PRIVACY POLICY

We respect your privacy. We are committed to safeguarding the privacy of our Site visitors. Please read this document carefully as it sets out our ‘Privacy Policy’ which informs you of our privacy practices, the way your data is collected online, how that information is used and how we share, transfer and protect that information.

This Privacy Policy applies to our Site, apps and other official related products, sites, communications and services, but excluding services which are offered under a different privacy policy or services provided by third parties.

Who Process Your Data

  1. Throughout this document, “Company”, “K&T CAPITAL”, “we”, “us”, “our” and “ours” refer to
    • K&T Capital Ltd. (“Data Controller”)
    • Address: 65 Compton Street, London, United Kingdom, EC1V 0BN
    • Contact e-mail: privacy@ktcapital.com

Data We Collect and Receive

  1. We may collect or receive data, which may include the information voluntarily provided in the course of email communication, publication of materials or information collected automatically.
  2. We collect information from you when you subscribe to our newsletter, voluntarily provide us the information in email communication, respond to a survey or fill out a form. You may visit our Site anonymously. Among the types of Data that this Site collects, by itself or through third parties, there are: Cookies, Usage data, Personal Data.

Data You Provide Us With

  1. When you communicate with us, sent any content or messages, or provide any other information within the Site, we may process all of this information.

Data We Collect Automatically

  1. The browser or a client program may transfer certain information about the details of visits to the Site, including
    • information about traffic, log-files, user activity information;
    • Internet Protocol (IP) address and unique device identifiers (such as your device ID, advertising ID, MAC address, Android ID, IMEI) for any device (computer, mobile phone, tablet, etc.);
    • general location data;
    • browser and device information, operating system;
    • URL address that referred you to the Site, search terms you entered into a search regime that led you to the Site, and other information commonly shared when browsers communicate with websites.

Cookie Files

  1. In order for the Site to function properly, we may use Cookies. Cookies are small bits of record-keeping text information that are automatically created and stored in your computer or other device in order to associate and identify your activity (“Cookies”). Cookies do not typically include names and/or email addresses and/or other Personal Data. In fact they typically contain anonymous information that is required for the better functionality of the Services.
  2. Web Beacons. We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as "web beacons" or "tracking tags" to help us keep track of what content on our Website is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Site, to monitor how K&T CAPITAL Users navigate the Website, to count how many e-mails that were sent were actually opened, or to count how many particular text information units were submitted.
  3. Embedded Scripts. An Embedded Script is programming code that is designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Website.
  4. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
  5. Cookies stored on your computer or device through which you use the Site have amongst others but without limitation, the following functions:
    • Authentification. Cookies help us show you the right information and personalize your experience.
    • Security. We use cookies to enable and support our security features, and to help us detect malicious activity.
    • Preferences and Features. Cookies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Site more easily. They also provide you with features, insights, and customized content.
    • Marketing. We may use cookies to help us deliver marketing campaigns and track their performance. Similarly, our partners may use cookies to provide us with information about your interactions with their services, but use of those third-party cookies would be subject to the service provider’s policies.
    • Performance, Analytics and Research. Cookies help us learn how well our Site perform. We also use cookies to understand, improve features, including to create logs and record when you access our Sites from different devices, such as your work computer or your mobile device.
  6. We may use third-party analytics providers (collectively “Third Party Analytics Providers”).
    • Google Analytics (Analytics Cookies)
      Our Site uses Google Analytics, a web analysis service by Google, Inc. (“Google”). Learn more from their Terms of Service and Privacy Policy.
      To Opt-out: Download the browser plugin “Google Analytics Opt-out Browser Add-on” here.
    • Google AdWords (Marketing Cookies)
      Our Site uses the Google AdWords Conversion Tracking cookie to measure and optimize the performance and user experience related to our ads in Google Search or selected Google Display Network sites. Learn more about Google’s privacy policy here.
      To Opt-out: Visiting Google’s Ads Settings.
  7. These Third-Party Analytics Providers use Cookies on our Site. The information generated by the Cookies about your use of our Sites, may be transmitted to and stored by Third-Party Analytics Providers’ servers, which may also be located outside of the European Economic Area. The Third-Party Analytics Providers will use this information on our behalf for the purpose of evaluating your use of our Sites, compiling reports on website activity, and providing other services relating to website activity. The terms of cookies storage by a third-party shall be established by the respective third party.
  8. We allow third parties to set the following cookies on this Website:
    Cookie / technology Google Analytics
    _ga Persistent cookie: 2 years from set/update
    _gat Persistent cookie: 10 minutes from set/update
    _gid Persistent cookie: 24 hours from set/update
    _cfduid Persistent cookie: 1 year from set/update
  9. You can control and/or delete cookies as you wish by changing your browser settings. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.

