Key Solutions Europe Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.keysolutionseurope.co.uk (our site) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of [our] Site;|
|“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 Part 14, below; and|
|[“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]|
Information About Us
Our Site is [owned and] operated by Key Solutions Europe Ltd, a Limited Company registered in England under company number 9146841.
264 High Street, Beckenham, Kent, BR3 1DZ
Main trading address:
Chislehurst Business Centre, 1 Bromley Lane, Chislehurst, Kent, BR7 6LH
VAT number: 205 9602 20.
Data Protection Officer: Steve Defries.
Email address: firstname.lastname@example.org
Telephone number: 020 3695 9764.
Postal Address: Chislehurst Business Centre, 1 Bromley Lane, Chislehurst, Kent, BR7 6LH.
[We are] regulated by SSAIB.]
What Does This Policy Cover?
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the GDPR, you have the following rights, which [we] will always work to uphold:
- The right to access the personal data [we] hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by [us] is inaccurate or incomplete. Please contact [us] using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask [us] to delete or otherwise dispose of any of your personal data that [we] Please contact [us] using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to [us] using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to [us] directly, [we are] using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask [us] for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. [We] do not use your personal data in this way.]
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about [our] use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data Do We Collect?
We may collect, store and use the following kinds of personal information:
- Information that you provide to us such as your name, address, date of birth, telephone number, email address, bank account and payment card details and any feedback you give to us, including by phone, email, post, meetings or when you communicate with us via social media;
- Information about the Services that we provide to you (including for example, the things we have provided to you, when and where, what you paid, the way you use our products and Services, and so on);
- Information if you visit one of our offices (including for example visual images collected via closed circuit television (CCTV));
- Information you may provide us about other people (including for example, property agents, tenants, family members, key holders and so on);
- Information about your computer and about your visits to and use of our website.
- Any other information that you choose to send to us.
Where you provide information about other people to us (including for example, name, telephone number) you are confirming by submitting said information that you have the permission of the third party to do so and that the information provided is accurate to the best of your knowledge.
How Do You Use My Personal Data?
Under the GDPR, [we] must always have a lawful basis for using personal data. This may be because the data is necessary for [our] performance of a contract with you, because you have consented to [our] use of your personal data, or because it is in [our] legitimate business interests to use it. Your personal data [may] be used for [one of] the following purposes:
- [Providing and managing your Account;]
- [Providing and managing your access to [our] Site;]
- [Personalising and tailoring your experience on [our] Site;]
- [Supplying [our] [products] AND/OR [services] to you. Your personal details are required in order for [us] to enter into a contract with you.]
- [Personalising and tailoring [our] [products] AND/OR [services] for you.]
- [Communicating with you. This may include responding to emails or calls from you.]
- [Supplying you with information by [email] AND/OR [post] that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the link within our email correspondence or emailing email@example.com).]
- [Analysing your use of [our] Site [and gathering feedback] to enable [us] to continually improve [our] Site and your user experience.]
[With your permission and/or where permitted by law, [we] may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on [our] [products] AND/OR [services]. You will not be sent any unlawful marketing or spam. [we] will always work to fully protect your rights and comply with [our] obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.]
How Long Will You Keep My Personal Data?
We keep your personal data for no longer than reasonably necessary. The retention periods can differ based on the type of data processed, the purpose of processing or other factors.
In general, we hold your personal data on our systems for as long as you are a customer and for as long afterwards as it is in our legitimate interest to do so or for as long as is necessary to comply with our legal obligations.
How and Where Do You Store or Transfer My Personal Data?
[[we] will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.]
The security of your personal data is essential to [us], and to protect your data, [we] take a number of important measures, including the following:
- Encrypted storage systems and data back ups
- Locked secure premises / filing cabinets
- Regular cyber resilience testing
Do You Share My Personal Data?
[we] will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, [we] may be legally required to share certain personal data, which might include yours, if [we are] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
How Can I Control My Personal Data?
- In addition to your rights under the GDPR, when you submit personal data via [our] Site, you may be given options to restrict [our] use of your personal 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] OR [,] at the point of providing your details [and by managing your Account]).
- 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.
Can I Withhold Information?
How Can I Access My Personal Data?
If you want to know what personal data [we] have about you, you can ask [us] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to firstname.lastname@example.org or our registered office address listed above.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] administrative costs in responding.
[we] will respond to your subject access request within 30 days and, in any case, not more than] one month of receiving it. Normally, [we] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] receive your request. You will be kept fully informed of [our] progress.
What are cookies?
Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
- We use anonymous session cookies (short-term cookies that disappear when you close your browser) to help you navigate the website and make the most of the features.
Should you wish to deny the use and saving of cookies from this website onto your computer hard drive, you should take necessary steps within your web browser’s security settings to block all cookies from this website and its external serving vendors (see the ‘Help’ menu of your browser to find out how to do this). You are also able to opt out of Google Analytics Cookies by following these links. If however you do not allow us to collect information in this way you may find our website less user friendly and more difficult to use.
How Do I Contact You?
To contact [us] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Steven Defries)]:
Email address: email@example.com.
Telephone number: 020 3695 9764.
Chislehurst Business Centre
1 Bromley Lane
[we] may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if [we] change [our] business in a way that affects personal data protection.