GENERAL PRIVACY NOTICE

Your personal data – what is it?

“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or physical address).  Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual (e.g. a list of staff may contain personal ID numbers rather than names but if you use a separate list of the ID numbers which give the corresponding names to identify the staff in the first list then the first list will also be treated as personal data).  The processing of personal data is governed by legislation relating to personal data which applies in the European Union including the General Data Protection Regulation (the GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.

Who are we?

This Privacy Notice is provided to you by Knogin Ltd. which is the data processor for your data.

Other data processors we work with:

We may need to share your personal data we hold with them so that they can carry out their responsibilities to us.  If we and the other data processors listed above are processing your data jointly for the same purposes, then Knogin Ltd. and the other data processors may be “joint data processors” which mean we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data processor.

A description of what personal data Knogin Ltd. processes and for what purposes is set out in this Privacy Notice.

Knogin Ltd. will process some or all of the following personal data where necessary to perform its tasks:

How we use sensitive personal data  

Do we need your consent to process your sensitive personal data?

Knogin Ltd. will comply with data protection law. This says that the personal data we hold about you must be:

We use your personal data for some or all of the following purposes:

Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.

What is the legal basis for processing your personal data?

Knogin Ltd. is a private company and has certain legal obligations.  Most of your personal data is processed for compliance with a legal obligation which includes the discharge of Knogin Ltd.’s duties.  Sometimes when exercising these duties, it is necessary to process personal data of clients or people using Knogin Ltd.’s services.   We will always take into account your interests and rights.  This Privacy Notice sets out your rights and Knogin Ltd.’s obligations to you.

We may process personal data if it is necessary for the performance of a contract with a client (the Data Controller), or to take steps to enter into a contract.  An example of this would be processing your data in connection with the use of a client’s enterprise resources, such as networks, computers, etc.

Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use in those cases.

Sharing your personal data

This section provides information about the third parties with whom Knogin Ltd. may share your personal data.  These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):

How long do we keep your personal data?

We will keep some records permanently if we are legally required to do so.  We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support financial audits or provide tax information.  We may have legal obligations to retain some data in connection with our obligations to local governments in the location where your contract is defined.  Knogin Ltd. is permitted to retain data in order to defend or pursue claims.  In some cases, the law imposes a time limit for such claims (for example 6 years for contract claims).  We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim.  In general, we will endeavour to keep data only for as long as we need it.  This means that we will delete it when it is no longer needed.

Your rights and your personal data 

You have the following rights with respect to your personal data:

When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security.  In such cases, we will need you to respond with proof of your identity before you can exercise these rights.

The right to access personal data we hold on you

The right to correct and update the personal data we hold on you

The right to have your personal data erased

The right to object to the processing of your personal data or to restrict it to certain purposes only

The right to data portability

The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained

The right to lodge a complaint with the Information Commissioner’s Office.

Transfer of Data Abroad

If you are an EU Citizen living in the EU, any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights.

Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.  Where and whenever necessary, we will seek your prior consent to the new processing.

Changes to this notice

We keep this Privacy Notice under regular review and we will place any updates on this web page.  This Notice was last updated in October, 2018.

Contact Details

Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints at:

The Data processor, Knogin Ltd. International House, 776-778 Barking Road, London, E13 9PJ, United Kingdom

Phone: +44 20 3000 6837

Email:    info@knogin.com