If you have any concerns or questions please feel free to contact us in writing or by emailing info@Kellman2.com
WHO ARE WE?
We are Kellman2 Ltd, our address is 1 Oak End Close, Tunbridge Wells, TN4 0TE. You can contact us by post at the above address, by email at info@Kellman2.com. Haelu is a Kellman2 Ltd product. Our website is www.haeludrinks.com
Kellman2 Ltd is committed to respecting your privacy and ensuring the personal information you have entrusted with us is held securely and takes into account major privacy principles and frameworks around the world, including The DPA (Data Protection Act) 2018 and UK GDPR (General Data Protection Regulation) ,and the EU GDPR.
PURPOSE OF THE POLICY
This Privacy Statement is issued by Kellman2 Ltd (also referred to as ‘we’, ‘us ‘or ‘our’ in this Privacy Statement) and sets out the ways and the manner in which we collect and use your personal data. It provides information about our privacy practices including details of the personal data we collect, use, disclose and transfer, as well as choices you can make and the rights you can exercise in relation to your personal data.
WHAT IS PERSONAL DATA (INFORMATION)?
Personal Data is defined as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
WHY WE USE YOUR PERSONAL INFORMATION
Kellman2 Ltd collects information about you to provide our services and products. To enable us to deliver our services and products in the best possible way, it is necessary for us to collect, process, and/or use the information as stated in this Policy.
We use the information we hold about you in a range of different ways, which broadly fall into these categories:
Things we need to do in order to provide you with the products or services you’ve requested
Things we need to do to meet legal or regulatory obligations
Things that enable us to run our business effectively and efficiently
Things we do with your consent for marketing purposes
We will only collect, use and share your information where we are satisfied that we have an appropriate legal basis to do this. We only process your personal data on the following legal bases:
Performance of a contract: We may process personal information to enter into a contract and/or fulfil agreements with you or your organisations, including managing and delivering our services and products and allowing our customers to use our products/services and supplementary tools.
Legal obligation: We may process personal data to comply with applicable laws and regulations and establish or exercise our legal rights. For example, to meet the responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities.
Legitimate Interest: We may process personal data as necessary to pursue our legitimate business interests (except where such interests are overridden by the interests, rights or freedoms of the data subject). We use personal data and other data to provide services you request; processing your payment, providing customer-related services; managing, developing and improving our products and services; performing our marketing and sales operations; protecting our employees and assets; and ensuring compliance with laws and regulations. We ensure that the information is processed in a way that values your privacy rights. You have the right to object to processing as explained in data subject’s rights to restriction of, or objection to, processing of personal data.
Consent: We may process your personal information if you have provided your consent to us. In particular, where we cannot rely on an alternative legal basis or we are required by law to ask for your consent in the context of some of our sales and marketing activities, online data collection tools or surveys. At any time, you have a right to withdraw your consent by changing your communication choices, unsubscribing from our communications or contacting us.
Except as described in this Privacy Statement, we will not disclose the personal data with third parties without the consent of the data subject, unless for:
responding to duly-authorised information requests from police and governmental authorities
complying with law, regulation or court order
enforcement and protection of our rights and properties
protection of the rights or personal safety of our employees and third parties on or using our property when allowed, and in each case in compliance with applicable laws.
THE TYPE OF INFORMATION WE COLLECT
The personal data we collect from you may include the following:
Information you provide to us when registering for our services
Information you provide to us in any correspondence and a record of any correspondence we have with you
Details of transactions you carry out with us and information about your bank account and card details
Information about your use of our services
Information you provide to us through surveys you complete or competitions you enter
Information about your preferences
Information about any possible fraudulent, criminal or anti-money laundering activity which our systems detect
Information we obtain from your device
Information we obtain via cookies on your browser
Information about you from external companies/sources
Information about you from public places
Information about you from social media
WHAT WE DO WITH YOUR CONSENT
We will send you offers and information only if you have given your consent for us to do so, in which case we will contact you via email, post, or online about any of our group products and services. We never share your data with companies outside of our group companies for them to use for their own marketing. From time to time, we may team up with a third party to bring you details of a product or service we think might interest you, but where we do this the contact will come from us – we will never pass your details to the third party without your prior consent.
Online Banner Adverts: Cookies
If you have enabled cookies in your browser you may receive banner adverts on our homepage, as these are cookie-based and are not tailored using other information we hold about you. As they are cookie-based you will receive them even if you have opted out of personalised marketing, but you can control them easily via your browser settings.
