This privacy and cookies policy explains how we (Kalgera Limited) collect, use, share and transfer your personal data when you use the services provided on kalgera.com (“our website”) and our related apps or marketing communication (“our services”). Personal data is any information about you by which you can be identified. This can include information such as:
- your name, date of birth, email address, postal address, phone number, mobile number;
- information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and
- information relating to your personal circumstances and how you use our website and services.
WHO WE ARE AND HOW TO CONTACT US
The data controller for our sites and apps is Kalgera Limited, with registered company number 10711821, registered at 34b York Way, King’s Cross, London, N1 9AB. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us, you can find our contact details in the “How to contact us” section below.
WHAT IS PERSONAL DATA?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out below.
WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT
We collect personal data when you sign up for our services and when you browse our website. This information is used to provide you with our services and to analyse how visitors use our website and interact with the content we produce.
The personal data we collect when you register for to receive The Kalgera Way Newsletter are as follows:
- your name;
- your email address;
- your IP address – a numerical code to identify your device and which can provide information about the country, region or city where you are based;
- your browsing history of the content you have visited on our website, including information on how you were referred to our sites via another website; and
- details of your devices, for example, the unique device ID, unique advertising ID and browsers used to access our content.
HOW WE COLLECT PERSONAL DATA
We collect personal data when you:
- sign up for marketing communications like the Kalgera Way Newsletter;
- use mobile devices to access our website;
- access our website, through cookies and other similar technology; and
- when you contact us via email, social media, our apps or similar technologies or when you mention us on social media.
Why we use your personal data
We use personal data collected through our website and apps for a number of purposes, including the following:
- To provide the services you sign up for, such as sending out The Kalgera Way Newsletter. We also use the personal data for related internal administrative purposes – such as our accounting and records – and to make you aware of any changes to our services.
- To send marketing communications when we have your permission, or when permitted by law.
- To personalise our services (for example, so you can sign in), remembering your settings, displaying personalised advertising as well as measuring how effective our online adverts are.
- To carry out marketing analysis, for example we look at what you have viewed on our website to better understand what your interests and preferences are, and to improve our marketing by making it more relevant to your interests and preferences. You can opt out from having your personal data used for marketing analysis by updating your preferences.
- To improve our marketing communications, we use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email.
- For statistical purposes such as analysing the performance of our website and to understand how visitors use them.
- To respond to your queries and to resolve complaints.
- For security and fraud prevention, and to ensure that our website is safe and secure.
- To comply with applicable laws and regulations.
USING CHILDREN’S PERSONAL DATA
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal data about children under 13. Some of our services may have a higher age restriction and this will be shown at the point of registration.
SECURITY OF YOUR PERSONAL DATA
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our website while still in transit and so you provide it at your own risk.
Who we share your personal data with
We do not share your personal data with other people or organisations that are not directly linked to us except under the following circumstances:
- We may share your data with other organisations that provide services on our behalf such as dealing with online payments and other forms of payment processing, ie credit card transactions and preventing fraud.
- We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.
Some of our webpages use social plug-ins from other organisations (such as the “Facebook Recommend” function, Twitter’s retweet function, Google+ function). These other organisations may receive and use personal data about your visit to our website. If you browse our website information collected may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.
INTERNATIONAL DATA TRANSFERS
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:
- We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
- We may also use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your personal data the same protection it has in the EEA .
- Where we use service providers in the United States, we may transfer personal data to them if they are part of the Privacy Shield scheme, which requires them to provide a similar level of protection of your personal data to what is required in the EEA.
- If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the EEA.
HOW LONG WE KEEP YOUR PERSONAL DATA
HOW WE MAY CONTACT YOU
From time to time we may send you service emails, for example, telling you your subscription is coming to an end or thanking you when you contribute or place an order with us.
Marketing communications and editorial newsletters
If we have your permission, we may send you materials we think may interest you by email. You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email.
Sometimes we may contact you for market research purposes, for example about a survey. If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
COOKIES AND SIMILAR TECHNOLOGY
When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technology. A cookie is a small file that can be placed on your device that allows us to recognise and remember you.
YOUR RIGHTS WITH REGARD TO THE PERSONAL DATA THAT WE HOLD ABOUT YOU
You can contact us with regard to the following rights in relation to your personal data:
- If you would like to have a copy of the personal data we hold on you or if you think that we hold incorrect personal data about you, please write to the Data Protection Officer at Kalgera Limited, 34b York Way, King’s Cross, London, N1 9AB or email email@example.com. We will deal with requests for copies of your personal data or for correction of your personal data within one month. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
- Where you have provided us with consent to use your personal data, you can withdraw this at any time.
- Where applicable, you may also have a right to receive a machine-readable copy of your personal data.
- You also have the right to ask us to delete your personal data or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request. Where applicable, you have the right to object to processing of your personal data for certain purposes.
- If you do not want us to use your personal data for marketing analysis, you can change your references accessible by clicking the link in your email and deselecting Market Research.
If you want to make any of these requests, please contact firstname.lastname@example.org. We may need to request specific information from you to help us confirm your identity.
CONTACT US FOR INFORMATION ABOUT HOW WE USE YOUR PERSONAL DATA
If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact us by writing to the Data Protection Officer at Kalgera Limited, 34b York Way, King’s Cross, London, N1 9AB. or email email@example.com.
Complaints will be dealt with by the Data Protection Manager, and will be responded to within 30 days. If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.
May 2018: updated to reflect changes resulting from the General Data Protection Regulation.
April 2020: updated to reflect change in the registered address of Kalgera Limited.