KEEPL. LIMITED - PRIVACY POLICY
WHAT IS THIS?
At Keepl
Limited we take privacy seriously and we are committed to protecting it.
This policy explains
when and why we collect personal data about individuals, how this information
is used, the conditions under which it may be disclosed to others and how it is
kept secure.
Please read this policy
carefully and ensure that you understand it. The policy aims to give you
information on how we collect and process your personal data through your use
of our website including any data you may provide through this website when you
purchase or use our service or access to our platform.
This policy may change from time to time so please check
this page occasionally to ensure that you’re happy with any changes.
This policy was last updated on 15th June 2023.
It is important that you read this
privacy policy together with any other policy on data processing or other
notices we may provide on specific occasions so that you are fully aware of how
and why we are using your personal data. We
keep this policy under regular review.
WHO WE ARE
The data controller responsible for your personal data is Keepl
Limited (company number: 13157100).
Where this policy refers to “Keepl”, “we”, “our” or “us”
below, unless it mentions otherwise, it’s referring to Keepl Limited.
In respect of certain processing activities, such as where collecting personal data to create and manage your
subscription account and where we collect technical information automatically
when you visit our site (as described below), Keepl will act as a data
controller. This means that Keepl decides why and how your personal data is
processed.
If you subscribe to our services, the Keepl platform will
enable you to securely store your personal files, records, documents, photos,
and so on, many of which will constitute or include your personal data. In
accordance with our Terms and Conditions, use
of our platform and services must be for purely personal or household
activities. Personal data processed in the course of a
purely personal or household activity, with no connection to a professional or
commercial activity, is outside the scope of UK GDPR.
In relation to the uploading and storage of personal data in
our platform, we are not a data controller for such processing activities. As
Keepl provides services to process such personal data, it will act as a data
processor and will comply with applicable obligations under UK data protection
law.
This privacy policy relates to personal data where Keepl is
the data controller.
HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data from you in the following ways:
Personal data you
give to us:
This is information about you that you give to us by
entering information via:
·
our
site (www.keepl.com);
·
our
mobile applications;
·
social
media platforms;
·
corresponding
with us by phone, email or otherwise,
and is provided
entirely voluntarily. This includes:
·
information uploaded by you to our
system,
·
information provided at the time of
registering to use our site,
·
subscribing to the services we provide
through our site / platform,
·
posting material or requesting further
services,
·
managing your account online (including
accessing documentation and engaging in correspondence with us by phone, email
or otherwise).
The personal data contained the documents you upload
to our system will be encrypted at rest and in transit. We will only access the
contents of those documents if it is absolutely necessary
in order to provide our service to you (e.g. to help you to access your data).
Personal data we
collect about you:
We may automatically collect the following information: details
of transactions you carry out through the site, and your visits to our site,
including, but not limited to, traffic data, location data, weblogs and other
communication data, and the resources you access. We may also automatically
collect technical information, including anonymous data collected by the
hosting server for statistical purposes, the Internet protocol (IP) address
used to connect your computer or device to the Internet, browser type and version,
time zone setting, browser plug-in types and versions, operating system and
platform. Please see Cookies
for further information. We may also
collect any personal data which you allow to be shared that is part of your
public profile, or third party social network, type
and version, time zone setting, browser plug-in types and versions, operating
system and platform. We may, if you so request, collect personal data from a
third party in accordance with the functionality of our system.
TYPE OF PERSONAL DATA WE PROCESS ABOUT YOU
We may process a range of personal data about you. To make
it easier to understand the information that we use about you, we have divided
this information into categories in the table below and provided a short
explanation of the type of information each category covers.
|
Category |
Personal
data included in this category |
|
Account Information |
Information required
to manage your account. This includes: Name, email
address, telephone number |
|
Correspondence |
information contained
in our correspondence or other communications with you about our products,
services or business. This includes: email address,
telephone number |
|
Analytics / Usage |
information about how
you use the same. This includes: frequency, any
issues you encounter, device used and details of these |
|
Legal |
information relating
to legal claims made by you or against you or the claims process. This includes: Name, address, telephone, email, details of the
claim and correspondence |
|
Complaints |
information contained
in a complaint made by you. This includes: Name,
email address, telephone number and the details of the complaint including
correspondence. |
|
Fraud |
information relating
to the occurrence, investigation or prevention of fraud. |
|
Payment |
Information relating
to payments and subscriptions you have with us. This includes:
payment history, upcoming payments and data to service your account. |
HOW WE USE YOUR PERSONAL DATA
The purposes for which we use your
information and the legal basis under data protection laws on which we rely to
do this are explained below.