Social Media Advertising
If you have given your consent to marketing, we may work with social media companies such as Facebook, Instagram, Twitter, Linkedin etc to provide you with information about our products and services via their platforms. If you do not wish to see these adverts, you can disable preference-based marketing in the privacy and ad settings on each individual social platform.
Even if you have withdrawn your consent to personalised marketing by Kellman2 Ltd, you may still see general adverts for Kellman2 Ltd products and services on your social media feeds. These will not be specifically targeted to you, and again, you can control this via the privacy and ad settings on each platform.
Sharing Your Personal Information
In addition to any sharing listed above, we may disclose anonymised data (such as aggregated statistics) about the users of our services in order to describe our sales, customers, traffic patterns and other information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will not contain your personal data.
We may occasionally be required by law, court order or governmental authority to disclose certain types of personal data.
We may also share your information with third parties in the following situations, to the extent permitted by law:
If we think doing so is necessary to protect the rights, property, security, or safety of us, our service, our users, or the public
To enforce our General Terms or any other agreements we have in place with you
To investigate and defend ourselves or others against any third-party claims or allegations
While negotiating or in relation to a business transaction, such as a merger, change of control, sale of assets, or bankruptcy.
HOW LONG DO WE KEEP YOUR INFORMATION?
We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, meeting our legal and regulatory obligations, resolving disputes and enforcing our agreements. The length of time for which we keep different types of personal information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them.
When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuse of our services, and audit requirements. To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we will delete it securely. Where we wish to retain any information for analysis purposes, we will first anonymise it to the standards approved by the UK Information Commissioner’s Office, (which, as we are based in the UK, is our lead regulator on matters relating to data protection) so that it can no longer be linked back to an individual. Please note that if you opt out of receiving marketing from us, we will still need to keep your contact details in order to suppress them from future marketing activity.
OUR INFORMATION SECURITY PROMISE
We strive to protect your personal data and our services from unauthorised access to or alteration of your personal data. This includes using various security measures to protect your personal data held by or on behalf of us, and conducting ongoing reviews of our information collection, storage and processing practices.
YOUR INFORMATION RIGHTS AND CHOICES
The General Data Protection Regulation (GDPR) gives you:
The right to opt out of having your information used for contacting you about our activities. You can opt out of receiving information from Kellman2 Ltd at any time by simply letting us know in writing.
The right to have any inaccuracies in your personal information corrected. We’ll update inaccuracies promptly, and within a month if you are requesting a simple and straightforward change.
Your ‘right of objection’ to certain activities. Data protection law gives you the right to express an objection to how we process your personal information.
Your Right to Erasure. People sometimes refer to this as the ‘right to be forgotten’. Under data protection law, you have the right to ask us to delete any personal information about you that we hold.
The right to access the data we hold about you. If you would like a copy of the personal information we hold about you, you can request it. Please refer to our Subject Access Procedure for more information about how you can do this.
Your Right to ‘Data Portability’. The right to ‘data portability’ aims to enable consumers to re-use some of their personal information online by making it available in a commonly-used, machine-readable format that can be passed to and used by other organisations. However, if you wish to exercise this right, you should let us know in writing and we will provide you with the information as a CSV file.
Your Right to Complain to the Regulator. If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the privacy regulator on the address below. As we are based in the UK, our principal data protection regulator is the UK’s ICO.
Information Commissioner’s Office
Help Line: 0303 123 1113
How do I exercise this right? By writing to us via post, email or telephone. We will respond to your request within 30 days for all reasonable requests.
Note: How you can exercise your rights will depend on the lawful basis on which we process your information.
REPORTING CONCERNS OR COMPLIMENTS
You also have the right to lodge a complaint with the Information Commissioner’s Office about how we manage your personal data.
Your browser also generates other information, including which language the website is displayed in, and your Internet Protocol address (IP address). An IP address is a set of numbers assigned to your computer during a browsing session whenever you access the internet via your internet service provider or your network (if you access the internet from, for example, a computer at work). Your IP address is automatically logged by our servers and used to collect traffic data about visitors to our website. We also use your IP address to help diagnose problems with our server, and to administer our website.
A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
'session cookies' , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
'persistent cookies ', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We use a tool which is based on Wix Analytics technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.
CHANGE TO THE PRIVACY NOTICE
Kellman2 Ltd will review our privacy notice regularly. The terms of this notice may be updated at any time – for example, in the event of legal changes or how we operate. Please do check our website from time to time. If there are any significant changes in the way we process your personal information, we will provide prominent notice on our website or send a notification.