This privacy policy applies between you, the User of this Website and True Sessions Ltd, the owner and provider of this Website. True Sessions Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any Data collected by us or provided by you in relation to your use of the Website.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions. We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate. Our policy complies with UK law accordingly implemented, including that required by the 1988 UK Data Protection Act, 1995 EU Data Protection Directive and 2018 EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. You can see further information about your rights, and our obligations, at www.ico.org.uk.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Please read this privacy policy carefully.


Definitions and interpretation

In this privacy policy, the following definitions are used: 

Data
Collectively all information that you submit to True Sessions Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies
A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Data Protection Laws
Any applicable law relating to the processing of Personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR
The General Data Protection Regulation (EU) 2016/679;True Sessions Ltd, a company incorporated in England and Wales with registered number 49 whose registered office is at Station Road, Polegate, East Sussex, BN26 6EA;

UK and EU Cookie Law
The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you
Any third party that accesses the Website and is not either (i) employed by True Sessions Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to True Sessions Ltd and accessing the Website in connection with the provision of such services;

Website
The website that you are currently using, www.thekitespot.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.


In this privacy policy, unless the context requires a different interpretation:

  • the singular includes the plural and vice versa.
  • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  • a reference to a person includes firms, companies, government entities, trusts and partnerships;
  • "including" is understood to mean "including without limitation";
  • reference to any statutory provision includes any modification or amendment of it;
  • the headings and sub-headings do not form part of this privacy policy

The scope of this privacy policy

a. This privacy policy applies only to the actions of True Sessions Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
b. For purposes of the applicable Data Protection Laws, True Sessions Ltd is the "data controller". This means that True Sessions Ltd determines the purposes for which and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you: 
- name;
- contact Information such as email addresses and telephone numbers;
- financial information such as credit/debit card numbers;
- in each case, in accordance with this privacy policy.

PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT

a. The law requires us to determine under which bases we process different categories of your personal information and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
b. When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information. We may use it in order to:

  • verify your identity for security purposes
  • sell products to you
  • provide you with our services
  • provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example, to monitor our performance concerning a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to tick a box on our contact form indicating your consent. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally.

We may aggregate it in a general way and use it to provide class information, for example, to monitor the performance of a particular page on our website. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us [email protected]. However, if you do so, you may not be able to use our website or our services further.

Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

THIS WEBSITE COLLECTS AND USES PERSONAL DATA FOR THE FOLLOWING REASONS:

Site visitation tracking
Like most websites, this site uses Google Analytics and other cookies to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although Google Analytics records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. Google Analytics also records your computer’s IP address, which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor (see section 7.0 below).

Google Analytics makes use of cookies, details of which can be found on Google’s developer guides. For more information on the cookies used on this site, please view our Terms and conditions of use.

Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 7.0. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 7.0 below). The email address that you submit will not be stored within this website’s database or in any of our internal computer systems.

Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list or until your interactions via Mailchimp are deemed inactive. You can remove your details from the newsletter list by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email by contacting [email protected] When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

While your email address remains within the MailChimp database, you will receive periodic (approximately once per month) newsletter-style emails from us, as well as important service messages relating to products and services that you have already obtained from us, for example, your website.

Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us to reply with the information you need. We record your request and our reply to increase the efficiency of our business. We keep personally identifiable information associated with your messages, such as your name and email address to be able to track our communications with you to provide a quality service.

Complaining
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.

How we collect Data

We collect Data in the following ways: 
   i. data is given to us by you; and
   ii. data is collected automatically.

Data that is given to us by you

True Sessions Ltd will collect your Data in a number of ways, for example: 

    • when you contact us through the Website, by telephone, post, e-mail or through any other means;
    • when you register with us and set up an account to receive our products/services;
    • when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
    • when you enter a competition or promotion through a social media channel;
    • when you make payments to us, through this Website or otherwise;
    • when you use our services;
      in each case, in accordance with this privacy policy.

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example: 

    • we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
    • we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Our use of Data

a. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons: 

    • internal record keeping;
    • improvement of our products/services;
    • transmission by email of marketing materials that may be of interest to you;
    • contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.
b. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
c. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:  

    • soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you were opt-out.
    • for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
    • if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

d. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
e. We may use your Data to show you True Sessions Ltd adverts and other content on other websites. If you do not want us to use your data to show you True Sessions Ltd adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).

