Kene Partners Limited (“Kene Partners” or “we”) is committed to protecting and respecting your privacy. As a professional services business, it is important that we treat your personal data properly and with care.
Please read the following carefully to understand how we will respect and manage your personal data. By visiting our website, or by providing us with any information about yourself, you are accepting and agreeing to the practices described in this notice.
For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”) as applicable in the UK and as amended, supplemented or replaced from time to time (“Data Protection Law”), the data controller is Kene Partners Limited, which has its registered office at Brockbourne House, 77 Mount Ephraim, Tunbridge Wells, Kent, TN4 8BS, United Kingdom. If you wish to write to us, our trading address is at WeWork, 10 Devonshire Square, London EC2M 4YP, United Kingdom.
This notice sets out our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.
1. Information provided to Kene Partners
1.1 Any information you provide to Kene Partners
This is any personal information that you provide to Kene Partners, for example by:
a. registering or filling in forms on our website or social media accounts (our “sites”)
b. corresponding with us by phone, e-mail or otherwise;
c. giving us instructions, to act for you or otherwise;
d. subscribing to any service that we offer;
e. subscribing to any mailing list that we operate;
f. participating in any discussion boards or social media functions on our sites;
g. entering competitions, promotions and surveys that we may conduct from time to time;
h. reporting a problem with our sites, products or services; or
i. applying to work with us.
The information you give us may include:
b. date of birth;
d. business/company name;
e. job title;
g. contact information such as address, email addresses and telephone numbers;
h. descriptive information such as preferences and interests;
i. financial information such as credit/debit card numbers;
j. information about your business, which is only personal data to the extent that the information actually relates to you.
If you are applying to work with us, it may include professional qualifications, professional affiliations, education, details about your work and career and a personal description.
If you provide any information about other individuals such as friends, family or colleagues, you warrant us that you are entitled to provide that information and authorise us to process this data on the same basis as outlined in this privacy notice.
1.2 Information Kene Partners collects about you
When you visit our sites, we may automatically collect the following:
a. technical information, including the Internet Protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types, plug-in versions, operating system and platform;
b. information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our sites (including date and time), items you viewed, page response times, download errors, length of visits to pages, page interaction information (such as scrolling, clicks, mouse-overs) and methods used to browse away from the page.
1.3 Information we receive from other sources
We may receive information about you from sources other than directly from yourself, which may include social media such as LinkedIn, Facebook, Instagram and Twitter. We may also receive information from partners who we work with, such as other professionals, who may refer you to us, or with whom we may need to co-operate in relation to the work that we do for you for example.
2. Data processing
2.1. Legal basis of processing
Data Protection Law requires us to fulfil at least one “legal ground” for processing data that contains personally identifiable information, currently set out in Article 6 of the GDPR. The grounds applicable to the personal data to which this notice relates to are:
a. Where the processing is necessary for us to perform a contract that you are party to, or to take steps at your request prior to entering a contract; and/or
b. Where the processing is necessary for compliance with a legal obligation to which we are subject; and/or
c. Where processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, provided that your fundamental rights and freedoms are not overridden. Our legitimate interests include the management, marketing and promotion of our business, products and services, the provision of our services, and the recruitment and management of staff; and/or
d. Where you have given consent to the processing.
If more than one of the above grounds apply to the processing of data in question, the applicable ground will be the first one listed.
2.2 How Kene Partners processes the information you provide
We will use this information to:
a. carry out our obligations arising from any contracts entered into between you and us;
b. provide and manage your account with us;
c. deliver information, products and services that you request from us;
d. share information about other products and services we or our partners offer that are similar to those that you have already obtained from us or enquired about;
e. to provide you, or to permit selected third parties to provide you, with information about products or services we feel may interest you, so long as, where required by law, you have given the relevant consent;
f. notify you about changes to our services, events or other items;
g. carry out market research;
h. ensure that content from our sites is presented in the most effective manner for you and for your device;
i. manage our own legal or risk issues;
j. process job applications submitted to Kene Partners, in order to evaluate and manage those applications.
When you enter into a contract with, or make a request to, Kene Partners, you are required to provide the necessary information. Otherwise, we may not be able to fulfil the contract or request.
2.3 How Kene Partners processes the information we collect about you
We will use this information to:
a. provide our services;
b. administer our sites;
c. manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
d. improve our sites to ensure that content is presented in the most effective manner for you and for your device;
e. allow you to participate in interactive features of our sites, if you choose to do so;
f. support our efforts to keep our sites safe and secure;
g. measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
h. make suggestions and recommendations to you and other users of our sites about goods or services that may interest you or them.
2.4 How Kene Partners processes the information we receive from other sources
We may aggregate multiple sources of data we collect about you from other sources and use this data only for the purposes outlined in sections 2.2 and 2.3 above.
3. Cookies and Pixels
Pixels or beacons may be included in our emails. These are similar to cookies, and may be used to track users’ activity in relation to our emails. If you sign up to receive emails, newsletters etc, each email can collect limited information, for example about whether and when you opened our mail. If you do not want this information to be collectable, you should disable and not open images in your email application.
