1. Introduction
This privacy notice gives you information about how Kaleidoscope Solutions Limited collects and uses your personal data through your use of this website (the Website).
Kaleidoscope Solutions Limited is the controller of your personal data ("Kaleidoscope", "we", "our", "us"). We are responsible for your personal data. We are entered in the Information Commissioner's Office ("ICO") Register of Data Controllers with registration number ZA857544.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please email us at privacy@kaleidoscope.com.
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified. If you use our Website, communicate with us, or do business with us, this will result in us collecting personal data about you.
We may collect, use, store and transfer personal data about you which we have grouped as follows:
Identity data such as your name, title, username, and date of birth.
Contact data such as your billing address, email address and telephone numbers.
Financial data such as your payment details.
Transaction data such as details about payments to and from you and other details of products and services you have purchased from us.
Technical data such as your 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 this Website.
Usage data which includes information about how you use our Website, products and services.
Marketing and communications data, including your preferences in receiving marketing from us and our third parties, and your communication preferences.
We do not normally collect “special categories” of personal data from our customers or users of our Website. Nor do we collect any information about criminal convictions and offences. In the event you provide us with any special category data, we will take extra care to ensure your rights are protected.
3. How is your personal data collected
We collect your personal information through different methods including:
Your interactions with us. You may give us your personal data by filing in online forms or by corresponding with us by telephone, e-mail, phone or otherwise.
Through the service we provide to you.
Automated technologies or interactions. As you interact with our Website, we may automatically collect anonymous aggregated data on how you use our Website. We collect this data by using cookies, server logs and other similar technologies.
4. How we will use your personal data
We will only use your personal data when we have a legal basis for doing so. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
If you fail to provide certain information to us, 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 service you have with us, but we will notify you if this is the case at the time.
5. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.
Purpose/Use | Type of data | Legal basis |
|---|---|---|
To register you as a new customer. | Contact Identity | Performance of a contract with you. |
To process your order, including: (i) managing payments, fees and charges; and (ii) collecting and recovering money owed to us. | Contact Identity Transaction | Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us). |
To manage our relationship with you, including: (i) notifying you about changes to our contract or services; (ii) asking you to provide us with feedback; and (iii) dealing with your requests, complaints and queries. | Contact Identity Marketing and communication | Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us). |
To provide you with information or services that you request from us or which we feel may interest you. | Contact Usage Identity Technical Marketing and Communications | Necessary for our legitimate interests (to grow our business and inform marketing strategy). |
To administer and protect our business and our Website. | Contact Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation. |
To ensure that content from our Website is presented in the most effective manner for you and for your computer or device. | Technical Usage Marketing and Communications | Necessary for our legitimate interests (to study how customers use products/ services, to grow our business and inform marketing strategy). |
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences. | Technical 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 marketing strategy). |
6. Marketing
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
7. Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
8. Opting out of marketing
You can ask us or third parties to stop sending you marketing messages at any time using the contact details at section 1 of this notice. .
9. Sharing your personal information
We may share your personal information with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.
We may share your personal information with:
Third parties who we engage to provide services and business functions. The activities carried out by third-party service providers may include: IT support, marketing and payment merchants.
Our professional service providers, such as lawyers.
Where we are legally required to share your personal data in respect of legal proceedings, or to comply with our legal obligations, a court order, or the instructions of a regulator, the police or a governmental authority.
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
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.
In the event we transfer your personal data outside of the UK, where the recipient is based in a jurisdiction that has not been deemed to provide adequate protection of your data, we will put in place specific contractual protections approved for use by the Information Commissioner’s Office to ensure that your data is adequately protected.
10. 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.
11. Data retention
We will only retain your personal information 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
12. Your legal rights
Your personal information is protected under data protection law and you have a number of rights which you can seek to exercise.
You have the right to:
Request access to your personal data. 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.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests).
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
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.
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.
Request restriction of processing of your personal data.
If you want to exercise any of the rights set out above, please use the contact details at section 1 of this notice. .
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
13. Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office by telephone 0303 123 1113 or via their website www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns beforehand so please use the contact details at section 1 of this notice. .
14. Changes to the privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.