Privacy Notice Exit

Introduction

The "SharedAffairs" website is owned and operated by Free My Kite Ltd. This Privacy Notice describes how Free My Kite Ltd ("We") collect, use and protect your personal information when you interact with Free My Kite Ltd ("Us") through the www.SharedAffairs.com website ("The Website") to use the SharedAffairs Service ("The Service").

For the purposes of this Privacy Notice, the terms "We" and "Us" will refer to "Free My Kite Ltd", "The Website" will refer to the "Shared Affairs Website" and "The Service" will refer to the "Shared Affairs Service". The Website is the set of online pages hosted by us at www.SharedAffairs.com and the Service includes the services that are available to registered users of the Website that allow the users to perform information-related operations such as (and not limited to) read, write, delete, amend and sharing of data.

You agree that by providing your personal information to us, you consent to the collection and use of your data as defined in the UK Data Protection Act 2018 (hereinafter referred to as "The Act"), The European General Data Protection Regulation 2018 (hereinafter referred to as "the GDPR") and in accordance with this Privacy Notice.

This Privacy Notice was updated on 18th August 2020.

Our contact details

Free My Kite Ltd is responsible for the processing of your personal information under the Data Protection Act 2018. We are regulated in the UK by the Information Commissioner's Office and our ICO registration number is ZA780535.

Our Data Protection Officer can be contacted by emailing: dataprotection@freemykite.com.

How we collect the different types of information about you

We will collect only the personal information necessary to provide you with our services. Most of the personal information we process is provided to us directly by you when you input the information into the website using the input forms provided. You do this when you:

  • register to use our services by creating an account,
  • make changes to your personal profile on the Website,
  • upload any information for safekeeping,
  • use the website to provide information to others to manage your affairs,
  • or invite your contacts to share information with them.

This includes, but may not be limited to, the following types of information:

  • personal identifiers such as the name you provide us with,
  • the email address(es) that you provide,
  • the names and email addresses of people you want to have access to your information
  • or any other personal information you choose to upload for safekeeping.

We may collect certain limited information (such as your browser type and IP address) ourselves for the purpose of optimising your user experience on our website.

Why we collect your information and the legal basis for processing

Under the GDPR, the lawful basis we rely on for processing this information is that we have a legitimate interest to collect, store and use this data for reasons of providing you with any services you may register to use on our website. This includes, but is not limited to:

  • setting up your account
  • identifying you to enable you to sign-in,
  • sending a two-factor authentication code to your email or mobile device to allow you to gain secure access to your account,
  • authenticating you when you access your information to prevent unauthorised access,
  • keeping your information up to date,
  • allowing you to reset your password,
  • analysing your use of the site to improve the Service and make it easier to use,
  • sending you service update emails regarding the Service for your account,
  • sending you alerts and notifications necessary in the use of the Service,
  • sending email invitations to the people that you invite to the Service when you want to share your information with them
  • and delivering the products and services selected by you

How we store and protect your information

Your information is securely stored within data centres contracted by us and located in the UK or within territories where either the UK Data Protection Act 2018 or the GDPR are applicable and enforceable.

We keep all the types of personal information, described within this Privacy Notice, for only as long as is required to provide the service to you and no longer than the time periods defined in our Data Retention Policy. After such time periods, we will then dispose of your information by secure deletion and prevent it being recovered.

You may delete your data at any time you wish to delete it using the delete facilities within the Website. Once you delete your data, we immediately delete it and do not recover it. You may also delete your account at any time using the delete account facilities provided by the Website. Once you delete your account and confirm deletion, we remove all associated files, contents, and other information uploaded by you immediately. We do, however keep a record, for audit purposes only, of your email address and the associated account deletion request timestamp.

We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. We use encryption to ensure that the private information you upload (other than information related to administer your account) is not readable by anyone other than you or the people you want to share it with. This encrypted information is not decrypted by us and cannot be seen by us or our staff.

We continuously monitor and regularly review our data protection methods and processes with the aim to implement robust security industry best practices and updating the data protections provided to users of our services. In the event that there is any breach of data, we shall work with the relevant Authorities to report and provide transparent access to investigate the extent and method of such breach keeping any affected persons informed of any action they may need to take to protect themselves from any, or further, impact.

In the event that Free My Kite Ltd undergoes reorganisation, transfers the business to a third party or is sold, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party as long as it is subject to the same data protection laws and regulations afforded under this Privacy Notice. If there is an intent to protect your data under different standards, you will be informed so that you may decide whether to continue to use the services or seek to clarify the risk or impact of any changes upon you.