4. Information disclosure
4.1. Within our group
We may share your personal information with any group undertakings, for administrative purposes as defined in s1161(5) of the UK Companies Act 2006. This includes any undertaking which is under 50% or more ultimate common ownership with Kene Partners Limited, provided that they either:
a. are within the UK or European Economic Area;
b. are in a country that the UK or European Union has decided has adequate data protection laws in place; or
c. have provided appropriate data protection safeguards of the sort approved by the UK or European Union and provide effective rights and remedies for you.
Any use of one group member’s personal data (beyond administration) by other members of the group will be subject to all the requirements of Data Protection Law.
4.2. Parties we may disclose your information to
Kene Partners will not generally disclose your personal data to any other person unless and to the extent that such disclosure is necessary for the performance of any contract we enter into with you. We may, for example, disclose your personal data to other professional advisers where necessary to carry out your instructions.
We may also disclose your personal information to third parties in the following instances:
a. If we outsource any aspect of our business or systems, then we may disclose your personal data to our service provider(s) to the extent necessary; or
b. If we sell or buy any business or assets, then we may disclose your personal data to the prospective seller or buyer of such business or assets; or
c. If we or a substantial part of our assets are acquired by a third party, in which case personal data held by us about our customers may be one of the transferred assets; or
d. In the event of a legal obligation to an authorised body or to protect the rights, property, or safety of Kene Partners, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Special categories of personal data
If you provide us with any special categories of personal data, you expressly consent (and you hereby do) to us processing that data for the purposes set out in clause 2.1. Under special categories of personal data, the GDPR refers to information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sex life or sexual orientation or genetic or biometric data personal data. We also include in this category information relating to criminal convictions and offences. If you do not want us to process any such categories, please do not provide it to us.
6. Data storage
6.1. Where we store your personal data
The data that we collect from you will be stored on our servers or those of our service providers. It will not be transferred to, and stored at, a destination outside the UK or European Economic Area (“EEA”) unless:
a. to one of our group undertakings to which section 4.1 applies;
b. to a processor acting on our behalf which is either (i) within the UK or EEA, or (ii) in a country that the UK or European Union has decided has adequate data protection laws in place, or (iii) has provided appropriate data protection safeguards of the sort approved by the UK or European Union and provide effective rights and remedies for you; or
c. you have given consent to us transferring data about you to third parties outside the UK or EEA.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our sites or systems, you are responsible for keeping this password confidential, and for all use made of your account with such password. You should not share your password with anyone.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the internet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
All electronic media storing your personal data will be encrypted. Any hard copies of personal data will be stored in a locked environment.
6.2. Length of data storage
Our policy is to ensure that personal data is only stored for as long as is necessary for the purposes set out at section 2 above. This may vary according to the type of information and the specific applicable purpose(s). In determining how long we retain your information for, the criteria that we will take into consideration include our legal obligations, good industry practice, the guidance of relevant UK authorities such as the Information Commissioner’s Office and HMRC, and also tax, accounting, health and safety and employment rules. We can provide you with further details applicable to your data on request – please see section 7 below as to how to request this information.
7. Your rights
You have various rights under Data Protection Law. These include:
a. the right to ask us not to process your personal data for direct marketing purposes, even if you have given consent;
b. the right to withdraw any consent you may have given for our processing of your data – if you exercise this right, we will be required to stop such processing if consent is the sole lawful ground on which we are processing that data;
c. the right to ask us for access to the data we hold about you (see section 8 below for further details);
d. the right to ask us to rectify any data that we hold about you that is inaccurate or incomplete;
e. the right to ask us to delete your data in certain circumstances;
f. the right to ask us to restrict our processing of your data in certain circumstances;
g. the right to object to our processing of your data in certain circumstances;
h. the right to require us to give you the data we hold about you in a structured, commonly used and machine-readable format so that you can provide the data to another data controller.
You can exercise any of the rights set out above, free of charge, by contacting us at firstname.lastname@example.org. If we require any more information from you in order to process the request, we will ask this from you following your request.
If you submit unfounded or excessive requests to exercise any of these rights, we reserve the right to decline your request or make a reasonable charge for fulfilling your request.
You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) if you are concerned that we are not respecting your rights under Data Protection Law. The Information Commissioner’s Office is the authority in the UK which is responsible for overseeing the application of, and enforcing, Data Protection Law.
8. Accessing your data
You have the right to obtain from Kene Partners a confirmation as to whether we are processing (including holding) personal data about you.
If we are processing personal data about you, you are entitled to be provided with:
a. information as to the purposes for which we process the data;
b. information as to the categories of the data that we are processing;
c. information as to the recipients or categories of recipients to whom the data has or will be disclosed;
d. information as to the envisaged period for which we will store the data, or if that has not been determined, the basis on which that period will be determined;
e. a copy of the data (should you request further copies, we may make a reasonable charge which will inform you of at the time). Please note that this right is subject to the rights of others in relation to their own or someone else’s personal data.
See section 7 above for details of how to exercise these rights.
9. Other websites
Our sites may, from time to time, contain links to and from the sites of third parties. If you follow a link to any of these sites, please note that they should have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those sites.
10. Changes to this privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, we will notify you by e-mail. Please ensure you review this privacy notice frequently to see any updates or changes.
If you have any questions, comments and requests regarding this privacy notice, please email them to email@example.com.
Updated: August 2021