LEGAL

Privacy Policy

Introduction

At Kindana & Company, our mission is to give people more control over their personal data. We will never, ever sell your personal data for use outside of the function of Kindana. Our team only ever has access to your data if you require us to. We operate a zero trust framework so none of our team have access by default.

The idea of a privacy policy that’s difficult to understand goes against the essence of Kindana. We think companies should be transparent about how they handle personal data, and it shouldn’t take ages to read the key points. In that spirit, we’ve broken down the key takeaways from our privacy policy below. If you’d like to read the full thing, it’s just below this next section.

Key takeaways:

  1. You are in control of your personal data and how it’s shared and used.
  2. You can ask us to delete your data at any time.
  3. We use cookies for the purposes of our site functioning and improving our user experience. There’s more detail on this below and in our Cookie policy.
  4. Our data handling processes are compliant with the highest data protection regulations in both the UK and EU.
  5. All of the data held within Kindana is subject to the highest security standards and stored in the UK, and we are Cyber Essentials compliant.
  6. We are responsible for the data that we process.
  7. We are fully accountable to the Information Commissioner’s Office (ICO).

Our full privacy policy is below. If you have any further questions, please do get in touch, we’d love to hear from you.

The fine print

Kindana Ltd. is a company registered in England and Wales, and our company number is 13337758. Importantly, we are also registered with the Information Commissioner’s Office. Our registration number is ZB077469. We’re a UK-based company, and our registered office is 7 Bell Yard, London, WC2A 2JR.

For the purposes of this Privacy Policy, personal data is defined as any information which may directly or indirectly relate to an identified or identifiable natural person. The data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier. Such identifiers include location data, name, an online identifier, identification number, or to one or more factors specific to the physical, physiological, genetic, mental, commercial, cultural or social identity of that natural person (the “Personal Data”).

This Privacy Policy applies to personal data processed by Kindana in our business, including on our website and other online or offline offerings (a “Service” or collectively, the “Services”). Kindana enables the visitors of its site www.kindanaconsulting.com to be in control of the use of their personal data. We note that Kindana acts as a ‘data controller’ and therefore are responsible for the personal data that they process. This privacy policy explains how Kindana processes, stores and protects this personal data, as well as what your rights are as a user under current data protection legislation.

The responsible use of personal data and consumer rights are two areas that we champion. As such, all of our data processing operations are in strict compliance with the EU General Data Protection Regulation (“GDPR”) (specifically but not limited to Article 6(1) (b) to (f) and Article 28).

What kind of personal data is processed and for what purpose?

Usage data

When you, or others, share your personal details with us it is with the objective of creating an account so that we may deal with you to provide our services. Firstly, the data processed by the ‘data controller’ (Kindana) is primarily the information needed to create an account and identification of you to verify this where necessary. In order to better understand their customers, Kindana may also collect anonymised data in surveys and other feedback methods. This helps us improve our service by tailoring our developments.

Lawful basis

Our lawful basis for processing your personal data, as required by data protection legislation, is our contract with our users. That contract is as set out in our terms and conditions. If we cannot process your personal data as set out in this notice, we cannot provide you with our service. We also do not currently process any special category data.

Cookies

Kindana uses cookies to facilitate proper site function and to improve our website and service. Cookies are text files which are downloaded to your device when you visit a website, and there are many different types.

Some of the cookies that we use respond to the actions of our users, such as remembering their privacy or cookie preferences. While you can choose to block this type of cookie, it would mean that parts of our website wouldn’t function properly. These cookies do not store any personally identifiable information. You can deactivate or restrict cookies at any point by changing the settings of your web browser, and cookies that are already stored can be deleted at any time. 

Analytics

We use Google Analytics and other service providers to collect information regarding visitor behaviour and demographics to improve our services and user experience. This information is not used to directly identify anyone. For more information about Google Analytics, please visit www.google.com/privacy/partners/. You can also choose to opt out at any time. To do this, please visit https://tools.google.com/dlpage/gaoptout.

By using our services you agree to our terms of service, and as laid out above, to the collection of website usage data and to the use of analytics cookies.

Contact us procedure

Our contact us procedure is found below.

Access and disclosure to third parties

Kindana does not sell, and has never sold, the personal data of our customers. We must note however that we may be obliged to share or disclose your personal data when required by law or regulatory authorities.

We use a select number of trusted external service providers for certain data analysis, processing and/or storage offerings. Here we mean companies that help us provide services you use, and need to process details about you for this reason. We share as little information as we possibly can. 

