Purpose of this Processing Notice
This processing notice aims to give you information on how we collect and process your personal data in a variety of circumstances. It is important that you read this processing notice so that you are fully aware of how and why we are using your data. This version was last updated on 15 June 2021 and previous versions can be obtained by contacting us.
Kx Systems, Inc. (referred to as we, us or our in this processing notice) is the controller and responsible for your personal data. If you have any questions about this processing notice (including any requests to exercise any of your legal rights) please contact us by emailing firstname.lastname@example.org.
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
· User Data includes first name, last name, online username or similar identifier, password and time zone from which you access the Portal;
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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Your Duty to Inform us of Changes
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.
We use different methods to collect personal data from and about you. The ways we collect it, what we collect and how and why we use that personal data is set out below:
|Personal Data Type||Collection Method||Basis of Use||Purpose|
|User Data||Provided at time of registration||Legitimate Interests (to run our company and make the Portal available)||To contact you if needed.
To permit access to our Portal
To register you as a user of the Portal and to attribute your input on the Portal to you
For testing and evaluation purposes to ensure our platform works well
|any of the above||as above||Legitimate interests (to protect and run our company)|
Compliance with law
|Ancillary purposes, such as back-ups and archiving|
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to make available the Platform and manage it effectively. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties (all established in the European Union unless otherwise stated) set out below for the purposes set out in the table in paragraph 4 above:
We generally do not transfer your personal data outside the UK other than to the European Economic Area (EEA) in connection with the Platform.
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. We have also 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. 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. Please contact us if you would like more information regarding the security measures we use.7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, how long a legal claim may be taken and whether we can achieve those purposes through other means, and the applicable legal requirements. On the basis of the above consideration (including the fact that old interactions on the Platform may remain valuable and of interest to our users, regardless of when they review those interactions later), we will retain your personal data for so long as we operate the Platform.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us. Note, however, that we may not always be able to comply with your request for specific legal or compelling legitimate reasons which will be notified to you, if applicable, at the time of your request.
No fee usually required
You will not 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 may 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 may 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.
Supervisory Authority Contact
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.