Updated 10th October 2018
1 – Definitions and Interpretation
In this Policy, the following terms shall have the following meanings: “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below; “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and “We/Us/Our” means Kisiel Ltd, a limited company registered in England under company number 06126906, whose registered address is Kisiel Ltd, 1 Approach Road, London, SW20 8BA, United Kingdom.
2 – Information About Us
2.1 – Our Site is owned and operated by Kisiel Ltd, a limited company registered in England under company number 06126906, whose registered address is Kisiel Ltd, 1 Approach Road, London, SW20 8BA United Kingdom.
2.2 – Our VAT number is 975 3436 88.
2.3 – Our Data Protection Officer can be contacted by email at firstname.lastname@example.org, by telephone on +44 (0) 203 984 7410, or by post at Kisiel Ltd, 1 Approach Road, London, SW20 8BA, United Kingdom.
3 – What Does This Policy Cover?
4 – Your Rights
4.1 – As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 – The right to be informed about Our collection and use of personal data;
4.1.2 – The right of access to the personal data We hold about you (see section 12);
4.1.3 – The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 – The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 – The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 – The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 – The right to object to Us using your personal data for particular purposes; and
4.1.8 – Rights with respect to automated decision making and profiling.
4.2 – If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 – For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5 – What Data Do We Collect?
5.1 – name; gender; business/company name; job title; profession; contact information such as email addresses and telephone numbers; demographic information such as town, country, preferences, and interests; IP address; web browser type and version; operating system; a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to; and Business and work interests.
6 – How Do We Use Your Data?
6.1 – All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 – Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 – Providing and managing your access to Our Site;
6.2.2 – Personalising and tailoring your experience on Our Site;
6.2.3 – Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4 – Personalising and tailoring Our services for you;
6.2.5 – Replying to emails from you;
6.2.6 – Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing Us at email@example.com or changing your preferences via Our email footer;
6.2.7 – Market research;
6.2.8 – Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 – With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, device/text message with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 – Third parties including Google, Facebook, Twitter, HubSpot, Instagram, LinkedIn and others whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 – You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 – We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following basis):
6.6.1 – We keep your personal data for no longer than reasonably necessary for a period of 6 years in order to meet legal requirements. Examples include: in case of any legal claims/complaints; for safeguarding purposes etc;
7 – How and Where Do We Store Your Data?
7.1 – We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 – Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.3 – Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 – Steps We take to secure and protect your data include:
7.4.1 – Compliance with our IT Security Policy.
8 – Do We Share Your Data?
Subject to section 8.2, We will not share any of your data with any third parties for any purposes. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
Where Is Your Data Shared?
8.1 – We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.2 – The third party data processors used by Us and listed below could be located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.3 – In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9 – What Happens If Our Business Changes Hands?
9.2 – In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10 – How Can You Control Your Data?
10.1 – When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10.2 – You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11 – Your Right to Withhold Information
11.1 – You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12 – How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or +44 (0) 207 788 7439 using the contact details below in section 14.
13.2 – By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for advertising, to track how you use and experience our website, build anonymous statistical data about how our website is performing, and to power the personalisation of website content to you. For more details, please refer to section 6, above, and to section 13.6 below.
13.3 – All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.4 – Before Cookies are placed on your computer or device, you will be shown a pop up banner at the bottom of any of our website pages requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
13.5 – Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken care to ensure that your privacy is not at risk by allowing them.
13.6 – Third party Cookies from Google, LinkedIn, Facebook, Twitter, Instagram and HubSpot function on Our Site and may be placed on your computer or device: Our tracking code sets the following cookies when someone visits Our Site.
The following information is detailed information regarding Cookies set by HubSpot. These cookies fall into two general categories: Functional cookies: these cookies do not require consent. Consent banner cookies: there are cookies included in the consent banner under GDPR. Specific cookie names and descriptions are listed below, as well as tracking information for the ads tool and cookies from third-party systems:
__hs_do_not_track This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, which still allows anonymized information to be sent to HubSpot. (Expires: 2 years)
__hs_testcookie This cookie is used to test whether the website visitor has support for cookies enabled. (Expires: Session cookie)
hs_ab_test This cookie is used to consistently serve website visitors the same version of an A/B test page that they’ve seen before. (Expires: Session cookie)
hs_lang_switcher_choice This cookie is used to consistently redirect website visitors to the language version of a page in the language they’ve selected on this top-level private domain in the past (if such a language version exists)
_key When visiting a password-protected page, this cookie is set so future website visits to the page from the same browser do not require login. The cookie name is unique for each password-protected page.
hs-messages-is-open (TTL 30 minutes) This cookie is used on the website visitor UI side so HubSpot can determine/save whether the chat widget is open for future visits. It resets after 30 minutes to re-close the widget after 30 minutes of inactivity hs-messages-hide-welcome-message (TTL 1 day) When you dismiss the welcome message in your messages tool, a cookie is set to prevent it from appearing again for one day.
Consent banner cookies
__hstc The main cookie for tracking website visitors. It contains the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). (Expires: 2 years)
hubspotutk This cookie is used for to keep track of a website visitor’s identity. This cookie is passed to HubSpot on form submission and used when de-duplicating contacts. (Expires: 10 years)
__hssc This cookie keeps track of sessions. This is used to determine if we should increment the session number and timestamps in the
__hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. (Expires: 30 min)
__hssrc Whenever HubSpot changes the session cookie, this cookie is also set. We set it to 1 and use it to determine if the user has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session. (Expires: None. Session cookie)
messagesUtk This cookie is used to recognize website visitors who chat with us via the messages tool. If the website visitor leaves your site before they’re added as a contact to our database, they will have this cookie associated with their browser. If we have a history of chatting with a website visitor and they return to our site later in the same cookied browser, the messages tool will load our conversation history with that website visitor. If a visitor is logged in to HubSpot, HubSpot will set additional authentication cookies.
You can see a complete list of cookies set by HubSpot’s app here. Ads tracking We have the Facebook pixel code installed on our website, Facebook may place a cookie on our website visitors. As we use the HubSpot ads tool to select and install our Facebook pixel on pages with the HubSpot tracking code, HubSpot will link the placing of that pixel code to the cookie notification banner. If we require opt-in consent via this banner, the Facebook pixel will not be able to set any cookies on a visitor until they have opted in. If we have manually placed the pixel code on pages (for example, by editing our site header code), HubSpot will not be able to control which visitors Facebook is able to set cookies on. For additional information, check out Facebook’s business tools terms and Facebook’s cookie consent guide. How are cookies from third-party systems handled? HubSpot is not able to control the cookies placed by other scripts included on our website. However, we can choose to use the cookie consent banner to know when a website visitor has given consent to place cookies in their browser.
13.7 – Our Site uses analytics services provided by HubSpot and Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.8 – The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.9 – The analytics service(s) used by Our Site use(s) the following Cookies:
13.10 – In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.11 – It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.