We are committed to protecting the privacy of all users of our website kingpinsecurity.co.uk, or mobile applications (together, the "Platform"). Please read this privacy policy that explains how we use and protect your personal information. We are the "controller" of the information we process, unless otherwise stated.

1. Contact Details

If you have any queries or requests about this privacy policy or how we handle your information more generally, you can get in touch by contacting us at [email protected]

2. How We Collect Your Information

We collect your information when you interact with us or use our services to help us improve our services and optimise client experience.

We collect information:

• 1. when you create a client/employee account with us or you change your account settings;
• 2. through your interactions with us or our services, such as when you request information or to receive marketing, information about Kingpin Security initiatives or other communications from us by email, phone, post, SMS, push notification, or via our chat function;
• 3. when you participate in a competition, prize draw, promotion about our services, or our businesses’ services; and
• 4. when you browse or use our Platform (before and after you create an account with us).

We also collect information from third party sites, such as advertising and social media platforms and our fraud detection provider. If you link your social media or your third-party accounts to us, we will keep a record of your social media handle, and the other information that is made available to us according to your social media account settings.

3. Information We Collect From You

As part of our commitment to the privacy of our clients and visitors to our Platform more generally, we want to be clear about the sorts of information we will collect from you.

We collect information about your use of the Platform and information about you from any messages you post to the Platform or when you contact us or provide us with feedback, including via email, post, phone or chat function. If you contact us by phone, we record and make notes about the call, including for training and service improvement purposes.

We collect information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Platform. We also collect technical information about your use of our services through a mobile device, for example, carrier, location data and performance data such as mobile payment methods, interaction with other retail technology such as use of NFC Tags, QR Codes and/or use of mobile vouchers. Unless you have elected to remain anonymous through your device and/or platform settings, we automatically collect and use this information if you use the service through your mobile device(s) via any Kingpin Security mobile application, through your mobile's browser or otherwise.

Where we need to collect information by law, or under the terms of a contract we have with you, and you fail to provide that information, 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 our services). In this case, we may have to cancel our service to you but we will notify you if this is the case at the time.

4. Use Of Your Information

We will only process your information if there is a reason for doing so, and if that reason is permitted by law.

Where we need to provide you with the service you have requested or to enter into a contract with you, we use your information to:

• enable us to provide you with access to the relevant parts of the Platform, we collect necessary cookies from your device.

We also process your information where we have a legitimate interest for doing so, which are to:

• improve the effectiveness and quality of service that our clients can expect from us in the future;
• enable our customer support team and our businesses to help you with any enquiries or complaints that you submit to us or our businesses in the most efficient way possible and to provide a positive customer experience;
• contact you for your comments and feedback regarding our Platform and services or our businesses’ services and/or products;
• notify you if there are any important changes or developments to the Platform or our services;
• let you know that our services are operating in a new area, where you have asked us to do so;
• send you information by post about our products, services, promotions and Kingpin Security initiatives (if you do not want to receive these, you can let us know by getting in touch (Please see “Contact Details” section);
• analyse your activity on the Platform so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud;
• prepare anonymous and aggregate reports (which do not contain your information) used to analyse and improve the performance of our services and partnerships; and
• detect, investigate, report and seek to prevent fraud or crime.

We also process your information to enforce our contractual terms with you and any other agreement, to ensure compliance with our internal policies and procedures and for the exercise or defence of legal claims and to protect the rights of Kingpin Security, our partners, or others (including to prevent fraud).

When you use our security services, we may ask you to leave a review. We share this feedback with other Kingpin Security visitors.

When you respond to surveys we may use the comments and/or feedback you leave on our Platform in our marketing or advertising materials. We will only identify you for this purpose by the name and the city you have provided us, unless you have chosen for your name not to appear on our Sites and in our marketing or advertising materials. We also use your survey comments and feedback to:

• generate aggregated insights to help us to assess and improve our services; and
• share aggregated insights with our partners to enable them to assess and improve their services.

Your name will not be used when generating or sharing these aggregated insights.

We analyse data about your use of the Platform and the services to create profiles relating to you and for you. This means that we make certain assumptions about what you may be interested in and use this, for example, to send you more tailored marketing communications, to present you with partners that we think you will prefer, or to let you know about special offers or products which we think you may be interested in. This activity is referred to as profiling and you have certain rights in relation to this type of processing. Please see “Your Rights” section for more details.

We also use your information:

• to comply with any legal obligation or regulatory requirement to which we are subject.

5. Use Of Your Information

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. For more information about the cookies we use, and how to set or amend your cookie preferences, please see our Cookie Policy.

6. Marketing

Where you have given your consent or where we have a legitimate interest for doing so (and are permitted to do so by law) we will use your information to let you know about our other products and services, or Kingpin Security initiatives that may be of interest to you and we may contact you to do so by email, post, phone, or push notification or in-app message.

We use online advertising to keep you aware of what we’re up to and to help you see and find our products.

We use your information to make sure the online ads we manage are relevant to you and so you may see Kingpin Security banners and ads when you are on our Sites or other third party websites and apps, such as on social media, or relevant third party ads on our Sites. We manage this through a variety of digital marketing networks and using a range of advertising technologies of third party advertising partners (“Advertising Partners”). The banners and ads you see are based on information we hold about you, or your previous use of our services or on banners or ads on our Platform that you have previously clicked on.

You can control your marketing preferences by:

• visiting our website, www.kingpinsecurity.co.uk, or mobile application;
• clicking on your name (for our website this is on the header); and
• scrolling down and clicking on to "Contact Preferences".

Where you have chosen at a device level to begin or continue receiving push notifications from us, we send you push notifications relating to the services that you have requested from us and information about our services, offers and Kingpin Security initiatives. You can choose to stop receiving push notifications from us at any time by changing your preferences on your mobile device.

