Privacy notice

Introduction

This Privacy Notice (“Notice”) applies to any business entity from time to time controlled by Kin and Carta Holdco Ltd. (whether as a subsidiary company as defined in s. 1159 of the UK Companies Act 2006 or as a controlled company as defined in s. 1124 of the UK Corporation Tax Act 2010). Kin and Carta Holdco Ltd. is incorporated in England and Wales with registered company number 01552113, its registered office is at Kin and Carta, The Spitfire Building, 71 Collier Street, London, England, N1 9BE (“we”, “us” or “our”). Our VAT number is GB 233 250 991.

This Notice details the ways in which we collect, process, transfer and dispose of your personal data.

If you are a resident of California please click this link to see a notice tailored to your region.

Security

We are committed to establishing a trustworthy and secure environment for all your data at rest or in motion. Therefore, we strive to provide top-tier security practices for our data flows through the most contemporary technical and organizational measures.

Who are we and how to contact us

Kin and Carta Holdco Ltd.

Registered office address:
The Spitfire Building
71 Collier Street
London
N1 9B3

Registered in England with company number 1552113
Information Commissioner’s Office registration number Z6651639.

You can get in touch with us in any of the following ways:

• Through this website: https://www.kinandcarta.com/contact/
• By post: Kin and Carta, The Spitfire Building, 71 Collier Street, London, N1 9BE marking it for the attention of the Company Secretariat
• To contact or Data Protection Team: data.protection@kinandcarta.com

If you are a resident of California please click this link to see a notice tailored to your region.

What data we process about you

We may collect and process the following categories of personal data about you:

• Name, contact details, organization, career (such as job title and/or seniority levels);
• Information relevant to the work, service or other relationship we may have with you;
• Business details, bank and financial details, communication and correspondence;
• Information generated by You visiting our website or engaging with us on social media (including, but not limited to, IP addresses, social handles or usernames).

We will take reasonable steps to ensure the accuracy of the information we hold about you. We will not use your personal information unless it is (to the best of our knowledge) accurate and up to date. You can contact us at any time to update the data we may hold about you.

Why we collect your information

We will collect and process your personal data for the following purposes:

• Manage our relationship and administer our business as a part of an agreement with you;
• Guarantee proper and secure functioning of our business operations and streamline our processes in addressing your inquiries and requests in a reasonable and responsible fashion
• Keep you informed of our products or services and market them by appropriate communication methods, unless you’ve objected to us doing so;
• Perform legal obligations or comply with regulatory requirements;
• Fulfil our compliance responsibilities as well as protect our brand and reputation during your use of our websites, systems, applications, tools and others

Where we collect information about you

We collect information from the following sources:

• Our website(s)
• Email/other digital correspondence or subscriptions
• Telephone calls
• Paper communications
• Social media
• Visiting our offices
• Enquiring about or buying products or services from us
• Providing products or services to us
• Trade or other events such as conferences or exhibitions.
• From third parties who we purchase or license data from.
• From publicly available sources either on or offline
• Contractors, shareholders, affiliates, subsidiaries and newly acquired businesses, members of the board of directors, public authorities, previous employers, and educational/membership institutions.

The legal basis we use for our activities

We will use your personal information only as long as the law permits us to, and limited to the purposes for which we collected your data for. This includes, but is not limited to the following circumstances:

• Where you have given consent for us to process your information;
• Where we need to perform the contractual obligations, we have entered with you or the business you are working for or with;
• Where we need to comply with a legal obligation;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Kin and Carta are committed to supporting your personal rights and freedoms. Therefore, in our privacy program, we commit to our objectives:

• To be transparent about our collection, use and dissemination of your personal data;
• To prioritize your rights and freedoms when we consider new processing activities;
• To follow privacy by design principles in all our solutions and processes relevant to the processing of personal data;
• To review and update our practices on a regular basis.

Please note that on some occasions, if you decide not to share certain pieces of your personal data, we may not be able to accomplish some or all of our purposes for the collection of your personal data and this may lead to a total or partial inability to use our website, services, systems, applications or tools.

Data sharing

We may also share some of your personal data with, or process them through the following categories of third parties:

• Marketing agencies who help us promote ourselves or deliver our services;
• Printers, email service providers or other suppliers or systems that help us to send any communications;
• Suppliers providing services to us to help us run our business;
• Where we exchange personal data in relation to our contractual obligations;
• Law enforcement agencies or other government agencies who may require access provided that an appropriate basis for access is available;

We may also share your personal information with other third parties, if and to the extent required by law.

In any case, we require all third parties to respect the security of your data and to treat it in accordance with the law.

International Transfer of Data

As a global company and in relation with the purposes identified above, your data may be transferred internationally. Where your personal data is transferred or accessed outside of its country of origin we will adhere to any protected transfer requirements that the law in your territory requires us to, e.g. Standard Contractual Clauses.

Our representative within the EU is Kin and Carta Services Bulgaria EOOD and our representative in the UK is Kin and Carta Services UK Limited. You can contact them via  data.protection@kinandcarta.com.

Your choices in relation to personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

You also have the rights and choices which you can exercise on the data we hold on you.
Depending on the legislation you are subject to, you may have the right to:

• Obtain access to your personal information;
• Withdraw consent (to the extent that processing by us is based on your consent);
• Object to direct marketing;
• Ask us to correct any errors or delete the information we hold;
• Object or restrict our processing of your information;
• Request that we port your personal information.

For more information or to action these rights, please contact us on data.protection@kinandcarta.com.

Please be aware that we may refuse your request in accordance with applicable law.

Retention and destruction of personal information

We will only retain your personal information for as long as necessary to fulfil the purposes of our collection otherwise relationship with you or to satisfy a legal obligation in accordance with applicable law. This includes but is not limited to the purposes of satisfying any legal, accounting or reporting requirements. When these purposes have ended we will securely destroy or irreversibly anonymise your personal information in accordance with applicable agreements, standards, laws and regulations.

To determine the appropriate retention period for personal data, we consider the purposes for which we process your personal data whether we can achieve those purposes through other means, and the applicable legal requirements. In case of multiple purposes, the retention period may be consistent with the purpose requiring the longer retention of the personal data, provided however that the retained data will be limited to those required for the attainment of such outlasting purpose(s). We will not retain your personal data for longer than is necessary.

For further details about data retention please contact the data protection officer whose details can be found below.

Data Protection Officer

If you have any inquiries regarding Kin and Carta privacy practices, please feel free to raise them with our Data Protection Officer at:
data.protection@kinandcarta.com

You also have the right to complain to the Information Commissioner’s Office if you believe we have not acted within the law or have infringed your rights.
https://ico.org.uk/for-the-public/

Nevertheless, we would request that you contact us in the first instance so we can discuss and find a prompt resolution to any potential concerns you may have in relation to Kin and Carta’s privacy and data protection practices.

Changes

Kin and Carta remains responsible and reserves its rights to change the terms of this privacy notice from time to time.