Version 2: 26 October, 2018
Definitions and interpretation
|Data||collectively all information that you submit to Kinny Co Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;|
|Cookies||a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);|
|Data Protection Laws||any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;|
|GDPR||the General Data Protection Regulation (EU) 2016/679;|
|Kinny Co Limited, or us||a company incorporated in England and Wales with registered number 11549057 whose registered office is at Apt 24431 Chynoweth House, Trevissome Park, Blackwater, Cornwall, TR4 8UN;|
|UK and EU Cookie Law||the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;|
|User or you||any third party that accesses the Website and is not either (i) employed by KINNY CO LIMITED and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to KINNY CO LIMITED and accessing the Website in connection with the provision of such services; and|
|Website||the website that you are currently using, www.swag.kinny.io , www.kinny.io/swag and any sub-domains of this site unless expressly excluded by their own terms and conditions.|
- the singular includes the plural and vice versa;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
- For purposes of the applicable Data Protection Laws, Kinny Co Limited is the “data controller”. This means that Kinny Co Limited determines the purposes for which, and the manner in which, your Data is processed.
- We may collect the following Data, which includes personal Data, from you:
- contact Information such as email addresses, postal addresses and telephone numbers;
- IP address (automatically collected);
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
- Payment details are processed by established trusted third parties and are not processed or stored by Kinny Co Limited.
How we collect Data
- We collect Data in the following ways:
- data is given to us by you;
- data is received from other sources; and
- data is collected automatically.
Data that is given to us by you
- Kinny Co Limited will collect your Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you register with us and set up an account to receive our products/services;
- when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
- when you use our services;
Data that is received from publicly available third parties sources
Data that is collected automatically
- To the extent that you access the Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
- Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- provision of Kinny Co Limited, Kinny Swag Store services
- We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
- We may use your Data to show you Kinny Co Limited adverts and other content on other websites. If you do not want us to use your data to show you KINNY CO LIMITED adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).
Who we share Data with
- We may share your Data with the following groups of people for the following reasons:
- our employees, agents and/or professional advisors – information may be shared in order for Kinny Co Limited to deliver the services of the Kinny Swag Store (swag.kinny.io)
- third party service providers who provide services to us which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website and associated kinny applications runs smoothly;
Keeping Data secure
- We will use technical and organisational measures to safeguard your Data, for example:
- We or our Trusted third party hosts, payment providers store your Data on secure servers.
- Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Data retention (and Processing)
- Third party providers such as clothing fulfillment and payment providers will retain data according to their particular data policies. Our third party providers have been carefully selected and operate their own GDPR and PCI compliant procedures.
- Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
- You have the following rights in relation to your Data:
- Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase – the right to request that we delete or remove your Data from our systems. You can send us a request to delete your account. Upon receiving the request, we will make a reasonable effort to delete your personal information from our internal network within a reasonable period of time as long as we are not obligated to preserve your information due to things like law enforcement preservation requests, subpoenas, investigations, litigation, or otherwise meet any of our other legal obligations including a clear attributable record of what could be regarded as financial transactions. We may also retain depersonalised information after deletion. You may have to request the erasure of Data directly with our integrated Third Parties given you may be subject to their particular policies.
- Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- Right to data portability – the right to request that we move, copy or transfer your Data.
- Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
- To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org.
- If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
- It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Transfers outside the European Economic Area
- Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA.
- We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data. For example we use payment providers PayPal and Stripe that adhere to a strict implementation of GDPR policies.
- To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures to be followed should we share your Data with third parties . This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.
Links to other websites
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
- All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
- Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Kinny Co Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- This Website may place the following Cookies:
|Type of Cookie||Purpose|
|Strictly necessary cookies||These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.|
|Analytical/performance cookies||They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.|
|Functionality cookies||These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).|
|Targeting cookies||These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.|
- You can find a list of Cookies that we use in the Cookies Schedule.
- You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
- For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Below is a list of the cookies that we use or may use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.
We use the following strictly necessary cookies:
|Description of Cookie||Purpose|
|Session cookie||We may use this session cookie to remember you and maintain your session whilst you are using our website|
We use the following analytical/performance cookies:
|Description of Cookie||Purpose|
|Analysis cookie||We may use this cookie to help us analyse how users use the website|
We use the following functionality cookies:
|Description of Cookie||Purpose|
|Identifier and analytical cookie||We use this cookie to identify your computer and analyse traffic patterns on our website|
We use the following targeting cookies:
|Description of Cookie||Purpose|
|Smart cookie||We may use this cookie to enable us to show you adverts while you are browsing our website and other websites on the internet|
If any part of these Terms is found to be invalid, illegal or unenforceable for any reason, then that provision will be severed from these Terms to the minimum extent such that the remaining provisions of these Terms will continue in full force and effect.
Updates to this policy