Privacy Notice of Compliance Software Systems DMO Limited trading as KitchTech
EFFECTIVE DATE: 15/05/2019
WHO WE ARE
Compliance Software Systems DMO Limited trading as KitchTech is a limited liability company registered in Ireland (company number IE646001) hereinafter referred to as “KitchTech”). Our registered office is at IFSC House, Custom House Quay, Dublin 1.
Any reference in this Notice to “us”, “we” and “our” means KitchTech.
APPLICATION OF THIS NOTICE
As part of our business relationship with you, we collect certain information about you in order to perform our contract with you, and to provide our services to you.
This Privacy Notice explains how we collect, use, process, and share the personal information that we collect from you, or that you provide to us when you use our website, including any data that you may provide through the website when you make contact with us.
WHAT IS PERSONAL DATA?
Personal data is any data that identifies you, or could be used to identify you, which is submitted and/or collected by KitchTech. It does not include anonymised data where your identity has been removed.
WHAT INFORMATION DO WE PROCESS?
We may collect the following categories of personal data:
- Personal contact details including your name, telephone number, email address, postal address, username or similar identifier
- Personal details including date of birth, gender, marital status and gender
- Financial information including your bank account details and payment card details, billing address, payment details, anti-money laundering documentation (including a copy of your driver’s licence or passport and utility bills)
- We may receive personal data about you from third parties or from publicly available sources
Like most websites, we also gather statistical data and other analytical information (for example, demographic information, usage data etc.) collected on an aggregated basis of all visitors to our website. This data is not considered personal data in law as it does not directly or indirectly reveal your identity.
We do not collect any categories of sensitive personal data from you, or information relating to criminal convictions.
We use the personal data that we collect from you for the performance of our contract with you:
- To open an account for you as a customer
- To communicate with you in relation to our services
- To perform the contract with you and to provide services to you
- To process payments due in relation to the services
- To subscribe to our services and publications
- For marketing and promotional purposes in connection with the services (which may include surveys)
We also use the data for statistical reporting regarding our web activities and products/services
It is our intention to hold only accurate, complete and up-to-date data. If you need to update your details you can do so by emailing firstname.lastname@example.org or writing to us at Compliance Software Systems DMO Ltd, IFSC House, Custom House Quay, Dublin 1, and instructing us what personal data needs to be updated. We may also contact you directly once you have supplied your email address for further information / clarification.
OUR LEGAL BASIS
We use your personal data for the purposes outlined above, except where restricted by law. In doing so we rely on a number of separate and overlapping legal bases to lawfully process your personal data, as follows:
- Where necessary to perform our contract with you
- For the purposes of our legitimate interests, provided that those interests are not overridden by your interests or fundamental rights and freedoms.
- Where you have consented to the processing (in which case you may revoke your consent at any time by contact us at email@example.com or write to us at the address below.
- Where necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims.
We will use your personal data where it is necessary to preserve or to defend our rights in court, to respond to law enforcement requests or discovery procedures, or when required or permitted by applicable laws, court orders, government regulations, or government authorities, which may include lawful access by courts or governmental authorities outside your country of residence.
DO WE SHARE YOUR PERSONAL DATA?
We may have to share your personal data with other parties as set out below:
- Our employees, officers, contractors, and agents acting on our behalf
- Our advisers (including our accountant and auditor)
- Service providers who act on behalf of KitchTech pursuant to a contractual relationship
- Where we are required to do so by any regulatory or government agency/body, law enforcement agency, court or other legal process, or by law.
- To third parties to whom we may choose to sell, transfer, or merge all or part of our business or our assets.
Our IT services, marketing services and payment services are provided by an external service provider pursuant to a written agreement; however, we continue to be the controller of your personal data and such third parties may only process your personal data as instructed by us. They are also required to keep the data safe and secure.
We do not envisage that your personal data will be transferred outside the European Economic Area, but if we need to do so, we will ensure that appropriate measures are in place to protect your personal data and to comply with our obligations under applicable data protection law.
HOW DO WE KEEP YOUR DATA SECURE?
We have put in place appropriate security measures against unauthorised access to, or alteration, disclosure or destruction of personal data and against accidental loss or destruction.
We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. We will only process your personal data for the purposes for which it was collected and third parties will only be permitted to process your data on our instructions.
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 obliged to do so.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including the purposes of satisfying any legal, accounting, or reporting requirements.
By law we are required to hold certain information about our customers for 6 years for accounting and tax purposes. We will keep your data in accordance with our record retention policy taking into account requirements imposed on us by law, and also business and legal considerations.
In some circumstances, for example research/statistical purposes, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use this data indefinitely without further notice to you.
In accordance with the Data Protection laws, individuals may access their personal data and request a copy of their data held by KitchTech at any time. Please contact us via email firstname.lastname@example.org , or write to us at the address below to request a copy of your data.
WHAT ARE YOUR RIGHTS
You have various rights under data protection law, subject to certain exemptions, in connection with our processing of your data:
- Right to access your personal data: You have the right to request a copy of the personal data that we hold about you, and information as to how we process that data.
- Right to rectification: You have the right to request that any inaccurate or incomplete data that we hold about you be corrected.
- Right to erasure: You have the right to request us to delete data that we hold about you.
- Right to restriction of processing: You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your data for particular purposes.
- Right to data portability: You have the right to request the transfer of your data to a third party.
Please note that you may be required to provide us with sufficient information in order that we can verify your identity and locate your data. Note also that these rights are also subject to certain restrictions. Please contact us if you require further information in this regard.
If you would like any further details about the measures that we have in place to ensure compliance with data protection law, or in relation to your personal data, you can submit queries and requests to email@example.com or contact us at the address below.
Without prejudice to any other rights you may have, you may file a complaint with the Irish Data Protection Commission. The Commission’s website is www.dataprotection.ie and details of how to lodge a complaint can be found there.
CHANGES TO THIS NOTICE
We reserve the right to update this Privacy Notice at any time. If we make any changes we will post details of the changes on our website. When you use our website the current Privacy Notice will apply and you should review it each time that you visit our site.
Last updated: 09/04/2019
If you have any questions regarding this Notice or our use of your personal data, please contact us using the following information:
Compliance Software Systems DMO Limited
Custom House Quay