1.2. Koypo Laboratories Ltd – Privacy Notice.
Koypo Laboratories Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
By ‘We’ or ‘Us’, we mean Koypo Laboratories Ltd (“Koypo Laboratories”). By “You” we mean the customer or individual who has accessed our service or the individual to whom data relates that we process or control. We are Registered in England and Wales. Registered Address: United House, North Road, London, England, N7 9DP. Company Number: 10024201. ICO registration number: ZA176874.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Koypo Laboratories Ltd (“Koypo Laboratories”) collects and processes your personal data through your use of this website, including any data you may provide through this website or any data that you have provided to third party companies wherein you consented to the passing and processing of data by Koypo Laboratories.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Koypo Laboratories is the controller and is responsible for any of your personal data it controls and processes.
OUR CONTACT DETAILS
Our full details are:
Full name of legal entity: Koypo Laboratories Ltd
Email address: [firstname.lastname@example.org]
Koypo Laboratories Ltd,
N7 9 DP.
Telephone number: 0203 633 0836
YOUR RIGHT TO COMPLAIN TO THE SUPERVISRY AUTHORITY
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Please see our Complaint Policy.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks such as Facebook, Tabool, Outbrain, based outside of the EU; and
(c) search information providers such as Google based outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have provided us consent to control or process your data for direct marketing purposes.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|Performance of a contract with you
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate interests (to develop our products/services and grow our business)
Consent means you giving a freely informed choice for us to contact you in relation to the service we wish to offer and how we use your data. We will make sure that consent is appropriate and offers you a real choice of control over how we will use your data.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us at email@example.com
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or to third parties that work with us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Koypo Laboratories for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or contacting us via firstname.lastname@example.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service engaged.
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things such as remembering your preferences, recording what you have put in your shopping basket, and counting the volume of people accessing the website.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email email@example.com
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Selected third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy.
We work carefully with selected data processing companies.
We may also disclosure your information with:
- HM Revenue & Customs, Claims Management Regulator, Regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Accountants, Solicitors, Compliance Consultants and other like services acting as processors, based in the United Kingdom who require reporting of processing activities in certain legal and compliance circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by emailing us at firstname.lastname@example.org. By law we have to keep certain information about our customers and this data will be held solely and securely for those legal purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information. However, an erasure request may be partially declined. In the event a complaint has been made, coupled with an erasure request, we will maintain records relating to the complaint, including basic information such as name, and telephone number. In the event that you do not wish to be contacted by us, we are required to maintain a log of this request, withholding applicable data to ensure we no longer contact you further.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, email us at email@example.com
SUBJECT ACCESS REQUEST
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We will respond to your request within one month of receiving your request. We will inform you of the third parties to whom your data has been disclosed.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8.1. The Right to be Informed
The right to be informed encompasses our obligation to provide ‘fair processing information’, typically through a privacy notice. It emphasises the need for transparency over our uses of personal data.
The information we will supply relating to the processing of personal data must be:
- Concise, transparent, intelligible and easily accessible;
- Written in clear and plain language, particularly if addressed to a child; and
- Free of charge.
The use of data, including how we protect and store data, will be made readily available to individuals through our privacy notice on our website.
What information must be supplied?
The below summarises the information we should supply to individuals and at what stage:
- We need to provide full contact details of our firm (and where applicable, the controller’s representative) and the data protection officer;
- We need to detail the purpose of the processing and the legal basis for the processing;
- We need to include the legitimate interests of the controller or third party, where applicable;
- List the categories of personal data;
- We need to detail any recipient or categories of recipients of the personal data;
- We need to include details of transfers to third country and safeguards;
- We need to include our retention period or criteria used to determine the retention period;
- We need to include the existence of each of data subject’s rights;
- We need to inform the customer of their right to withdraw consent at any time, where relevant;
- We need to inform the customer of their right to lodge a complaint with a supervisory authority;
- We are to inform the customer of the source the personal data originates from and whether it came from publicly accessible sources;
- Whether the provision of personal data part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data; and
- We are to include the existence of automated decision making, including profiling and information about how decisions are made, the significance and the consequences.
8.2. The Right to Access
The data subject shall have the right to obtain from the controller confirmation as to whether personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) where the personal data are not collected from the data subject, any available information as to their source.
(h) Information on the existence of automated decision making, including profiling, and providing meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data is transferred to a third country outside the EEA or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
Such safeguards include:
o A legally binding and enforceable instrument between public authorities or bodies; and
o Binding corporate rules in accordance with Article 47.
When requested, the controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs.
Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others.
8.3. The Right to Restrict Processing
Under the DPA, individuals have a right to ‘block’ or suppress processing of personal data. The restriction of processing under the GDPR is similar, as detailed in Articles 18 (Right to restriction of processing) and 19 (Notification obligation regarding rectification or erasure of personal data or restriction of processing) respectively.
When processing is restricted, we are permitted to store the personal data, but not process it further. We can retain just enough information about the individual to ensure that the restriction is respected in future. This needs to be applied and communicated to each data processor where applicable and documented where appropriate.
When does the right to restrict processing apply?
We are required to restrict the processing of personal data in the following circumstances:
- Where an individual contest the accuracy of the personal data, we should restrict the processing until we have verified the accuracy of the personal data. We would do this by asking the individual to confirm the information is correct and where required update accordingly.
- Where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our organisation’s legitimate grounds override those of the individual. This can only be confirmed by way of evidenced consent from the individual or for the purpose of criminal proceedings.
- When processing is unlawful, and the individual opposes erasure and requests restriction instead, we are obliged to ensure this request is documented and the data collected is only used for the intent on which it was originally collected for, and not process it further.
- If we no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim. We would ask the individual to submit a DSAR and release the data upon receipt and in accordance with the DSAR procedure.
- We may need to review procedures to ensure we are able to determine where you may be required to restrict the processing of personal data.
- If we have disclosed the personal data in question to third parties, we must inform them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so. We must inform individuals when we decide to lift a restriction on processing.
8.4. The Right to Object
Individuals have the right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling); and
- Processing for purposes of scientific/historical research and statistics.
How to comply with the right to object?
If we process personal data for the performance of a legal task or our organisation’s legitimate interests Individuals must have an objection on “grounds relating to his or her particular situation”.
We must stop processing the personal data unless:
- We can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
- the processing is for the establishment, exercise or defence of legal claims.
We must inform individuals of their right to object “at the point of first communication” and in our privacy notice.
This must be “explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information”.
If we process personal data for direct marketing purposes
We must stop processing personal data for direct marketing purposes as soon as we receive an objection. There are no exemptions or grounds to refuse.
We must deal with an objection to processing for direct marketing at any time and free of charge.
We must inform individuals of their right to object “at the point of first communication” and in your privacy notice.
This must be “explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information”.
If we process personal data for research purposes
Individuals must have “grounds relating to his or her particular situation” in order to exercise their right to object to processing for research purposes.
If we are conducting research where the processing of personal data is necessary for the performance of a public interest task, we are not required to comply with an objection to the processing.
If our processing activities fall into any of the above categories and are carried out online:
We must offer a way for individuals to object online.