Your privacy matters
Introduction
We are committed to protecting and respecting your privacy and Personal Data. This Privacy Policy will inform you as to how we look after your Personal Data when you visit our Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.
1. Important Information and Who We Are
2. The Data We Collect About You
3. How Is Your Personal Data Collected?
4. How We Use Your Personal Data
5. Disclosures of Your Personal Data
6. International Transfers
7. Data Retention
8. Data Security
9. Your Legal Rights
10. Glossary
By agreeing to the terms of this Privacy Policy, you consent to the collection, storage, processing and sharing of your Personal Data and other information on the basis set out in this Privacy Policy.
1. Important Information and Who We Are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how Knowa collects and processes your Personal Data through your use of the Knowa Services and/or the Website, including any data you may provide through this website when you complete a Contact Form on the Website.
The Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Company Information
Knowa Limited (ICO Registration Number: ZA426522) is the controller and responsible for your Personal Data (collectively referred to as “Knowa“, “we“, “us” or “our” in this Privacy Policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager by post using the details set out below:
Knowa Ltd.
Julco House,
26-28 Great Portland St,
London.
W1W 8QT
and by email at: privacy@knowa.co
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.
You can obtain further information about data protection and privacy laws by visiting the Information Commissioner’s website at: https://ico.org.uk/for-the-public/.
Changes to the Privacy Policy and Your Duty to inform us of Changes
We keep our Privacy Policy under regular review. This version was last updated on 9th July, 2020. Historic versions can be obtained by contacting us.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. You can update or edit any of the information in your Account. Furthermore, it is your responsibility:
To protect against unauthorised access to your Account.
To log off from your Account when not using it.
To keep your log-in details secret.
Third-Party Links
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
2. The Data We Collect About You
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:
Identity Data includes first name, maiden name, last name, company, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes [billing address], delivery address, email address and telephone numbers.
Technical Data includes 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 the Website.
Profile Data includes your username and password, your interests, preferences, feedback and form/survey responses.
Usage Data includes information about how you use our Website, products and services.
Special Category Data
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.
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including:
When End Users use the Knowa Services: When making use of the Knowa Services we will collect Identity Data, Contact Data, Technical Data and Usage Data relating to End Users.
Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
complete the Contact form on the Website;
Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see Cookies below for more information.
4. How We Use Your Personal Data
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To provide the Knowa Services to End Users
(a) Identity
(b) Contact
(c) Technical
(d) Usage
Performance of a contract with you
To manage our relationship with you which will include notifying you about changes to our terms or Privacy Policy.
(a) Identity
(b) Contact
(c) Profile
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
We use information collected from you to provide the functionality of the Website and the Knowa Services to the Client, and to communicate with you on matters relating to your Account, the Knowa Services or the Website.
We will only use your Contact Data for the purposes of contacting and communicating with you, and not for any other purposes.
Cookies
We may obtain information about your general internet usage by setting a cookie file which is stored on your browser or the hard drive of your Device. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on the hard drive of your Device for an extended period of time. You can remove persistent cookies via your browser’s “clear cookies” function. Please see www.allaboutcookies.org for more information about blocking cookies on your particular web browser.
Unless you have adjusted your browser setting so that it will refuse cookies, we will drop cookies onto your Device as soon as you visit our site. Persistent cookies enable us to track and target your interests to enhance your experience on our Website. For example, we use this data to understand how you interact with our Website so we can make improvements to the information and design of our Website.
By agreeing to the terms of this Privacy Policy, you consent to the cookies referenced above being set on your Device and, if applicable, to us collecting and storing any Contact Data that you provide via the Website.
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. Please contact us if you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose.
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.
5. Disclosures of Your Personal Data
We may share your Personal Data with the parties set out below, for the purposes described in the “How We Use Your Personal Data” table above:
Third parties to whom we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce our contractual rights; or to protect the rights, property, or safety of Knowa, our stakeholders, or others.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
Third party providers of IT services, such as hosting, connectivity and telecommunications services.
Third party providers of analytics technologies, including Google Analytics, Hotjar, Intercom and other third parties.
Except as set out above and elsewhere in this Privacy Policy, we do not share your Personal Data with any third parties.
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.
6. International Transfers
We may share your Personal Data with our staff operating at various global locations. This will involve transferring your Personal Data outside of the European Economic Area (EEA).
Some of our external third parties are also based outside the EEA, so their processing of your Personal Data will involve a transfer of data outside the EEA. We use these third parties for activities such as website penetration testing (also known as “ethical hacking”), hosting, connectivity and telecommunications services.
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 transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if the appropriate Data Processing Addendums are in place. As of July 16, 2020, we no longer rely on the EU-U.S. Privacy Shield to transfer data that originated in the EEA or the UK to 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.
7. Data Retention
How long will we use your Personal Data for?
We will generally store your Personal Data for no more than six months after the relevant Client stops actively using the Knowa Services, at which time your Personal Data will be irretrievably deleted.
We will only retain your Personal Data for longer periods in limited circumstances, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may also 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.
8. Data Security
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
The transmission of information via the internet is not completely secure, and you acknowledge that you are solely responsible for the security of your data (including the equipment, webservers and networks used for its transmission) until the data is received by our systems. .
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.
9. Your Legal Rights
Under certain circumstances, you have rights under Data Protection Laws in relation to your Personal Data Data Protection Laws, including:
The right at any time to withdraw your consent to our processing of your Personal Data.
The right to be told what Personal Data we hold about you on our database and how we process that data.
The right to request that we provide you with a copy (in a commonly used electronic format) of all the Personal Data that we hold about you.
The right to request that we correct any inaccurate or incomplete Personal Data that we hold about you.
The right to object to, or request a restriction of, the processing of your Personal Data.
The right to request that we irretrievably delete all Personal Data that we hold about you (the so-called “right to be forgotten”). Note that there are limited circumstances in which we are legally entitled to refuse to comply with this request.
The right to request that we transmit all the Personal Data that we hold about you (in a structured, commonly used and machine readable form) to another organisation’s IT environment. Note that we are only legally obliged to comply with this request if it is technically feasible for us to do so.
Should you wish to exercise any of the rights set out above, please contact us.
Fees
You will not usually 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.
10. Glossary
“Account”
means an account set up for a Client on the Website.
“Data Protection Laws“
means the Data Protection Act 2018 and The General Data Protection Regulation (EU) 2016/679 (GDPR)
“Device”
means a computer, tablet, smartphone or other device capable of accessing the Website
“Client”
means a user of the Knowa platform.
“End User”
an individual who has been authorised by a Client to access and use the Knowa Services.
“Personal Data”
information from which the identity of a living individual may be determined. Examples of Personal Data include (but are not limited to) first and last name, physical address, email address, phone number and IP addresses.
“Knowa Services”
means the ability for an End User to access the functionality of the Website.
“Visitor”
an individual visiting the Website.
“you”, “your”
anyone who interacts with the Website, including End Users and Visitors.
“Website”
Knowa’s proprietary platform that may be accessed at https://app.knowa.co
