Privacy Policy – KOP Consultancy

Privacy Policy Effective date: January 22, 2019 KOP Consultancy operates the http://www.kopconsultancy.com website. We are committed to protecting the privacy of those individuals whose personal data is shared with us, in compliance with The Data Protection (Jersey) Law 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). KoP Consultancy Limited provides Project Management, Business Analysis, Training and Consultancy services. This Privacy Statement informs you of our policies regarding the collection, use, and disclosure of personal data when you use our services and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from http://www.kopconsultancy.com Data Controller Data Controller: KoP Consultancy Limited Company Registration Number: 1118707 Registered address: 1 Silver Sands, La Grande Route de la Cote, St Clement, Jersey, JE2 6SB. Contact: Mike Thorpe, Managing Director Tel: +44 1534 857252 Email: mike.thorpe@kopconsultancy.com Information Collection and Use We collect several different types of information for various purposes to provide and improve our Service to you. How we collect data

Directly from the individual, e.g. verbally, via emails, via business cards and in documentation such as proposals, information requests, our registration form;
From third parties such as referees, or through publicly available sources such as social media platforms or company websites;
Automatically via cookies during your use of our website.

Types of Data Collected Personal Data While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Mobile number
Company address
Cookies and Usage Data

How we protect data We take comprehensive measures, technical and organisational, to safeguard personal data. These include policies and procedures to deal with any suspected data breach, and business continuity measures to enable us, in the event of any circumstances arising that may otherwise interrupt the delivery of our service to you, to continue to be able to access and process your data. If we use a third party to process personal data on our behalf (e.g. an IT services provider) we will check that they have suitable measures in place to protect your personal data, and seek to make this a condition of our contract with them. Usage Data We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. Tracking & Cookies Data We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

Use of Data KoP Consultancy uses the collected data for various purposes:

To provide and maintain the Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer care and support
To provide analysis or valuable information so that we can improve the Service
To monitor the usage of the Service
To detect, prevent and address technical issues

Data subject rights The Data Protection Law (Jersey) 2018 and the GDPR confer rights on individuals in relation to their personal data. You have the right to:

be informed about the personal data we process about you;
access to the personal data we process about you;
rectification of your personal data;
erasure of your personal data in certain circumstances;
restrict processing of your personal data;
data portability in certain circumstances;
object to processing of your personal data that was based on public or legitimate interest;
not to be subjected to automated decision making and profiling; and
to withdraw consent (where applicable) at any time.

Right to object to the processing of personal data: you have the right to object to our processing of your personal data where the processing is carried out for one of the following reasons:

our legitimate interests;
to enable us to perform a task in the public interest or exercise official authority;
for direct marketing purposes; or
for scientific, historical, research, or statistical purposes.

We are most likely to be processing data for our legitimate interests or for direct marketing. If you object to us processing your personal data for direct marketing purposes, we are obliged to stop the processing. If you object to us processing personal data of yours that we are processing in our legitimate interests, we must stop processing the data unless we can demonstrate compelling legitimate grounds for processing which override your interests or that the processing is necessary for the establishment, exercise or defense of a legal claim. Right to request access / data subject access requests: you have the right to request confirmation from us as to whether your personal data is being processed by us as the data controller (or on behalf of us) and if so, you have the right to request information regarding aspects of the processing and access to your personal data. We will not charge you for giving you access to personal data of yours that we hold, unless your request is ‘manifestly unfounded or excessive’ or if you are requesting further copies of information that we have already provided to you. In these cases, we may charge you a reasonable administrative cost where permitted by law. We may also request further information from you to enable us to verify your identity. Where we are legally permitted, we may refuse to act on your request but if we do we will provide reasons and information about your rights in relation to this. Right to rectify personal data: if any personal data we hold about you is inaccurate or incomplete, you have the right to make a written request that we rectify the personal data. If we are satisfied that the personal data we hold is accurate and complete, we are entitled to take no further action. So that the information we have is about you is accurate and complete, please keep us informed of any changes to your personal information. Right of erasure / right to be forgotten: you have the right to request that we erase personal data we hold relating to you in certain circumstances such as:

the information is no longer necessary for the purpose for which it was originally collected and/or processed;
you have withdrawn your consent to us processing your data, and there is no other valid legal reason for us to continue processing;
the basis on which we process your personal data is because we believe that it’s necessary to do so for our legitimate interests and you object to the processing on that basis and we are unable to demonstrate any overriding legitimate grounds for our continued processing;
you object to the processing of your personal data for direct marketing purposes;
the data has been processed unlawfully;
it is necessary for the data to be erased for us to comply with our legal obligations as a data controller.

We are entitled to refuse to comply with the request for erasure to the extent that the processing is necessary for any of the following reasons:

to exercise the right of freedom of expression and information;
to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to establish, exercise or defend a legal claim.

Right to restrict processing: you have the right to request that we restrict the processing of your personal data where one of the following circumstances applies:

you contest the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted while the accuracy of the data is verified;
our processing of your data is unlawful, but you prefer us to restrict our processing, not erase;
we have no further need to process your personal data but you need it to establish, exercise, or defend legal claims;
you object to our processing your personal data for our legitimate interests or public function, in which case you can request the data be restricted while we verify our grounds for processing your personal data.

If you obtain a restriction of processing of your data, we will still be able to store your data but we won’t be able to continue to process it unless you consent or the processing is for the purposes of legal proceedings, vital interests (i.e. matters of life or death) or in the public interest. We will inform you before we lift any such restriction. In relation to the rights of rectification, erasure and restriction of processing, if we have shared the personal data with third parties, we will notify them about the rectification or erasure of personal data or restriction of processing, unless this is impossible or involves disproportionate effort. If requested by you, we will also tell you which third parties we have disclosed the personal data to. In the event that we think that it’s reasonable for us not to comply with your request, we will explain our reasons for this decision and inform you of your rights in relation to this. Right to data portability: your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. You have the right to obtain and transfer your personal data between data controllers, so you can reuse your personal data for your own purposes across different services. This right of data portability applies where the personal data:

has been provided to us by you; and
is processed based on your consent or in order to fulfil a contract; and
is processed automatically.

We will provide you with your data in a commonly used machine-readable format or where technically feasible we may directly transfer the data for you. In dealing with your request for data portability we may request further information from you in order to verify your identity. Where we think that it is reasonable for us not to take any action in relation to one of the above requests, we will explain our reasons for this decision and your rights in relation to this. Transfer Of Data If you are located outside Jersey or United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. KOP Consultancy will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information. Automated individual decision-making: we will never make any decisions about you based on purely automated means. Right to complain: you have to the right to lodge a complaint with the Office of the Information Commissioner, whose contact details are: Telephone: +44 1534 716530 E-mail: enquiries@oicjersey.org Address: Office of the Information Commissioner, Brunel House, Old Street, St Helier, Jersey JE2 3RG Website: www.oicjersey.org Disclosure Of Data Legal Requirements KOP Consultancy may disclose your Personal Data in the good faith belief that such action is necessary to:

To comply with a legal obligation
To protect and defend the rights or property of KOP Consultancy
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability

Security Of Data The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Service Providers We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Links To Other Sites Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. Children’s Privacy Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers. Changes To This Privacy Policy We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Contact Us If you have any questions about this Privacy Policy, please contact us:

By email: mike.thorpe@kopconsultancy.com
By visiting this page on our website: http://www.kopconsultancy.com/contact-us