Information collected from other sources

We will use Google Analytics to assess how users are interacting with our site; although we will not collect or track any personal information from this.

Notice regarding third-party websites

The Services may contain links to other websites, and other websites will reference or link to our website or other Services. It must be noted that these other websites are not controlled by Kindana and we encourage our users to read the privacy policies of each website and application with which they interact. While we do our best, we do not always screen, approve or endorse and are therefore not responsible for the privacy practices or content of such other websites or applications. As such, visiting these other websites or applications is at your own risk. 

However, where Kindana may work with third parties, this is outside of the realm of Kindana’s responsibility with regards to your personal data. Any breach of their contract with you is the liability of the third party, and not of Kindana. Please notify us at Kindana if you suspect that any third party is using your data outside of this description and we will take the necessary steps.         

Duration of processing

All data specified as above will be retained for as long as is necessary for the purpose(s) for which we originally collected it and to provide the Kindana service(s). We may also retain information as required by law.

You may at any time ask us to delete your data, or to pause the sharing of it for any reason.

Data storage

Kindana stores all of its data in the United Kingdom, with a back up in the EU. We use GSuite as our cloud solution provider for all our storage related to our platform, or Galaxkey where dealing with highly sensitive material which is accredited by the National Cyber Security Centre (NCSC).

We will not transfer your personal information outside the European Economic Area (EEA). The only circumstances in which users’ data may be transferred outside of the EEA is if the user is based outside the jurisdiction and downloads the data there.

You may be able to access your own registration details over the Internet from locations abroad including outside of the EEA. This Privacy Notice only covers processing undertaken by Kindana and does not apply to any processing which may be carried out by your own Internet service provider..

We want to communicate with you

Apart from the necessary emails for our service to function, like the email verification email, you have full control over whether you receive emails. You can easily opt out of marketing emails, unsubscribe free of charge, or delete your account if you no longer want to receive emails from Kindana.

Your data is yours alone: your rights

At Kindana we strongly believe that people should be fully informed of their rights, so that they can act upon them should they wish to.

When it comes to your personal data, thanks to GDPR and the Data Protection Act (2018) you have several rights that give you more control.

  1. Right to access – You have a right to ask for the personal data that we hold about you. We will provide you with your data within 30 days. If we may take longer, we will let you know and explain the reasons for the delay. We will not charge you for such a request, unless we reasonably consider your request to be excessive or repetitive. We also reserve the right to refuse a request if we reasonably consider it unfounded, repetitive or excessive.
  2. Right to be informed – The notice provides the information you need about how we collect and use your data. If you require any further information, please contact us
  3. Right to rectification – If you consider that any information we hold is inaccurate, please let us know and we will take steps to rectify it.
  4. Right to erasure – In certain circumstances, you have the right to have personal data that we process blocked, erased and destroyed.
  5. Right to object and restrict – You can ask for your processing of your personal data to be restricted, for example for marketing purposes. You can also object to the processing of your data entirely but this will affect the service we are able to offer.
  6. Right to portability – You can request your data to be “ported” to another platform, in certain circumstances.

You should note that these rights are not absolute and can be restricted in certain circumstances.

You may also withdraw your consent for us to process your personal data at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of Kindana and/or Services. You further agree that Kindana shall not be held liable with respect to any loss and/or damage to your personal data if you choose to withdraw consent.

Please contact us if you have any further questions. Our data protection director can be contacted at hello@kindana.co  or you can contact us by post at our registered office, found at the top of this document.

Further information about your rights are available on the Information Commissioner’s Office website: https://ico.org.uk/make-a-complaint/

Data Protection Officer

Kindana has a Data Protection Lead, rather than a Data Protection Officer, as we do not meet the requirements to have such a role under the GDPR. We will keep the need for this position under review and in the meantime keep data protection at the forefront of what we do.

Revisions to this Privacy policy

We may revise our Privacy policy according to new developments or advances in legislation and the wider data protection landscape. The most current version of our Privacy policy will always be on our site, and we will put a written notice on our site to notify our users of any revisions.

If you have an account with us, we’ll notify you of any notable changes by sending you an email to the email address associated with your account, unless you have unsubscribed from all email communications. Please note that your use of the site and/or Services following the effective date of any modifications to the Privacy Policy will constitute your acceptance of the Privacy Policy, as modified. All changes to this Privacy Policy automatically take effect on the sooner of the day you use the site and/or services following the effective data of any modifications to this Privacy Policy, as modified.

Contact details

You can contact us at hello@kindana.co 

Date: 13 May 2024

Version number: 1.0

Language: English