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Privacy Policy

Last Updated: 16/09/2024

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Welcome to KLS Signature. We are committed to protecting your privacy and ensuring the responsible management of your personal data. This Privacy Policy explains how we collect, use, share, and protect your personal information, your rights regarding your data, and how the law protects you.

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This document is organized in a layered format for your convenience. You can jump to specific sections using the headings below. For a clearer understanding of the terms used in this policy, please refer to the Glossary at the end of this document.

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Sections:

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  1. Important Information and Who We Are

  2. How We Collect Your Personal Data

  3. The Data We Collect About You

  4. How We Use Your Personal Data

  5. Disclosures of Your Personal Data

  6. International Transfers

  7. Data Security

  8. Data Retention

  9. Your Legal Rights

  10. Glossary

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1. Important Information and Who We Are

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This privacy notice provides comprehensive information on how KLS Signature manages and processes your personal data when you use our services. This includes data you provide when interacting with our website, subscribing to our newsletter, purchasing our products or services, or participating in competitions.

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Controller

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KLS Signature is the data controller responsible for your personal data. We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy policy or wish to exercise any of your legal rights, please contact our DPO using the details provided below.

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Contact Details

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Third-Party Links

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Our 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. We encourage you to read the privacy policy of every website you visit.

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2. How We Collect Your Personal Data

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We use various methods to collect data from and about you, including:

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  • Direct Interactions: You may provide personal data by filling out forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data when you:​​

    • Subscribe to our services or publications;

    • Request marketing materials to be sent to you;

    • Enter a competition, promotion, or survey;

    • Provide us with feedback.

  • Create an account on our website;

  • Apply for our products or services;

  • Automated Technologies or Interactions: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.

  • Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources, which helps us enhance our services and interactions with you.

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3. The Data We Collect About You

Personal data, or personal information, refers to 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).

Types of Data We Collect:
 

  • Identity Data: Includes first name, last name, username or similar identifier, title, and date of birth.

  • 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 services you have purchased from us.

  • Technical Data: Includes IP address, browser type and version, time zone setting, 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 your username and password, purchases or orders made by you, your interests, preferences, 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 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 under the law, as this data does not directly or indirectly reveal your identity.
Special Categories of Personal Data: 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).

4. 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:
 

  • Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you.

  • Legitimate Interests: 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.

  • Compliance with a Legal Obligation: Where we need to comply with a legal obligation.

  • Purposes for Which We Will Use Your Personal Data:

  • Below is a description of the ways we plan to use your personal data and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above:
 

  • Internal Third Parties: Other companies within the KLS Signature Group acting as joint controllers or processors and who are based in different locations and provide IT and system administration services and undertake leadership reporting.

  • External Third Parties: Service providers acting as processors based in different jurisdictions who provide IT, system administration services, payment processing, and delivery services; professional advisers including lawyers, bankers, auditors, and insurers based who provide consultancy, banking, legal, insurance, and accounting services; and regulatory authorities and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
     

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.

6. International Transfers

Your personal data may be transferred to and processed in countries outside of the European Economic Area (EEA). This might occur when our servers, service providers, or partners are located in countries outside the EEA.
When we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
 

  • Adequacy Decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • Standard Contractual Clauses (SCCs): Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

  • Binding Corporate Rules (BCRs): Where applicable, we implement BCRs approved by competent data protection authorities to protect data transferred between entities within our corporate group.
     

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. These measures include both technical solutions (e.g., encryption, firewalls) and organizational measures (e.g., access control procedures, data protection policies).
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 are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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 unauthorized 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.
In some circumstances, we may anonymize 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.

9. Your Legal Rights

Under data protection laws, you have specific rights regarding your personal data. KLS Signature is committed to ensuring you can fully exercise these rights. Your rights include:
 

  • Right to Access: You have the right to request access to the personal data we hold about you. This enables you to receive a copy of your data and verify that we are processing it lawfully.

  • Right to Rectification: You have the right to request correction of any incomplete or inaccurate personal data that we hold about you. We may need to verify the accuracy of the new data you provide to us.

  • Right to Erasure (Right to be Forgotten): You can request the deletion or removal of your personal data where there is no compelling reason for us to continue processing it. This right is applicable when, for example, the data is no longer necessary for the purposes for which it was collected, or if you withdraw consent on which the processing is based.

  • Right to Restrict Processing: You have the right to request the suspension of processing of your personal data in certain circumstances. This includes if you want us to establish the data's accuracy, where our use of the data is unlawful but you do not want it erased, or if you need us to retain the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.

  • Right to Data Portability: You have the right to request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format. This right applies only to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Right to Object: You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party), but there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

  • Right to Withdraw Consent: Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of any processing carried out before you withdraw your consent.

  • Right to Lodge a Complaint: If you believe that we have infringed upon your rights, you have the right to lodge a complaint with a supervisory authority, particularly in the country of your residence, workplace, or location of the alleged infringement.


To exercise any of these rights, please contact us using the details provided in this policy. 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 try to respond to all legitimate requests within one month. Occasionally, it may take us longer if your request is particularly complex or if you have made several requests, in which case we will notify you and keep you updated.

10. Glossary

This section defines key legal terms to help you understand your rights under this policy and our corresponding obligations:
 

  • Personal Data: Information that identifies you as an individual or relates to an identifiable individual. Examples include your name, email address, phone number, and any other data that can be used to identify you directly or indirectly.

  • Processing: Any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination, restriction, erasure, or destruction.

  • Controller: The natural or legal person, public authority, agency, or other body that determines the purposes and means of the processing of personal data. In this context, KLS Signature acts as the controller of your personal data.

  • Processor: A natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller. This could include service providers who process data according to our instructions.

  • Data Subject: Any individual who can be identified, directly or indirectly, via an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
     

This glossary is intended to provide you with comprehensive insights and information, ensuring that your interactions with KLS Signature are conducted securely, in compliance with legal standards, and with the utmost respect for your privacy rights.

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