We are committed to safeguarding the privacy of our app users.
This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, "we", "us" and "our" refer to KA Technology. For more information about us, see Section 9.
In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
We do not collect any data from the app. We will only process your personal data if you contact us.
We may process data enabling us to get in touch with you ("contact data").
We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.
Purposes of processing and legal bases
In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is [our legitimate interests, namely communications with our app users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our services and business.
Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Providing your personal data to others
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Retaining and deleting personal data
This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
contact data will be retained for a minimum period of 1 year following the date of the most recent contact between you and us, and for a maximum period of 5 years following that date; and
communication data will be retained for a minimum period of 1 year following the date of the communication in question, and for a maximum period of 5 years following that date.
Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
In this Section 7, we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:
the right to access - you can ask for copies of your personal data;
the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
the right to erasure - you can ask us to erase your personal data;
the right to restrict processing - you can ask us to restrict the processing of your personal data;
the right to object to processing - you can object to the processing of your personal data;
the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.