Where
you have provided CONSENT
We may use and process your personal data where you have consented for us to do so for the
following purposes:
·
contact
you [via email or text with marketing information about our services if you (i) register for an account with us online and indicate that
you would like to receive such marketing from us; (ii) sign up to [our
newsletter] [emails/ texts] via our website or other medium where available; or
(iii) when you refresh your marketing preferences when responding to a request
from us to do so;
You may withdraw your consent for us to use your information
in any of these ways at any time. Please see Withdrawing your consent
for further details.
The withdrawal of your consent will not impact the
lawfulness of any processing carried out before the withdrawal.
Where
there is a LEGITIMATE INTEREST
We may use and process your personal data where it is
necessary for us to pursue our legitimate
interests as a business, or that of a third party, for the following
purposes:
·
for
marketing activities (other than where we rely on your consent to contact you
by email or text with information about our products and services;
·
for
analysis to inform our marketing strategy, and to
enhance and personalise your customer experience (including to improve the recommendations
we make to you on our website);
· to correspond or communicate with you;
·
to
verify the accuracy of data that we hold about you and create a better
understanding of you as a customer;
·
for
network and information security in order for us to take steps to protect your
information against loss or damage, theft or unauthorised access;
·
for
prevention of fraud and other criminal activities;
·
to
comply with a request from you in connection with the exercise of your rights
(for example where you have asked us not to contact you for marketing purposes,
we will keep a record of this on our suppression lists in order to be able to
comply with your request);
·
to
assess and improve our service to customers through recordings of any calls
with our contact centres;
·
for
the management of queries, complaints, or claims; and
·
for
the establishment and defence of our legal rights.
Where
there is a LEGAL REQUIREMENT
We will use your personal data to comply with our legal
obligations: (i) to assist any public authority or
criminal investigation body; (ii) to identify you when you contact us; and/or
(iii) to verify the accuracy of data we hold about you.
Where
it is required to complete a CONTRACT
We may use and process your personal data where we have
supplied you (or continue to supply you) with any services, where we have
arranged for the supply of another company’s products or services to you, or
where you are in discussions with us about any new product or service. We will
use this information in connection with the contract for the supply of services
when it is needed to carry out that contract or for you to enter
into it. Please see Type of personal data we process about you
above for details of the types of personal data we process for these purposes.
Specific Uses
Specifically, we may use your data for the following
purposes and on the basis of the legal bases
identified in the table below. Please 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.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of
legitimate interest |
|
Providing and managing your
account |
·
Identity ·
Contact details |
Performance of a contract
with you |
|
Providing and managing your
access to our website / platform |
·
Identity ·
Contact details |
Performance of a contract
with you |
|
Personalising and tailoring
your experience on our website /platform |
·
Identity ·
Contact details ·
Technical Data |
Necessary for our
legitimate interests (to provide customers with the best experience of using our
website) |
|
Supplying our products and
services to you (please note that we require your personal data in order to enter into a contract with you). |
·
Identity ·
Contact details ·
Financial |
Performance of a contract
with you |
|
Personalising and tailoring
our products and services for you. |
·
Identity ·
Contact ·
Technical Data ·
Usage ·
Profile ·
Marketing and Communications |
Necessary for our
legitimate interests (to develop our products/services and grow our
business). |
|
Replying to emails from
you. |
·
Identity ·
Contact |
Necessary for our
legitimate interests (for running our business and providing a good customer
service). |
|
Supplying you with emails
that you have opted into (you may unsubscribe or opt-out at any time by
clicking the unsubscribe link at the bottom of the marketing emails). |
·
Identity ·
Contact |
Consent. |
|
Analysing your use of our website
/ platform and gathering feedback |
·
(a) Technical
Data ·
(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). |
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL
DATA
Our suppliers and
service providers
We may disclose your
information to our third party service providers,
agents, subcontractors and other organisations for the purposes of providing
services to us or directly to you on our behalf. Such third parties may include
cloud service providers (such as hosting and email management), advertising
agencies and administrative services.
