Privacy Policy
Contact details
Email: Karen@kogdigital.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
· Names and contact details
· Addresses
· Pronoun preferences
· Occupation
· Payment details (including card or bank information for transfers and direct debits)
· Transaction data (including details about payments to and from you and details of products and services you have purchased)
· Usage data (including information about how you interact with and use our website, products and services)
· Information relating to compliments or complaints
· Website user information
We collect or use the following personal information for the operation of client or customer accounts:
· Names and contact details
· Addresses
· Purchase or service history
· Account information, including registration details
· Information used for security purposes
· Marketing preferences
· Technical data, including information about browser and operating systems
We collect or use the following personal information for research or archiving purposes:
· Names and contact details
· Purchase or client account history
· Website and app user journey information
· IP addresses
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Identification documents
· Client account information
· Any other personal information required to comply with legal obligations
· Criminal offence data
We collect or use the following personal information to protect client welfare:
· Names and contact information
· Client account information
· Health and well-being information
· Emergency contact details
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Address
· Payment details
· Account information
· Purchase or service history
· Call recordings
· Photographs
· Customer or client accounts and records
· Financial transaction information
· Information relating to health and safety (including incident investigation details reports and accident book records)
· Correspondence
KOG Digital customer privacy notice
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights, which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information, such as details about where we get personal information from and who we share personal information with. There are some exemptions, which means you may not receive all the information you ask for. You can read more about this right here.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
· Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
· Your right to object to processing - You have the right to object to the processing of your data. You can read more about this right here.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and, in any event, within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
· Consent - we have permission from you after we give you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Our legitimate interest in collecting or using personal information lies in enhancing our clients' experience by tailoring our services to meet their specific needs and improving our offerings. This provides a significant benefit, ensuring clients receive personalised and efficient support, which helps them achieve their goals. We carefully balance our need to process data with the potential impact on individuals, respecting their privacy and data protection rights at all times. Our approach prioritises delivering value and maintaining trust in our services without placing our needs above our clients.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
· Consent - we have permission from you after we give you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Our legitimate interest in collecting or using personal information to operate client or customer accounts lies in providing efficient and tailored services. By managing client information accurately, we ensure effective communication, personalised support, and the smooth operation of accounts. The benefits include improved service delivery and a better client experience. We carefully balance our need to process data with the potential impact on individuals, ensuring their privacy and data protection rights are always respected. Our approach prioritises delivering value and maintaining trust in our services without placing our needs above those of our clients.
Our lawful bases for collecting or using personal information for research or archiving purposes:
· Consent - we have permission from you after we give you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Our legitimate interest in collecting or using personal information for research or archiving purposes lies in enhancing our services and understanding client needs more effectively. By analysing historical data, we can identify trends and improve our offerings, ensuring a better client experience. We balance our data processing needs with individuals' privacy rights, ensuring that our research benefits do not outweigh the importance of their personal data protection.
Our lawful bases for collecting or using personal information to comply with legal requirements:
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to protect client welfare are:
· Consent - we have permission from you after we give you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Our legitimate interest in collecting or using personal information to protect client welfare is to ensure that we can respond effectively to any health or safety concerns. By understanding the specific needs and circumstances of our clients, we can provide tailored support and swift intervention when necessary. This benefits our clients by safeguarding their well-being and enhancing their overall experience with our services. We take care to balance our data processing activities with the privacy rights of individuals, ensuring that their welfare is prioritised without unnecessary risk to their personal information.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Consent - we have permission from you after we give you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Our legitimate interest in collecting or using personal information for dealing with queries, complaints, or claims lies in resolving issues efficiently and improving our services. By handling queries and complaints thoroughly, we can provide better support and enhance client satisfaction. This approach benefits both our clients and our organisation by ensuring concerns are addressed swiftly and effectively. We carefully balance this with the privacy rights of individuals, ensuring that their data is protected and used responsibly without placing our needs above theirs.
Where do we get personal information from
· Directly from you
· Publicly available sources
· Suppliers and service providers
How long do we keep information?
This section outlines our data retention policies and procedures designed to ensure compliance with legal obligations regarding the retention and deletion of personal data.
Personal data we process for any purpose shall not be kept longer than necessary for that purpose.
We will retain your personal data as follows:
Any personal data you have submitted to us will be retained for as long as you remain a client of KOG Digital. This personal data is retained to provide our services to you.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation or to protect your vital interests or the vital interests of another person.
Who do we share information with
· Professional or legal advisors
· Regulatory authorities
· Organisations we’re legally obliged to share personal information with
· Publicly on our website, social media or other marketing and information media
· Suppliers and service providers
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Last updated
30 October 2024