number 06126906, whose registered address is Kisiel Ltd, Rift House, 200 Eureka Park, Upper Pemberton, Kennington, Ashford, TN25 4AZ, United Kingdom.
2 – Information About Us
2.1 – Our Site is owned and operated by Kisiel Ltd, a limited company registered in England under company number 06126906, whose registered address is Kisiel Ltd, Rift House, 200 Eureka Park, Upper Pemberton, Kennington, Ashford, TN25 4AZ, United Kingdom.
2.2 – Our VAT number is 975 3436 88.
2.3 – Our Data Protection Officer can be contacted by email at firstname.lastname@example.org, by telephone on +44 (0) 20 3984 7410, or by post at Kisiel Ltd, 5 Sandiford Road, Sutton, SM3 9RN, United Kingdom.
3 – What Does This Policy Cover?
4 – Your Rights
4.1 – As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 – The right to be informed about Our collection and use of personal data;
4.1.2 – The right of access to the personal data We hold about you (see section 12);
4.1.3 – The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 – The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 – The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 – The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 – The right to object to Us using your personal data for particular purposes; and
4.1.8 – Rights with respect to automated decision making and profiling.
4.2 – If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 – For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5 – What Data Do We Collect?
5.1 – name; gender; business/company name; job title; profession; contact information such as email addresses and telephone numbers; demographic information such as town, country, preferences, and interests; IP address; web browser type and version; operating system; a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to; and Business and work interests.
6 – How Do We Use Your Data?
6.1 – All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 – Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 – Providing and managing your access to Our Site;
6.2.2 – Personalising and tailoring your experience on Our Site;
6.2.3 – Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4 – Personalising and tailoring Our services for you;
6.2.5 – Replying to emails from you;
6.2.6 – Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing Us at email@example.com or changing your preferences via Our email footer;
6.2.7 – Market research;
6.2.8 – Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 – 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, telephone, device/text message 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.
6.4 – Third parties including Google, Facebook, Twitter, HubSpot, Instagram, LinkedIn and others whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 – You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 – We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following basis):
6.6.1 – We keep your personal data for no longer than reasonably necessary for a period of 6 years in order to meet legal requirements. Examples include: in case of any legal claims/complaints; for safeguarding purposes etc;
7 – How and Where Do We Store Your Data?
7.1 – We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 – Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.3 – Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 – Steps We take to secure and protect your data include:
7.4.1 – Compliance with our IT Security Policy.
8 – Do We Share Your Data?
Subject to section 8.2, We will not share any of your data with any third parties for any purposes. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
Where Is Your Data Shared?
8.1 – We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, 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.
8.2 – The third party data processors used by Us and listed below could be located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.3 – In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9 – What Happens If Our Business Changes Hands?
9.2 – In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10 – How Can You Control Your Data?
10.1 – When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (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).
10.2 – You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11 – Your Right to Withhold Information
11.1 – You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12 – How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or +44 (0) 207 788 7439 using the contact details below in section 14.
A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computer and stored on your computer’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track online traffic flows and record information about your online preferences.
What Cookies do we use and what for?
Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you.
We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
By using our site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. We use third-party cookies on our site for analytics, advertising, social media interaction and logged administrative purposes. For more details, please refer to the above table. These Cookies are not integral to the functioning of our site.
All Cookies used by and on our site, are used in accordance with current UK and EU Cookie Law.
See the table below for the list of Cookies used by our site:
|_fbp||.kisiel.co.uk||Advertisement||This cookie is set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.||3 months|
|fr||.facebook.com||Advertisement||The cookie is set by Facebook to show relevant advertisments to the users and measure and improve the advertisements. The cookie also tracks the behavior of the user across the web on sites that have Facebook pixel or Facebook social plugin.||3 months|
|_ga||.kisiel.co.uk||Analytics||This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.||2 years|
|_gid||.kisiel.co.uk||Analytics||This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visted in an anonymous form.||1 day|
|AWSALBCORS||process.iconnode.com||Necessary||This cookie is used for load balancing services provded by Amazon inorder to optimize the user experience. Amazon has updated the ALB and CLB so that customers can continue to use the CORS request with stickness.||7 days|
|_GRECAPTCHA||.google.com||Necessary||This cookie is set by Google. In addition to certain standard Google cookies, reCAPTCHA sets a necessary cookie (_GRECAPTCHA) when executed for the purpose of providing its risk analysis.||5 months 27 days|
|__cfduid||.fonts.net||Necessary||The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.||1 month|
|__cfduid||.fontawesome.com||Necessary||The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.||1 month|
|__cfduid||.ka-f.fontawesome.com||Necessary||The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.||1 month|
|_gat_UA-43036644-1||.kisiel.co.uk||Other||No description||1 minute|
|_ga_MHR0BNMT5G||.kisiel.co.uk||Other||No description||2 years|
|prism_252938449||prism.app-us1.com||Other||No description||1 month|
|wc_visitor||.kisiel.co.uk||Other||No description||2 years|
|wc_client||.kisiel.co.uk||Other||No description||5 months 27 days|
|prism_252938449||.kisiel.co.uk||Other||No description||1 month|
|wc_swap||.kisiel.co.uk||Other||No description||5 minutes|
|AWSALB||process.iconnode.com||Other||AWSALB is a cookie generated by the Application load balancer in the Amazon Web Services. It works slightly different from AWSELB.||7 days|
* If you choose to decline cookies, you may not be able to fully experience the interactive features of our Service or Website. Kisiel Ltd keeps track of the pages you visit on our website, in order to determine what portion of our Website or Service is the most popular or most used. This data is used to deliver customised content and promotions within the Kisiel Ltd Website and Service to customers whose behaviour indicates that they are interested in a particular subject area.
Types of Cookies Used
We use ‘analytical’ cookies which, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of the website are most popular. This helps us gather feedback so that we can improve our website. Our analytics cookies include Google Analytics and HubSpot. To opt-out of Google Analytics, click here or to find out more information about Google Analytics security and privacy click here.
We may use Remarketing with Google Analytics to advertise online and make ads more relevant. Remarketing cookies will be used by third parties (including Google) to show our ads on websites other than our own.
Both us and third parties (including Google) will also use Remarketing cookies – both first-party (such as Google Analytics) and third-party – to serve more relevant ads to users based on past visits to our website, whether those users are on our website or on other websites. To opt-out of Remarketing or to control your ad preferences, click here. Remarketing cookies expire 90 days from the time that the cookie is set or updated (whichever the later).
In order to enhance your internet experience and to make the sharing of content easier, some pages on our website contain tools or applications that are linked to third party social media providers such as Facebook, Twitter or LinkedIn. Through these tools or applications, the social media service provider may set its own cookies on your device. We do not control these cookies and you should check the social media service provider’s website for further details about how they use them.
How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.
In addition, most advertising networks offer you a way to opt-out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. You may opt-out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.