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Customer/Vendor Data Protection Statement
Kinly is committed to protecting the personal data of the visitors of this website (Kinly.com), and our customers/vendors and any third party or individual who interacts with Kinly. We want to provide a safe, secure user experience.
This customer/vendor data protection statement (the ‘Statement’) explains what to expect from Kinly when we collect certain types of information about you.
Scope of Statement
This Statement describes the types of personal data that companies within the Kinly group (as specified below, collectively ‘Kinly’, ‘we’, ‘us’) collect.
It also describes how we use personal data, with whom we share personal data, how long we store your personal data, whether we transfer it to third countries and the rights you have as a data subject.
Kinly is a controller under the General Data Protection Regulation (‘GDPR’) with regard to your personal data.
Visitors to this website
When you visit kinly.com we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
With respect to Kinly’s mailing list, we use Hubspot to store personal data from people who request information from this website via forms and to deliver marketing information to people who opt in to our mailing list. For more information, see Hubspot's privacy notice.
What types of personal data do we process?
Kinly processes the following personal data of customers, vendors and/or third parties:
Name, business e-mail address, business postal address, business telephone number, occupation/title, name of organization, department, industry, date of agreement, business facsimile number, VAT numbers, tax identification numbers, bank details.
Kinly will maintain personal data in a manner that ensures it is accurate, complete and up-to-date.
Kinly will not collect personal data if such collection is prohibited under the applicable data protection laws.
Purpose and legal basis for processing
Personal data of customers, vendors and/or third parties may be processed for the purposes of:
- Managing commercial relationships, order fulfillment, payment and invoicing for products and services, contacting customer/vendors;
- Selling products and providing our services;
- Carrying out promotional operations, direct marketing;
- Fraud detection and prevention;
- Security;
- Complying with legal obligations and/or regulatory investigations, assisting the Company in the context of any litigation or arbitration, including employment tribunal proceedings, and protecting Kinly against injury, theft, legal liability, fraud, abuse or other misconduct;
- Managing transactions (e.g., mergers or acquisitions);
- Managing our operations, including the operation and monitoring of the proper functioning and security of our IT systems;
- Managing health and safety incidents; and
- Managing product deliveries and shipments.
- The individual has given consent for the processing;
- The processing is necessary to perform an agreement with you;
- The processing is necessary to comply with a legal obligation to which we are subject; and
- The processing is necessary for the purposes of the legitimate interests of Kinly or a third party, except where such interests are overridden by the interests and fundamental rights and freedoms of an individual. Kinly’s legitimate interests in any case consist of the purposes stated above.
Kinly shall process personal data in accordance with applicable data protection laws and only for limited, explicit and legitimate purposes. We will not use personal data for any purpose that is incompatible with the purpose for which it was initially collected unless you provide us your prior consent for further use. Personal data of customers/vendors may be processed on the basis of the following legal grounds:
- The individual has given consent for the processing;
- The processing is necessary to perform an agreement with you;
- The processing is necessary to comply with a legal obligation to which we are subject; and
- The processing is necessary for the purposes of the legitimate interests of Kinly or a third party, except where such interests are overridden by the interests and fundamental rights and freedoms of an individual. Kinly’s legitimate interests in any case consist of the purposes stated above.
Do we share your personal data with third parties?
Within Kinly, your personal data will only be accessible for Kinly employees who, by virtue of their position, need access to your personal data in order to achieve the above purposes.
We may also share your personal data with third parties. This may be necessary to allow us to properly perform the agreement to which you are a party, or because we are subject to a statutory obligation to share your personal data.
When we share your personal data with third parties who process personal data on our behalf (data processors), we will ensure that your personal data are protected in accordance with the GDPR and the terms of this Statement through the data processing agreements we have concluded with these third parties.
Kinly shares your personal data with the following third parties: suppliers of IT-systems, processors, accountants, insurers, external legal counsel, regulators, affiliated companies, third-party service providers, advertising partners.
How long do we store personal data?
Kinly does not store personal data longer than necessary for the purposes for which it is processed. For some data we must observe mandatory retention periods, for instance due to tax legislation. In general, we aim to retain customer/vendor personal data for no longer than two (2) years, unless a longer or shorter mandatory retention period applies or retention of the specific personal data is necessary.
Any personal data held by us for people who request information will be kept until you submit a request to remove your data. In any case your personal data will never be retained longer than Kinly is permitted by the data protection laws and/or statutory local retention periods.
Do we transfer your personal data?
Kinly’s international footprint involves the transfer of personal data to other group companies or third parties, which may be located outside the EEA, including the United States. We are located in United Kingdom, Norway, Netherlands and Singapore. Hosting and storage of your data takes place in data centers located in the United Kingdom, Netherlands, Norway and the USA. We use 3rd party suppliers to store this information and have an agreement with them that protects your information.
We will ensure that when personal data is transferred to third countries that do not have an adequate level of protection, Kinly will implement appropriate safeguards, namely Standard Contractual Clauses, to adequately protect the personal data.
We have also implemented Standard Contractual Clauses to cover international data transfers between companies of Kinly.
For additional information regarding the safeguards Kinly has implemented, please contact us at privacy@kinly.com.
What are your rights?
Under the GDPR, you have a number of rights in relation to your personal data. These rights are:
- the right to access your personal data that we process
- the right to rectify your personal data if they contain factual inaccuracies
- the right to erase your personal data
- the right to limit the processing of your personal data
- the right to data portability
- the right to object to the processing of your personal data
- the right to withdraw your consent to the processing of your personal data
If you wish to exercise these rights, you can submit a request to us at privacy@kinly.com. We may require proof of identity.
If you are not satisfied with the way in which we handle your personal data, you have the right to lodge a complaint with the relevant supervisory authority. Please consult https://edpb.europa.eu/about-e... for an overview of the European Data Protection Authorities.
Contact and privacy statement changes
If, at any time, you have questions or concerns about our privacy commitment, please feel free to email us at privacy@kinly.com.
This Statement was last updated on the 27 November 2023.