If you have any concerns, please feel free to contact us at firstname.lastname@example.org.
- The personal information we collect, how we collect it, and why
- Our legal basis for processing personal information
- When do we share your personal information?
- How long do we store your personal information?
- Security of your personal information
- Age restrictions
- Your rights and choices
- Contacting us
a) the singular includes the plural and vice versa;
c) a reference to a person includes firms, companies, government entities, trusts and partnerships;
d) "including" is understood to mean "including without limitation";
e) reference to any statutory provision includes any modification or amendment of it;
2. The personal information we collect, how we collect it, and why
Personal information means any information about an individual from which that individual can be identified. The following shows information we process about you, and the purpose for which we process that information. There may be more than one reason for which we collect such information and we have only listed the main reasons. If you would like further information, please contact us at email@example.com.
In respect of all the above information, our overarching purpose is to enable us to deliver the best service to our Users.
3. Our legal basis for processing personal information
We only ever use your information in line with applicable data protection laws – in particular, the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018 (DPA 2018) and together the Data Protection Legislation. In short, this means we only use it where we have a legal basis to do so. Under the Data Protection Legislation, these are the general legal bases for which we process your personal information, as detailed in the table above:
Consent – you have given us consent to process your personal information for a specific purpose that we have told you about.
Performance of our contract – processing your personal information is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.
Legitimate interests – processing your personal information is necessary for our legitimate interests or those of a third party, provided those interests are not outweighed by your rights and interests (including where processing is required to comply with or enforce a legal obligation, or to exercise or defend our legal rights).
4. When do we share your personal information?
We may disclose your information for certain purposes and to third parties, as described below:
Third Party Providers: We use certain companies, agents or contractors (Third Party Providers) to perform services on our behalf or to help deliver our services to you. In particular, we contract with Third Party Providers, for example to track our contacts and communications, advertising, marketing communications, infrastructure and IT services, to personalise and enhance our services, to provide customer service, to collect debts, to analyse and action data (including data about interactions with our services), and to process and administer consumer surveys. In the course of providing such services, these Third Party Providers may have access to your personal information. We do not authorise them to use or disclose your personal information except in connection with providing their services to us.
This section is to explain how we will ensure that you only receive communications that you wish to receive.
You can change your marketing preferences and unsubscribe at any time by emailing us or clicking the ‘unsubscribe’ in applicable communications. If you choose not to receive this information we will be unable to keep you informed of new services and promotions of ours, or the Kaiku group of companies, that may interest you.
Whatever you choose, you’ll still receive other important information, for example service updates, as described below.
As detailed in the table at section 2, we may send you communications such as those which relate to any service updates (e.g. new product features, service availability) or provide customer satisfaction surveys. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.
6. How long do we store your personal information?
We are legally required to retain financial and transaction data for a minimum period of 7 years for tax, audit and accounting purposes. This includes keeping a record of the amount of each transaction, what it related to, and who we transacted with.
If there is an unresolved issue relating to another User, for example relating to an issue with a Travel Itinerary or an unresolved dispute, then we will retain your personal information until the issue is resolved.
There may be other situations where we have legitimate business interests to retain personal information, such as to prevent fraud or protect security of other people interacting with us.
Any Third Party Providers that we engage will keep your personal information stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third party providers, we will take reasonable steps to ensure that they securely delete or return your personal information to us.
We may retain personal information about you for statistical purposes. Where information is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that information.
7. Security of your personal information
We are committed to securing and protecting your personal information, and we make sure to implement appropriate technical and organisational measures to help protect the security of your personal information. We may adopt various policies including anonymisation, pseudonymisation, encryption, password restricted access, and retention policies to guard against unauthorised access and unnecessary retention of personal information in our systems.
Unfortunately, the transmission of your personal information via the internet is not completely secure and although we do our best to protect your personal information, we cannot guarantee the security of your information transmitted to us over the internet and you acknowledge that any transmission is at your own risk.
9. Age Restrictions
You must be 16 years of age or older to use our website and services generally. We do not knowingly collect personal information from individuals under 16 years of age. If you are under that age limit, then please do not use Kaiku or provide any personal information to us. If you are under 18 years of age, then you will be required to have consent of your parent or guardian to access our website and/or services and we will only process the basic information which we require from you for so that you can use our Platform and/or services.
If you are a parent or legal guardian of a child under the applicable age limit or accessing our website and/or services without consent, and you become aware that your child has provided his/her personal information to us, please contact us at firstname.lastname@example.org. If we learn that we have collected personal information of an individual under the age of 16, then we will take all reasonable steps to delete that information from our systems.
10. Your rights and choices
This section explains that you have a number of rights in relation to your personal information.
Under the Data Protection Legislation, you are entitled to certain rights. There are circumstances in which your rights may not apply. You have the right to request that we:
- provide you with a copy of the information we hold about you;
- update any of your personal information if it is inaccurate or out of date;
- delete the personal information we hold about you - if we are providing services to you and you ask us to delete personal information we hold about you then we may be unable to continue providing those services to you;
- restrict the way in which we process your personal information;
- stop processing your data if you have valid objections to such processing; and
- transfer your personal information to a third party.
For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
As explained in section 4, even if you consented to the processing of your personal information for marketing purposes (by ticking the relevant box or by requesting information about services for example), you have the right to ask us to stop processing your personal information for such purposes. You can exercise this right at any time by contacting us. Please note that we reserve the right to charge a fee for responding to requests where we reasonably determine that they are manifestly unfounded or onerous or being made in bad faith.
10. Contacting us
If you have any questions or concerns about how we handle your personal information, please contact by email to email@example.com.
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.