When we use third party
service providers, we only disclose to them any personal data that is necessary
for them to provide their service and we have a contract in place that requires
them to keep your information secure and not to use it other than in accordance
with our specific instructions.
Credit/debit card
payment processors
When you purchase any
products or services online, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure
online capture and processing of credit/debit card transactions. If you have
any questions regarding secure transactions, please contact us using the
details at the end of this policy.
Other ways we may
share your personal data
We may transfer your personal
data to a third party as part of a sale of some or all of
our business and assets to any third party or as part of any business
restructuring or reorganisation. We may also transfer your personal data if
we’re under a duty to disclose or share it in order to
comply with any legal obligation, to detect or report a crime, to enforce or
apply the terms of our contracts or to protect the rights, property or safety
of our visitors and customers. We will always take steps with the aim of
ensuring that your privacy rights continue to be protected.
Where you ask us to
share your personal data with a third party (e.g. your insurer), we will not be
responsible for how that third party uses your personal data.
We will never sell your
personal data to a third party and only share it will third parties (as
described above) when it is necessary for us to do so in
order to provide our service to you.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure
servers which are located within the United Kingdom (UK) and European Economic
Area (EEA).
If at any time we transfer your personal data to, or store
it in, countries located outside of the UK and EEA (for example, if our hosting
services provider changes) we will ensure that appropriate safeguards are in
place for that transfer and storage as required by applicable law. This is
because some countries outside of the UK and EEA do not have data protection
laws equivalent to those in the UK and EEA.
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
If we collect your personal data, the length of time
we retain it is determined by a number of factors
including the purpose for which we use that information and our obligations
under other laws. We do not retain personal data in an identifiable format for
longer than is necessary. 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, regulatory, tax, accounting or other
requirements.
We may need your personal
data to establish, bring or defend legal claims. For this purpose, we may retain your personal
data for 7 years after the date it is no longer needed by us for any of the
purposes listed under How we use your personal data above. The only exceptions to this are where:
·
we may delete
your personal data sooner if we believe it necessary;
·
the law requires
us to hold your personal data for a longer period, or delete it sooner;
SECURITY AND LINKS TO OTHER SITES
Unfortunately, the
transmission of information via the internet is not completely secure. Although
we will do our best to protect your personal data, we cannot guarantee the
security of your information transmitted to our website and any transmission is
at your own risk. Once we have received your personal data, we put in place
reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or
unauthorised access.
Where we have given (or
where you have chosen) a password which enables you to access an account, you
are responsible for keeping this password confidential. We ask you not to share
your password with anyone.
Our website may contain
links to other websites run by other organisations. This policy does not apply
to those other websites‚ so we encourage you to read their privacy statements.
We cannot be responsible for the privacy policies and practices of other
websites even if you access them using links that we provide. In addition, if
you linked to our website from a third party website,
we cannot be responsible for the privacy policies and practices of the owners
and operators of that third party website and recommend that you check the
policy of that third party website.
COOKIES
For information on how
we use cookies and how to switch them off on your device, please visit our
Cookie policy.
MARKETING
We may collect your preferences to receive marketing
information directly from us by email, SMS, automated calls or other means in
the following ways:
We may contact you with targeted advertising delivered
online through social media and platforms operated by other companies, by
phone, mail or any other medium by using your personal data,
or use your personal data to tailor marketing to improve its relevance
to you, unless you object.
We will only share your information with our third party partners for them to contact you with marketing
information about their products and services where you have indicated that you
would like us to do so. Please use the link on the page requesting your consent
to find out more about these third parties. Once shared, the relevant third
party’s privacy policy will apply to their processing of your personal data,
not ours. If you’d like to opt-out of receiving marketing from a third party
after providing your consent, you can do so at any time by contacting the
relevant third party directly.
If you do not complete a purchase and have not indicated
that you would prefer otherwise, we may send a reminder to you about your
incomplete purchase.
From time to time, we may ask you to refresh your marketing
preferences by asking you to confirm that you consent to continue receiving
marketing information from us.
You have the right to opt-out of our use of your personal
data to provide marketing to you in any of the ways mentioned above. Please see
Withdrawing your Consent and Objecting to our use of your personal
data and automated decisions made about you above for further details on
how you can do this.
