Personal data we collect
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 as follows:
We may collect personal data about you if you participate in any of our research projects. We may collect information such as your name, title, date of birth and gender, contact details such as your email address, telephone number and home address (“Identity Information”), and any other information you provide to us for the purposes of the research (“Research Information”). The information that we collect may vary depending on the nature of the research that we are carrying out, and will be explained to you before you participate in the research. This also covers insight we may request and be provided with by email and/or surveys undertaken by any of our business contacts who we contact for such purposes. We may collect your Identity Information from you directly, or from third-party sources such as LinkedIn and other online platforms.
Where we are carrying out research on behalf of our client, we may only be collecting Research Information and processing it as a data processor on behalf of our client, the data controller. We will inform you if this is the case. In these circumstances, you should refer to the data controller in order to exercise your legal rights as a data subject.
In any other case, if we are carrying out our own research, or are otherwise the instigator of the research, we will be the data controller in respect of the Research Information that we collect.
We may collect personal data about you if you agree to speak at an event organised by us, or generally if you agree for us to hold your details for events we may run in the future for which we think you will be a suitable speaker. We may collect your Identity Information, and also details about your profession and career (“Speaker Information”).
We may collect personal data about you if you are invited to attend an event organised by us. This may include your Identity Information, and whether you are attending the event (“Invitee Information”).
If you attend one of our events, we may collect other information about you through surveys or questionnaires that you participate in at or after the event (“Attendee Information”).
We may collect personal identification information from you when you visit our Site, fill out a form, and in connection with other activities, services, features or resources we make available on our Site (“Site Information”). You may be asked for, as appropriate, name, email address, phone number. You may, however, visit our Site anonymously. We will collect this personal identification information from you only through our Site if you voluntarily submit such information to us. You can always refuse to supply this personally identification information, except that it may prevent you from engaging in certain Site related activities.
We may also collect technical information which includes your 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 our Site, and information about how you use our Site (“Technical Information”).
Special categories of personal data
If you provide it to us, we may receive your passport information in connection with events you are attending or speaking at, but we delete this information as soon as possible after receiving it. We may also become incidentally aware of information such as your sexual orientation or political opinions when researching speakers, but this is not information that we will record, store, or retain in any way.
Beyond this, 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.
How we use collected information and our lawful basis for doing so
Kite Insights collects and uses your personal information for the following purposes, and with the following lawful bases:
- We may use your Identity and Research Information for the purposes of carrying out and publishing the results of our research. Our lawful basis for doing so is your consent.
- We may use your Identity and Speaker Information for the purposes of contacting speakers and arranging and promoting events (this may include posting certain of your Identity and Speaker Information online). Our lawful basis for doing so is our legitimate interests in providing our services to our clients, or promoting or organising events in collaboration with our partners.
- We may use your Identity Information in order to invite you to events that we are arranging and promoting. Our lawful basis for doing so is your consent.
- We may use your Identity and Invitee Information for the purposes of administering and managing events that we organise. Our lawful basis for doing so is our legitimate interests in properly managing such events.
- We may use your Attendee Information in order to develop and improve our events. Our lawful basis for doing so is our legitimate interests in continually evaluating and improving our events.
- We may use your Site and Technical Information in order to administer and manage our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), Our lawful basis for doing so is our legitimate interests in running our business, and for the provision of administration and IT services, and ensuring network security.
- We may use your Technical Information in order to use data analytics to improve our Site, products/services, marketing, customer relationships and experiences. Our lawful basis for doing so is our legitimate interests in keeping our Site updated and relevant, to develop our business and to inform our marketing strategy.
- We may use your Identity Information to send you marketing emails and promote research studies that we have carried out. Our lawful basis for doing so is your consent.
You can ask us to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for other purposes.
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 contact us.
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.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored by us.
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.
Sharing your personal information
We do not sell, trade, or rent you personal information to others.
We may share your personal data with the parties set out below for the purposes set out above.
- We may share your personal data with our clients where we are processing your personal data in connection with services we are providing to them.
- We may also share your personal data with third parties in the course of inviting attendees to events, and for general events management. This could include sharing information with our partners or organisations we are collaborating with in running an event.
- We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers
- We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys.
- We may use professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
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.
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:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers or transfer to other organisations within our group, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers or transfer to other organisations within our group based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
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 will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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.
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Third party websites
You may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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, please contact us.
No fee usually required
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 could refuse to comply with your request in these circumstances.
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 could 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.
Complaints to the ICO
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.
KITE INSIGHTS LTD / / 2 VARDENS ROAD / / LONDON SW11 1RH / / UNITED KINGDOM
Send us an email for more information. This document was last updated on 13 November 2019.