Confidentiality and providing information to others

We will treat your personal information as private and confidential. Under certain exceptional circumstances we are obliged, and permitted by law, to disclose information as described in the cases set out below:

  • Where we are legally compelled to do so
  • Where there is a duty to the public to disclose
  • Where the disclosure is required to protect our interest
  • Where disclosure is made at your request or with your consent

For the purposes mentioned above, we will only share your data with law enforcement bodies in order to comply with any legal obligation or court order and only in accordance with applicable privacy and data protection laws.

We may also provide information to third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, IT services and customer services.

If we employ third party service providers to process your personal information on our behalf the same duty of confidentiality and security will apply to them and all processing will be carried out under our instruction meeting the full requirements of this Privacy Notice as a minimum.

Cookies

When you visit the Website, cookies are used to collect anonymous information (without personally identifying you) so that your experience with the website can be improved in the future.

What are cookies?

Cookies are small text files saved to your website browser to help us to provide you with a more personal experience and allow us to make improvements to our services over time. You may delete and block all cookies or decide to just block certain types of Cookie via your browser setting. However, if you choose to block or delete Cookies, this may affect the functionality of the website.

What types of cookies do we use?

We may use session, persistent and third-party cookies on our websites. Session cookies exist for the duration of a visit and are erased when you close the web browser. Persistent cookies are stored until they expire, which can range from several minutes to many years.

The Cookies we use are explained below:

Essential Technology:

We use these cookies to make sure that our website is working correctly, and they are essential for us to provide you with the service. To do this we also collect anonymous data from your computer that helps us to optimise the website and make sure that we give you the best possible experience.

Google Analytics

We use Google Analytics cookies to give us insights into our website traffic and marketing effectiveness. It helps us optimise and target our activities more effectively. Again, all of your data is anonymised.

About Google Analytics Cookies

Find out more about cookies

www.aboutcookies.org
www.allaboutcookies.org/manage-cookies

You can change your cookie preferences at any time by clicking on the banner and adjust your preferences before pressing 'Save and close'. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:

 

To find information relating to other browsers, visit the browser developer's website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of any personal information we hold for you.

  • We do not hold any personal information for you except that which is available to you through the SharedAffairs account that you created when you registered to use our Service. You can access that information directly through that account online. However, if you wish, you may request a copy of your personal information by sending an email to our Data Protection Officer (dataprotection@freemykite.com). We will provide you with the information by return of email to the email address directly related to your account. We can only send you your information that is not stored in an encrypted format.
  • If you have deleted your account, you may request details of any residual information by sending an email to our Data Protection Officer (dataprotection@freemykite.com). We will provide you with the information by return of email to the email address directly related to your account.

Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. You can do this by sending an email to our Data Protection Officer (dataprotection@freemykite.com). If any inaccurate or incomplete information was entered directly into the website by you, you are responsible for correcting or completing (rectifying) that information yourself through your account.

Your right to erasure - You have the right to ask us to erase your personal information. You can delete your account (and all associated information) directly after signing into your account under your profile settings page. If you still wish to ask us to do that, you can send an email to our Data Protection Officer (dataprotection@freemykite.com). You also have the facility to delete any information that you have yourself created directly on the website immediately.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal data in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances. You may request a copy of your personal information by sending an email to our Data Protection Officer (dataprotection@freemykite.com). We will provide you with the information by return of email to the email address directly related to your account. We can only send you your information that is not stored in an encrypted format.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at dataprotection@freemykite.com if you wish to make a request. We may ask proof of identity to authenticate you before releasing personal information belonging to you.

In certain circumstances (for example where required or permitted by law) we might not be able to provide you with access to some of your personal information, but where appropriate we will notify you of the reasons for this.

Contact & Complaints Process

If you have a query or concern about how we store or process your personal information or any questions about this Privacy Policy you may contact us via email at dataprotection@freemykite.com

You can also complain to the UK's data protection authority, 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: +44 (0) 303 123 1113

Concerns can be also be logged via the ICO website and the ICO can be contacted at: https://ico.org.uk/global/contact-us/

Updates

This Privacy Policy is regularly reviewed and amended. Please revisit this policy periodically to be kept informed of any changes.

We will notify registered users, of the service, of any material changes we make to this Policy and, where required under applicable privacy and data protection law, we will appropriately notify or give you the option to consent to changes to the Policy.

If you do not accept the statements in this Privacy Policy, please get in touch or stop using our website.

This Policy only applies to the service provided at the SharedAffairs.com website.

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