Your personal information is important to us and we respect it. We are committed to protecting the information we hold about you and to being open with you as to what we do with it.
Important information and who we are:
Our full name is Keko London Limited, and for the purposes of the data protection laws in the UK, we are the ‘data controller’. This means that we decide how and why the personal information you give us is used.
If you have any complaints:
Whilst we hope that it will never occur, if you are unhappy with the way in which we have used your personal information you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). The Information Commissioner’s Office is the authority in the UK responsible for data protection issues. If you are not in the UK but are in Europe, you can make a complaint to your local body responsible for data protection issues. These are usually known as ‘competent supervisory authorities’.
Having said this, if you are unhappy with anything we do or have done we would love the opportunity to put it right so please do let us know.
If we, or you, need to change anything:
This version was last updated on 29th January 2020.
It is important that the information we hold about you is up to date and correct. Please do let us know if any of your personal information changes so that we can update our records.
Other websites and links:
Our website may contain links to other websites, plug-ins and apps. Clicking on those links or enabling those connections may allow other people to collect or share information about you. We do not control anyone else’s websites and are not responsible for their privacy policies or for the content, accuracy or opinions expressed on such websites. We do not investigate, monitor or check anyone else’s websites for accuracy or completeness and the inclusion of any linked website on or through our website does not mean we approve or endorse the linked website.
What we collect:
The data protection laws protect ‘personal data’. Personal data means any information that we can identify an individual from. We also sometimes refer to this as ‘personal information’.
We may collect and use lots of different types of personal information about you. To help you understand the types of information we collect and use we have grouped them together as follows:
- Identity Data this includes your name, your title, your employer (where relevant) and your gender.
- Contact Data this is everything which we can use to get in touch with you such as your address, your email address and your telephone numbers.
- Financial Data this includes bank account details.
- Transaction Data this includes details about payments to and from you or your employer (where you are the named contact) and other details of services purchased from us or provided to us by you or your employer.
- Profile Data this includes things like your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and other organisations and how you would like us to keep in contact with you.
- Technical Data this includes technical things such as your 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 our website.
- Usage Data this includes information about how you use our website, and services.
Personal data does not include information where your identity has been removed or which is not associated with or linked to your information. This is known as anonymous data.
We do not collect any Special Categories of Personal Data about you (this includes information 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.
Sometime the law or an agreement we have with you requires us to collect personal information, if that is the case and you don’t give us that information when we ask for it, we may not be able to perform any agreement with you or we may not be able to enter into an agreement with you (for example, to provide you with services that you request). In this case, we may have to cancel a service you have requested but we will tell you if this is the case at the time.
How we get your information:
We get your personal data in a number of ways:
- Directly from you. You might give us personal information such as your Identity, Contact and Financial Data by contacting us by post, phone, email, via our website or in some other way, when you engage us to provide services to you or your employer or where we engage you (or your employer) to provide services to us or where you request marketing from us, enter any competition we may run or give us any feedback.
From others. We may receive personal information about you from various other people such as:
- Identity, and Contact Data from your employer or people you provide as referees;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from publicly available sources such as Companies House.
What we use your information for:
We only use your personal data when the law allows us to. We may collect and process your personal information for the following purposes:
- For the provision of services - we will use your Identity, Contact, Financial and Transaction Data to perform any contract we are about to enter into with you or your employer or which we have already entered into with you or your employer.
- Managing fees and payments and recovering debts – we will use your Identity, Contact, Financial and Transaction Data to manage any fees or payments due to or from us and to recover any debts owed to us. This is necessary for the performance of our contracts with you/your employer and it is in our legitimate interests to use your information in this way.
- Contacting us - when you contact us with an enquiry or to request information, we will use your Identity and Contact Data to respond to you.
- Surveys - If you choose to complete a survey that we use for research purposes we will retain the information that you provide in response to that survey. This is necessary for our legitimate interest in understanding our clients and developing our business and marketing strategy.
- Administration - we may use your Identity, Contact and Technical Data for the purpose of protecting our business and our website, including troubleshooting, data analysis, testing and system maintenance, support, reporting and hosting of data. This is necessary for our legitimate interest in running our business, to ensure security and to prevent fraud. We may also use this personal data where we have to reorganise, sell or restructure our business in accordance with our legitimate interest to do so, or where we need to do so to comply with the law.
- Website Analytics - as you navigate our website, Technical and Usage Data may be collected automatically. We do this to find out things such as the number of visitors to the various parts of the website, and to help us to improve our website. This is necessary for our legitimate interest in defining areas of interest for our clients, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
- Fault reporting - if you contact us to report a fault with our website, we will use the Identity and Contact Data provided for the purposes of rectifying that fault in accordance with our legitimate interests.
- Recruitment - personal data provided for an employment or consultancy opportunity will be processed so as to allow us to process and evaluate the merits of that application in accordance with our legitimate interests.
We may also use your personal information, where the law allows us to, as follows:
- To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we need to comply with a legal or regulatory obligation, including the prevention of crime.
- 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.
Generally we do not rely on you consenting to us using your personal information in the ways set out above other than in relation to sending someone else’s direct marketing communications to you via email or text message.
Where you tell us we can use your personal information for marketing you can change your mind at any time (withdraw consent) by contacting us.
