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.
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;
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;
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;
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.
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.
We may collect the following Data, which includes personal Data, from you:
- contact Information such as email addresses and telephone numbers;
- financial information such as credit/debit card numbers;
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:
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.
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@example.com. However, if you do so, you may not be able to use our website or our services further.
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.
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).
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.
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 firstname.lastname@example.org. 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.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
We collect Data in the following ways:
i. data is given to us by you; and
ii. data is collected automatically.
True Sessions Ltd will collect your Data in a number of ways, for example:
To the extent that you access the Website, we will collect your Data automatically, for example:
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:
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:
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).
a. We will use technical and organisational measures to safeguard your Data, for example:
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@example.com.
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.
b.Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
a. You have the following rights in relation to your Data:
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: firstname.lastname@example.org.
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.
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.
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.
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.
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).
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.
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 Inc. - For advertising. https://www.facebook.com/full_data_use_policy
Google AdWords Conversion
Google Inc. - For advertising. https://policies.google.com/privacy
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:
|Facebook Inc.||1601 S. California Ave, Palo Alto, CA 94304, USA|
|Instagram LLC||1601 Willow Road, Menlo Park, CA 94025, USA|
|Twitter Inc.||795 Folsom St., Suite 600, San Francisco, CA94107, USA|
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.
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@example.com. 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 firstname.lastname@example.org. This may limit the service we can provide to you.
How you can complain
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.
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
You may contact True Sessions Ltd by email at email@example.com.
- 15th March 2019