Privacy Notice
Kiltti has a legal responsibility to keep all of your personal information safe. We must also let you know what we will do with your information at the moment we collect it from you. That is so that you have the choice of whether to give it to us or not.
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This policy explains how we handle your personal information so please make sure you read and understand it. If there is anything you don’t understand, or you would like more information about, please contact Kiltti’s Data Protection Officer using the information below.
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What is personal information?
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Personal information is anything that can identify you specifically in some way. It can include lots of things, like your name, your gender, your address, your email and your date of birth. Some pieces of information about you will not be able to identify you specifically, unless it is linked to some other information. For instance, if all the information we had was a date of birth, then neither we nor anyone else could link that to a specific person; if we had a date of birth plus a home address, it is highly likely that we could.
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What personal information do we collect?
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Here at Kiltti, we will only ask you to provide the minimum amount of information that will allow us to provide you with the service you have requested. For instance, Kiltti may offer free digital resources or information which may be of interest to you so we would only ask for an email address to send it to.
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In the course of providing a service to you, there might be information that you volunteer to us. During a coaching session, for example, you might tell us your marital status, your employment history, or your sexual preferences. Information such as this will only be noted by your Kiltti coach as an aide memoire for any further sessions, and only if it is relevant to achieving the coaching goal.
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Any information you give to Kiltti will be confidential and, unless we are required to by law, will not be retained for longer than is necessary to provide the service to you. At the end of that period, the information will be digitally deleted and/or confidentially destroyed as appropriate.
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Any personal information that Kiltti retains longer than legally required will be a) completely anonymised, and b) for a specific purpose e.g., to give us statistical demographic data about our customers. This means that Kiltti could tailor its services more effectively to meet the needs of a certain demographic, or change its marketing to attract people that are under-represented in its customer base.
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What personal information do we share with others?
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The personal information you give to Kiltti is confidential and will not normally be shared with anyone outside of Kiltti. However, there may be times when that information is shared with others and they are as follows:
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you ask us to share it
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to prevent serious physical harm to a person;
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to prevent loss of human life;
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the protection of public health;
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to safeguard vulnerable adults or children;
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in response to an emergency; or
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an immediate need to protect national security.
Kiltti will never sell your personal data, nor exchange it for any benefit.
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How we get the information and why we have it.
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Kiltti will only ever get your personal information directly from you.
Under data protection legislation, Kiltti must have one or more legitimate reasons for collecting and processing your information. ‘Processing’ includes things like recording, storing or retrieving information.
In Kiltti’s case, these reasons will mostly come under three categories: consent, contract or legal obligation:
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Consent - This is where you volunteer information to us and give your permission to use it. For example, you might be interested in receiving free resources or information from us, even if you’re not an existing customer of Kiltti’s. By letting us know who and where to send it to, you are giving us your permission to process some of your personal details. Under this category, you have the right to withdraw your permission at any time.
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Contract - This is where the information is required for us to meet our contractual obligations to you. For example, we will not be able to coach you if we don’t know who you are.
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Legal obligation - This is where we need to store the information for legal reasons. For instance, Kiltti has an obligation to store and maintain information for taxation purposes; HMRC takes a very dim view of poor and incomplete record-keeping.
How we store your information.
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Kiltti will do its utmost to store your information safely and securely at all times. Except for purposes already mentioned above, no-one outside of Kiltti will have access to the information.
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We store your information in this country, the UK. None of your information is stored in another country, but if we ever needed to store your information in another country, we would update this privacy policy to let you know and continue to look after your information carefully and make sure we store it legally.
Kiltti will store the information digitally on its computers, in password-protected folders and files. Paper records will be filed securely in locked cabinets in Kiltti’s operational offices.
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Your data protection rights.
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Kiltti is committed to the principles of Articles 12 to 22 of the UK GDPR, which deal with the rights of the person whose information is collected and stored. Your rights include, but are not limited to, the:
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Right of access – this is the right to ask us for copies of the personal information we hold.
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Right to rectification - this the right to ask us to rectify information that is inaccurate. It is also the right to ask us to complete information that is incomplete.
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Right to erasure – this is the right to ask us to erase personal information in certain circumstances.
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Right to restriction of processing – this is the right to ask us to restrict the processing of personal information in certain circumstances.
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Right to object to processing – this is the right to object to the processing of personal information in certain circumstances.
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Right to data portability – this is the right to ask that we transfer the information volunteered to us to another organisation, or to the person, in certain circumstances.
There is no requirement for you to pay any charge for exercising these rights. If Kiltti receives a request, we have one month to respond. It is Kiltti’s policy to respond sooner than this, as long as it is practicably possible.
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Please contact our Data Protection Officer (see ‘How to contact us’) if you wish to make a request.
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How to contact us.
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If you would like further information, or wish to make a request or complaint regarding your personal information, Kiltti’s Data Protection Officer can be contacted as follows:
By post: Data Protection Officer, Kiltti Ltd, Units 4 & 5 Brightwell Barns, Waldringfield Road, Brightwell, Ipswich, IP10 0BJ
By email: danbristow@gmail.com
By phone: 07964040210
You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.
The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113