Where we refer to legitimate interest above, this means our interest in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we use your information for our legitimate interests. We do not use your personal information for activities where the impact on you outweighs our interests (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests and weigh these up against your rights by contacting us.
We will only use your personal data for the purposes we collected it for, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose we obtained your information for. If you want to find out more about how the use of your information for the new purpose is compatible with the original purpose, please do get in touch and we would be happy to give you further details of this. If we need to use your personal data for an unrelated purpose, we will let you know and will explain why that use is lawful.
You should be aware that we may use your personal information without telling you or asking your permission, provided this is in line with the above rules, where this is required or permitted by law. This may include removing your details from our records where we have not heard from you for sometime.
Who we provide your information to:
Your personal data will only be given to those of our employees or workers that need to use it for the reason it was collected. We will not give your personal information to anyone else except in the following circumstances:
- On occasion, we need to hire other companies or individuals to help us to serve you better and in some of these cases we may need to share your personal information with them so they can perform the tasks we have asked them to perform, such as IT support providers, external consultants and sub-contractors, printers, couriers and delivery services, market research providers and any third parties we outsource any part of our business to.
- Where we need to, to perform our agreement with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
- Where we are under a legal duty to do so in order to comply with any legal obligation.
- In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention, internet safety and credit risk reduction.
- If we sell our business or any of its assets to a third party, in which case the information that we hold about our client’s may be one of the transferred assets.
- With other companies in the Keko Group, such as Keko GmbH, Keko Singapore Pte Limited, Keko Dubai and Keko Washington Inc. for the purposes of the effective administration of the Keko Group in accordance with our legitimate interests and where any member of the Keko Group is assisting us with the provision of our services to you.
Where someone else is using your personal information to help us provide our services to you, you can rest assured that we ensure that they respect the security of your personal data and treat it in accordance with the law. We do not allow anyone else to use your information for their own purposes and only allow them to use your personal data in the ways we tell them they can.
Sending your information abroad
Parts of the Keko Group and some of the people we work with are based outside the European Economic Area (“EEA”) so when they need to use or have access to your personal data this will mean your information has to be sent outside the EEA.
Whenever we transfer your personal information out of the EEA, we ensure a similar level of protection is given to it by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we transfer personal information between members of the Keko Group based in the EEA and those based outside the EEA, we have in place specific contracts approved by the European Commission to ensure your data is given the same protection as it has in Europe.
- Where we use providers based in the US, we may send your information 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.
Please contact us if you want to know more about the specific mechanism used by us when transferring your personal data out of the EEA.
How we keep your information secure
We are committed to ensuring that your personal data is secure. In order to make sure your information is not accessed or disclosed when it shouldn’t be, we have put in place the measures which we think are suitable to safeguard and secure your information, these include physical, electronic and managerial procedures. In addition, the access to and use of your personal data is restricted to our employees, workers, consultants and sub-contractors who need it to perform a specific job or task. Where your personal information is shared with anyone else in line with this policy responsible measures are used to protect your personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any regulator of a breach where we are legally required to do so.
You should be aware that the transmission of information over the internet is not completely secure. Once we have received your information, we will use strict measures and security features to try to prevent any unauthorised access. We urge you to take every precaution to protect your personal data when you are on the internet which ever device you use to access it.
How long we keep your information for.
We will only keep your personal information for as long as we need it for the purpose we collected it, this includes meeting any legal, accounting, or reporting requirements we may have.
To decide how long it we keep your personal information for, we think about the amount, nature, and sensitivity of the that information, the potential risk of harm from unauthorised use or disclosure, the reason for using your personal information and whether we can achieve those purposes another way, as well as any relevant legal requirements.
- By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being clients for tax purposes.
- We will retain your Contact, Identity, and Transaction Data for a period of 7 years from the date we last engage with you to enable us to deal with any follow-up communications from you or to ensure that we are in possession of all relevant papers in the event of a legal claim relating to the contract between us.
In some circumstances you can ask us to delete your data: see ‘The rights you have’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be linked to you) for research or statistical purposes, when we do this we may use this information indefinitely without further notice to you.
The rights you have:
The law gives you a number of rights in relation to your personal information, which are set out below:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully using it.
- Request correction of the personal data that we hold about you. This means that you can have any incomplete or inaccurate information that we hold about you corrected, although we may need to verify the accuracy of the new personal information that you provide to us.
- Request erasure of your personal data. This means you can ask us to delete or remove personal data where there is no good reason for us continuing to have it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have used your personal data unlawfully or where we are required to delete your personal data to comply with local law. Please be aware, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of someone else) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to carry on using your personal data which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the use of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to delete it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to someone else. We will provide to you, or the person or organisation you have chosen, your personal data in a structured, commonly used, machine-readable format (such as on a disk or memory stick). Please be aware, this right only applies to certain, automated, information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on your consent (where you have told us we can) to use your personal information. However, this will not affect the lawfulness of any use carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will tell you if this is the case at the time you withdraw your consent. You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) 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 information provided to us as a result of a contract, service experience or other transaction.
You will not have to pay us anything to access your personal information or to exercise any of your other rights. However, 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.
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.
We try to respond to all legitimate requests within one month. Occasionally it may take us a bit longer if your request is particularly complicated or if you have made a number of requests. In this case, we will notify you and keep you updated.
How you can contact us
The Information Security Officer
Keko London Limited
16-18 Beak Street
Or by email at firstname.lastname@example.org