Keeping Data secure

a. We will use technical and organisational measures to safeguard your Data, for example: 

    • access to your account is controlled by a password and a user name that is unique to you.
    • we store your Data on secure servers.
    • all billing information is collected and handled by our chosen payment handler, Stripe. True Sessions Ltd. does not and will not ever directly handle or store any billing information. See https://stripe.com/gb/checkout/legal for Stripe’s Terms and Conditions.

b. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected].
c. If you want detailed information from 'Get Safe Online' on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

a. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
b.Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

a. You have the following rights in relation to your Data: 

    • Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    • Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
    • Right to erase - the right to request that we delete or remove your Data from our systems.
    • Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
    • Right to data portability - the right to request that we move, copy or transfer your Data.
    • Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

b. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected].
c. 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/.
d. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes in business ownership and control

a. True Sessions Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of True Sessions Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
b. We may also disclose Data to a prospective purchaser of our business or any part of it.
c. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

COOKIES POLICY

a. This Website may place and access certain Cookies on your computer. True Sessions Ltd uses Cookies to improve your experience of using the Website and to improve our range of services. True Sessions Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
b. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
c. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling True Sessions Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
d. This Website may place the following Cookies:

Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

NOTICE ON WEB ANALYSIS, TRACKING TECHNOLOGIES & SOCIAL MEDIA PLUG-INS

a. True Sessions Ltd uses Web analysis tools to get information about how people use our Website and Internet offerings. These tools are usually provided by third parties. Typically, the information for this purpose is captured with cookies and sent to a third-party server. Depending on the provider, these servers are sometimes in other countries.
b. The transfer of information is done by using shortened IP addresses, which prevents the identification of individual end-user devices. Your IP address is not linked with other data from these third parties. Any onward transfer by third parties will only be based on legal regulations or as part of a data processing service agreement.
c. We use retargeting technologies on our Internet websites. This lets us appeal to users of our Internet websites with advertising on third-party Internet websites. The advertisements displayed on Internet websites you visit is based cookies in your browser, a cookie ID and an analysis of the previous usage.
d. We use the following third-party cookies and tracking technologies: 

Google Tag Manager
Google Inc. - For advertising. https://policies.google.com/privacy

Facebook Pixel
Facebook Inc. - For advertising. https://www.facebook.com/full_data_use_policy

Google AdWords Conversion
Google Inc. - For advertising. https://policies.google.com/privacy

Google Analytics
Google Inc. - For Web Analytics. https://policies.google.com/privacy

e. We use social plug-ins on our websites. All of the plug-ins we use are set up with two-click functionality. They are only activated if you click on the icon. Plug-ins can be recognised by their social network logos.
f. When you open one of our websites that has an activated plug-in, your browser will create a direct connection to the provider’s servers. The content of the plug-in is sent directly from the provider to your browser and integrated into the site. By integrating the plug-in, certain information is sent to the third party and saved by them.
g. If you are not a member of the social network in question, your IP address may still be captured and saved by the network via the social plug-in. If you are already logged into the social network, the third parties can immediately link your visit to our websites to your personal profile in the social network. If you interact with the plug-ins, for example with the “Like”, “+1”, “Twitter” or “Instagram” buttons, the corresponding information will also be sent directly to a server at the third party and saved there. The information is also published on the social network, in your Twitter or Instagram account and then shown to your contacts. For more information about the purpose and scope of the data capture, the further processing and use of the data by the third party, and the related rights and settings options to protect your privacy, please look at the data privacy statements of the third parties themselves.
h. If you would like to prevent Google, Facebook, Twitter or Instagram from linking your personal information captured on our websites with the social networks in question, you need to log out of that social network before visiting our website. You can completely prevent plug-ins from being loaded using special add-ons for your browser.
i. We use the following social media plugins: 

SOLUTIONPROVIDERADDRESS
FacebookFacebook Inc.1601 S. California Ave, Palo Alto, CA 94304, USA
InstagramInstagram LLC1601 Willow Road, Menlo Park, CA 94025, USA
TwitterTwitter Inc.795 Folsom St., Suite 600, San Francisco, CA94107, USA

General

a. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
b. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
c. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
d. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

HOW TO REQUEST YOUR PERSONAL INFORMATION

Access to your personal information
At any time you may review or update personally identifiable information that we hold about you and to obtain a copy of any information that is not provided on our website you may send us a request at [email protected] Requests for data will be processed within 20 working days, in accordance with the GDPR.

Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at [email protected]. This may limit the service we can provide to you.

How you can complain
If you are not happy with our privacy policy or if have any complaint then you should tell us by email.

DATA BREACHES

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors. This will be reported to any and all relevant persons/authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

DATA CONTROLLER

The data controller of this website is: True Sessions Limited, a UK Private Limited Company with company number: 10819366 
The registered office is: 49 Station Road, Polegate, East Sussex, BN26 6EA

Changes to this privacy policy

True Sessions Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact True Sessions Ltd by email at [email protected]

Change Log

- 15th March 2019