PRIVACY POLICY

Introduction

KEW Investments Ltd and subsidiaries/group of companies, respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

It’s likely that we’ll need to update this privacy notice from time to time. Please check this page regularly for changes to this notice.

This version was last updated on 24th May 2018.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how KEW Investments Ltd collects and processes your personal data when you interact with us, such as, through your use of our website, when you sign up to our publications, when you purchase a product or service from us, when you elect to receive further information about our events and conferences, or when you choose to share your data with us (for example at a meeting, trade event or exhibition).

Controller

KEW INVESTMENTS LTD is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice).

Keeping us informed of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our websites 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you and/or the company whom you work for and we trade with, which we have grouped together follows:

Identity Data includes first name, last name, username or similar identifier, and title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account, payment card details and credit history.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes 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 websites.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our websites, products and services.
Preference Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation).

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product, service or your attendance at one of our events but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Preference and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

(a) apply for or purchase products or services from us;

(b) create an account with us;

(c) when you ask to attend an event;

(d) subscribe to a service or publications from us or our partners;

(e) request marketing, product or event information to be sent to you;

(f) enter a competition, promotion or survey;

(g) visit us at a trade event or exhibition; or

(h) give us some feedback.

Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

(a) analytics providers;

(b) advertising networks and marketing companies;

(c) search information providers;

(d) vendor partners and reseller partners;

(e) credit reference, fraud prevention or government agencies;

(f) providers of technical, payment and delivery services;

(g) data brokers or aggregators;

(h) publicly availably sources such as Companies House and the Electoral Register.

4. How we use your personal data

We will only use your personal data when the law allows us to. The law says that we can only use your personal data in the following circumstances:
- Contract - Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate Interests - 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.
- Legal Obligation - Where we need to comply with a legal or regulatory obligation.
- Consent - Where you consent to it.

Purposes for which we will use your personal data

We have set out below a list of ways that we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Processing Purpose

Type of data

Legal basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Preference

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms

(b) Asking you to leave a review or take a survey

(c) To respond to refund requests and complaints

(a) Identity

(b) Contact

(c) Profile

(d) Preference

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services and to respond to you)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Preference

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and other illegal activities and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Preference

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations (by telephone, text messages, email, social media messages and post),to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Third party direct marketing communications, for example, from our vendor partners

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Preference

With your consent, we may supply your personal data to a third party for their direct marketing purposes

 

If we discover any criminal activity or alleged criminal activity through fraud monitoring and suspicious transaction monitoring.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Financial

Necessary for our legitimate interests (for the purposes of preventing or detecting unlawful acts)

To send you communications required by law or which are necessary to inform you about our changes to the services, products and events we provide to you.

(a) Identity

(b) Contact

(c) Preference

(d) Usage

(e) Profile

(a) Necessary for our legitimate interests (for example, product recall notices, and legally required information relating to your orders)

(b) Necessary to comply with a legal obligation

To comply with our contractual or legal obligations to share data with credit reference, fraud prevention agencies and law enforcement agencies.

(a) Identity

(b) Contact

(c) Technical

(d) Financial

(a) Necessary to comply with a legal obligation.

(b) Necessary for our legitimate interests (to protect our business by preventing financial crime)

To deliver events to you

a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Preference

 

(a) Performance of a contract to manage and maintain our relationships with you.

(b) Necessary for our legitimate interests (to grow our business)

Monitor and record your call, emails and text messages, social media messages and other communications in relation to your dealings with us.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Financial

(a) Necessary to comply with a legal obligation (for regulatory compliance, self-regulatory practices, and crime prevention and detection)

(b) Necessary for our legitimate interests (to protect the security of our communications systems and procedures, to check for obscene or profane content, to assess the quality of our customer services and to provide staff training)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the KEW Investments Ltd group of companies for marketing purposes.

Opting out

You can ask us or third parties 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 at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

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, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please see below.

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 reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

Credit reference checks

The personal data that we have collected from you when setting up an account may be shared with credit reference and fraud prevention agencies who use it to prevent fraud and money laundering and to verify your identity.

We may access and use information from credit reference agencies when you open your account and periodically to:
- manage and take decisions about your account, including assessing your creditworthiness;
- prevent criminal activity, fraud and money laundering
- check your identity and verify the accuracy of the information you provide to us; and
- trace debtors and recover debts.

Application decisions may be taken based solely on automated checks of information from credit reference agencies and internal records.

We will continue to share information with credit reference agencies about how you manage your account including any default in making payments, while you have a relationship with us. This information will be made available to other organisations so that they can take decisions about you.

If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to fraud prevention agencies, law enforcement agencies and other organisations may access and use this information.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services or financing to you. Fraud prevention agencies can hold your information for different periods of time.

When credit reference and fraud prevention agencies process your information, they do so on the basis that they have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect their business and to comply with laws that apply to them.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties:  
-  Being other subsidiaries of KEW Investments Ltd acting as joint controllers or processors and providing IT and system administration services and to undertake leadership reporting.

External Third Parties:
- Service providers acting as processors who provide IT and system administration services, delivery couriers, marketing agencies, credit reference and for fraud management.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities and law enforcement bodies.
- Vendor partners and reseller partners.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data with subsidiaries of KEW Investments Ltd. This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data 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.

7. 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions 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 of a breach where we are legally required to do so.

8. Recruitment Data

We collect Candidate personal data in three primary ways:
- Personal data that you, the Candidate, provide to us;
- Personal data that we receive from other sources; and
- Personal data that we collect automatically.

Personal Data you give to us;

KEW Investments Ltd needs to know certain information about you in connection with potential recruitment within the company. There are numerous ways you can share your information with us. It all depends on what suits you. These may include:
- Entering your details on our website or via an application form, as part of the registration process;
- From your supplied references or former employment/s to enable us to make an informed decision;
- Leaving a hard copy CV at one of our offices;
- Emailing your CV to us or being interviewed by us; and/or
- Working with one our recruitment agencies;
- Applying for jobs through a job aggregator, which then redirects you to our website or email system.

Personal Data we receive from other sources

We also receive personal data about you from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
- Your referees may disclose personal information about you;
- Our recruitment agencies may share personal information about you with us;
- We may obtain information about you from searching for potential Candidate from third party sources, such as LinkedIn and other job sites;
- If you 'like' our page on Facebook or 'follow' us on Twitter we will receive your personal information from those sites;
- If you were referred to us through a TSO or HRMS supplier, they may share personal information about you with us.

9. Data retention

How long will you use my personal data for?

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 for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  

You have the right to:
- 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 we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process 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 processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, 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 a third party) 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 process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (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 erase 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 a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to 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 consent to process your personal data. However, this will not affect the lawfulness of any processing 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 advise you if this is the case at the time you withdraw your consent.

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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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. We may also contact you to ask you for further information in relation to your request to speed up our response.

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.

Contact details

Should you have any questions please contact us as follows:
- Email us at GDPR.officer@globaldistribution.com
- Or write to us at GDPR, KEW Investments Ltd, Unit 7 Kings Court, Kirkwood Road, Cambridge, CB4 2PF, United Kingdom

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.  

11. Cookie Policy

Information about our use of cookies

Our websites use cookies to distinguish you from other users of our websites. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our sites. By continuing to browse the sites, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas of our websites, 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 websites when they are using it. This helps us to improve the way our websites operate, 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 websites. 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 websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our sites.