We use your information to send you communications that are the most relevant to you. You have certain rights in relation to this type of processing. Please see “Your Rights” section for more details.

We use your information to send you communications that are the most relevant to you. You have certain rights in relation to this type of processing. Please see “Your Rights” section for more details.

In addition, when you interact with ads on our Platform or a Kingpin Security ad on a third-party site or app, we or relevant Advertising Partners collect personal information about your interaction with the relevant ad, which is used to provide us with aggregated statistics and reports (which do not contain your personal information) to help to measure the effectiveness of our advertising or third party advertising on our Platform or our Advertising Partners platforms.

We and/or our Advertising Partners use tracking technologies to serve and measure the ads you see. For more information on our use of cookies and other similar technologies (including advertising technologies) and details on how to manage your consent to cookies please “Cookies” section and our Cookie Policy.

7. Automated Decisions

We undertake fraud checks on all customers which is necessary for us to:

• perform our contracted services to customers;
• ensure that our services (and those of all our businesses) provided are duly paid for.

8. Retention Of Your Information

We will only retain your information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. In the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, we retain your information for a longer period.

When determining the appropriate retention periods, we take into account factors including:

• our contractual obligations and rights in relation to the information involved;
• legal obligation(s) under applicable law to retain information for a certain period of time;
• statute of limitations under applicable law(s);
• our legitimate interests for retaining the information (please see “Use of Your Information” section);
• whether there is an actual or potential dispute; and
• guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information where we no longer require it for the purposes we collected it for.

9. Sharing Your Information

The information we collect about you is transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with.

We share your information with third party service providers that provide services on our behalf. The types of third party service providers whom we share your information with include, for example:

• payment providers (including online payment providers and fraud detection providers);
• IT service providers (including cloud providers);
• third parties that send direct marketing, market research surveys, and other communications on our behalf;
• customer support providers (including, but not limited to, companies that assist us to provide customer or technical support); and
• marketing and advertising partners.

We share your information when we promote a programme or offer a service or product in conjunction with a third-party business. We will share your information with that business to assist in marketing or to provide the associated product or service. In most of those cases, the programme or offer will include the name of the third-party business, either alone or with ours.

For more details on how your information may be processed by our Advertising Partners, such as Meta, Google and Criteo please see their respective privacy policies, where you may also find details on how to exercise your data subject rights and option on how to manage your online advertising preferences with them. We may act as joint controllers with Advertising Partners in connection with the processing of information for certain advertising activities as described in their privacy policies. Where we are joint controllers with any Advertising Partners, we enter into an appropriate agreement to set out our respective responsibilities on compliance with applicable data protection obligations in respect of these advertising activities.

Kingpin Security will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and applicable laws when it is transferred to third parties.

If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

We also share your information:

• if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement;
• in order to enforce our contractual terms with you and any other agreement;
• to protect the rights of Kingpin Security, our businesses, or others, including to prevent fraud; and
• with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police or for health and safety purposes.

In some cases the information we collect from you might be processed outside the United Kingdom or the European Economic Area, such as the United States and the countries in which Kingpin Security operates. These countries may not have the same protections for your information as the UK or EEA has. To the extent these countries have not been lawfully recognised as providing an adequate level of data protection, we will ensure that the information that is processed by us and our suppliers outside of the UK or EEA is protected in the same way as it would be if it was processed within the UK or the EEA. We ensure to use an appropriate data transfer mechanism, such as reliance on the protections set out in approved standard contractual clauses.

10. Security

We adopt robust technologies and policies to protect your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have implemented procedures to deal with any data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your information transmitted to the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

When you open an account you may create a password you must use a unique password and keep any password you create, or other secure login method, secret in order to help prevent others from accessing your account.

11. Your Rights

Under certain circumstances, you have rights under data protection law in relation to the information we hold about you.

These include:

• The right of access. This is also known as a “data subject access request”. You have the right to receive a copy of the information we hold about you and to check that we are lawfully processing it.
• The right to rectification. You are entitled to have any incomplete or inaccurate information we hold about you corrected, though in some cases, we need to verify the accuracy of the new information you provide to us.
• The right to erasure. This is also known as “the right to be forgotten” which enables you to request the deletion or removal of certain of the information that we hold about you where there is no good reason for us continuing to process it. This right is not absolute and only applies in certain circumstances.
• The right to restrict processing. You have the right to block or suppress further use of your information in certain circumstances. When processing is restricted, we may still have a lawful reason to store your information, but we will not use it further.
• The right to data portability. You have the right to receive your information in a structured, commonly used and machine-readable format which you can transfer to another service provider or other third party.This right is not absolute and only applies in certain circumstances.
• The right to withdraw consent. Where we rely on consent to use your information, you have the right to withdraw that consent at any time. Withdrawing consent will not, however, make unlawful our use of your information before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you.
• The right to object to processing. You have the right to object to certain types of processing of your information, including processing for direct marketing purposes and profiling. You can object by changing your marketing preferences and disabling cookies as set out in the “Cookies” and “Marketing” sections or by contacting us.
• You have the right not to be subject to a decision based solely on automated processing of your information, such as in connection with our fraud checks.

To exercise any of these rights, please contact our Data Protection Officer in writing at [email protected].

If you are unhappy with how we have handled your information you can contact your local data protection authority. In the UK, this is the Information Commissioner’s Office. We would, however, really appreciate the chance to deal with your concerns before you approach your local data protection authority and so we please ask that you contact us first.

12. Changes To Our Policy

We update this privacy policy from time to time, so remember to check back in every so often, in case anything has changed and, where appropriate, we may notify you of the changes, for example by email or push notification.

This privacy policy was last published on: 17 April 2024

Kingpin Security Ltd