How We Use Your Data

  1. We use your information, which is necessary:
    • to provide the Site and address your inquiries;
    • to administer and develop our business relationships with you and, if applicable, the company you represent; and for the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy;
    • to enable us to provide you with access to the Site and to enable you to review the materials and information on the Site;
    • to contact you with administrative communications and K&T CAPITAL newsletters, communicate with you, respond your comments and questions and send you information about features on our Site or changes to our policies;
    • to analyze and monitor the use of the Site;
    • to manage our relationship with you;
    • to administer, support, improve and develop the Site.
  2. You may opt out of receiving promotional communications from us. To find out how to do this, please refer to section “Request That We Stop Using Your Data”.

Who We Share Your Data With

  1. We share information we collect about you in the ways discussed below and only when necessary for the performance of a contract with you, compliance with a legal obligation to which we are subject, or based on our legitimate interests. We are not in the business of selling information about you to advertisers or other third parties.
    • Hosting Services: we may use third-party companies to host information or provide other infrastructure that helps with the delivery of our Site.
    • Service Providers: We may employ third party companies and individuals to facilitate our Site (including without limitation maintenance services, database management, web analytics and online advertising, fraud detection and improvement of K&T CAPITAL`s features).
    • Links to Third-Party Sites: the Site may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.
    • Sharing anonymous information: we also may share with third parties, anonymous or aggregated information, or other data that does not directly identify you, for instance to show trends about use of the Site.
    • Change of control: we may share your data as part of our company’s sale, merger or change in control, or in preparation for any of these events. Any entity that buys us, or part of our business, will have the right to continue using your data, but only in the manner set out in this Privacy Policy, unless you agree otherwise.
  2. Any third party, agent or representative of K&T CAPITAL who imports personal information in the course of providing services to K&T CAPITAL is required to keep that information confidential and comply with national data protection laws or, where applicable, to be bound by appropriate contractual obligations that protect your personal information.

International Transfers Within the Subsidiary or Affiliate Companies

  1. To facilitate our global operations, we transfer information to the companies based in the countries outside the European Union and allow access to that information from countries in which our owned companies have operations for the purposes described in this policy. These countries may not have privacy and data protection laws equivalent to the laws of many of the countries where our users are based. When we share information about you within and among corporate affiliates, we make use of standard contractual data protection clauses that have been approved by the European Commission.

International Transfers to Third-Parties

  1. Some of the third parties described in this privacy policy that provide services to us under contract, are based in other countries that may not have privacy and data protection laws equivalent to those of the country in which you reside. When we share the information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. We will provide you with a copy of the standard data protection clauses upon your request.

Data Retention

  1. We retain your data for as long as is needed to provide you with the Site. We regularly review and de-identify unnecessary data.
  2. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
  3. Marketing information. If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Site. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created.

Security Safeguards

  1. K&T CAPITAL takes reasonable technical and organizational security measures to prevent the loss, misuse, alteration or unlawful disclosure of information you provide to us. Any third party, agent or representative of K&T CAPITAL who requires access to your information is also required to implement reasonable technical and organizational security measures to protect your information.
  2. Please remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your personal data, K&T CAPITAL cannot ensure and does not warrant the security of any information you transmit to us.

Age Limits

  1. We do not knowingly collect or solicit personal data from anyone under the age of 18 or knowingly allow such persons to use our Site. If you are under 18, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal data. If we learn that we have collected personal data about a child under the age of 18, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 18, please contact us.

How To Exercise Your Personal Data Rights

  1. You have certain choices available to you when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.
  2. You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in the “Contact Us” section below to request assistance.
  3. Your requests and choices may be limited in certain cases, such as when fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.
    • Access Your Data (Right of Access): Upon your request, we will provide you with a copy of your personal data in a structured, electronic format.
    • Change or Correct Your Data (Right to Rectification): You can edit some of your personal data (such as your email address) through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
    • Delete Your Data (Right to Erasure): You can ask us to erase or delete all or some of your personal data.
    • Request That We Stop Using Your Data (Right to Object): Where processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing, or the data is necessary for the establishment, exercise or defence of legal claims. You can also opt-out of our use of your information for marketing purposes by contacting us, as explained in the section “Contact Us”. When you make such requests, we may need time to investigate and facilitate your request.
    • Data Portability: Data portability is the ability to obtain some of your personal data in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.
    • You may withdraw consent where processing of your personal data is based on consent, by contacting us as explained in the section “Contact us”. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
  4. We are obliged to respond to your requests without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.
  5. You have the right to complain to the Data Protection supervisory authority within the European Economic Area for unresolved complaints.

Contact US

  1. If you have any questions about how your personal data is collected, stored, shared or used, or if you wish to exercise any of your data rights, please contact us at:
  2. K&T Capital Ltd. (“Data Controller”)

    Address: 65 Compton Street, London, United Kingdom, EC1V 0BN
    
Contact e-mail: privacy@ktcapital.com

Changes to This Privacy Policy

  1. We may change this Privacy Policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice within the Site or by sending you an email notification. We encourage you to review our Privacy Policy whenever you use the Site to stay informed about our information practices and the ways you can help protect your privacy.

Effective Date   October 24, 2018
Updated   October 24, 2018