YOUR RIGHTS
Under certain circumstances, you
have a number of rights in relation to your personal
data under data protection law. In relation to certain rights, we may ask you
for information to confirm your identity and, where applicable, to help us to
search for your personal data. Except in rare cases, we will respond to you
within one month from either (i) the date that we
have confirmed your identity or (ii) where we do not need to do this because we
already have this information, from the date we received your request.
·
Accessing your personal data
You have the right to
ask for a copy of the information that we hold about you by emailing or writing
to us at the address at the end of this policy. No fee is payable
and we will provide any and all information in response to your request free of
charge unless your request is clearly unfounded, repetitive or excessive in
which case we may charge a reasonable fee. Alternatively, we could refuse to
comply with your request in these circumstances. We may not provide you with a
copy of your personal data if this concerns other individuals or we have
another lawful reason to withhold that information.
We try to respond to
all legitimate requests within one month. Occasionally it could 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.
You will be required to
provide evidence of your identity in order to receive
your personal data or have your personal data removed. 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.
·
Correcting and updating your personal data
The accuracy of your
information is important to us and we are committed to
making it easy for you to review and correct the information that we hold about
you.
In the meantime, if you
change your name or address/email address, or you discover that any of the
other information we hold is inaccurate or out of date, please let us know by
contacting us in any of the details described at the end of this policy.
·
Withdrawing your consent
Where we rely on your
consent as the legal basis for processing your personal data, as set out under How
we use your personal data, you may withdraw your consent at any time by
contacting us using the details at the end of this policy. If you would like to withdraw your consent to
receiving any direct marketing to which you previously opted-in, you can do so
using our unsubscribe tool. If you withdraw your consent, our use of your personal
data before you withdraw is still lawful.
·
Objecting to our use of your personal data and automated
decisions made about you
Where we rely on your legitimate business interests as the legal basis for
processing your personal data for any purpose(s), as set out under How we
use your personal data, you may object to us using your personal data for
these purposes by emailing or writing to us at the address at the end of this
policy. Except for the purposes for which we are sure we can continue to
process your personal data, we will temporarily stop
processing your personal data in line with your objection until we have
investigated the matter. If we agree that your objection is justified in
accordance with your rights under data protection laws, we will permanently
stop using your data for those purposes. Otherwise we
will provide you with our justification as to why we need to continue using
your data.
You
may object to us using your personal data for direct marketing purposes and we
will automatically comply with your request. If you would like to do so, please
use our unsubscribe tool.
If
we carry out any automated processing, you may also contest a decision made
about you based on automated processing by contacting us on the details at the
end of this policy.
·
Erasing your personal data or restricting its processing
In
certain circumstances, you may ask for your personal data to be removed from
our systems by emailing or writing to us at the address at the end of this
policy. Unless there is a reason that the law allows us to use your personal
data for longer, we will make reasonable efforts to comply with your request.
You
may also ask us to restrict processing your personal data where you believe it
is unlawful for us to do so, you have objected to its use and our investigation
is pending or you require us to keep it in connection with legal
proceedings. In these situations
we may only process your personal data whilst its processing is restricted if
we have your consent or are legally permitted to do so, for example for storage
purposes, to protect the rights of another individual or company or in
connection with legal proceedings.
·
Transferring your personal data in a structured data file
You can ask us to send your personal data directly to
another service provider, and we will do so if this is technically possible. We
may not provide you with a copy of your personal data if this concerns other
individuals or we have another lawful reason to withhold that information.
·
Complaining to the UK data protection regulator
You have the right to make a complaint at any time to the
Information Commissioner's Office (the “ICO”), the UK regulator 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. The ICO’s address: Information Commissioner’s Office, Wycliffe
House, Water Lane, Wilmslow, Cheshire SK9 5AF. Helpline number: 0303 123 1113
CHANGES TO THIS POLICY
We may review this policy from time to time and any changes
will be notified to you by posting an updated version on our website and/or by
contacting you by email. Any changes will take effect 7 days after the date of
our email or the date on which we post the modified terms on our website,
whichever is the earlier. We recommend you regularly check for changes and
review this policy whenever you visit our website. If you do not agree with any
aspect of the updated policy you must immediately
notify us and cease using our services.