Scope of this policy
We will collect and process the following data about you:
We will only collect information that is necessary for us to provide you with the product or service that you have requested. The type of information that we may collect will depend upon the nature of that service or product.
We will use your personal data for the following purposes:
We will always use your data according to the principles of:
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have signed up to and/or utilise our services and, in each case, you have not opted out of receiving marketing notifications. We will obtain your express opt-in consent before we share your personal data with any third party for marketing or promotional purposes.
Disclosure of your data
International transfer of data
We are an international organisation, with businesses both inside and outside of the European Economic Area ("EEA"). Third party service providers who handle data on our behalf may be based in locations around the world, and we may also be subject to scrutiny from courts or regulators in a number of different jurisdictions. For these reasons, your Personal Information may be transferred to other countries both inside and outside of the EU and the EEA. As privacy laws in other countries may not be equivalent to those in your home country, we only make arrangements to transfer data overseas where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that Personal Information handled in other countries will receive at least the same level of protection as it is given in your home country, for instance by entering into contracts incorporating the European Commission approved model contract clauses.
Retention of your personal information
We will retain your personal information for as long as is reasonably necessary for the purposes listed above. However, in some circumstances we may retain your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations or to have an accurate record of your dealings with us in the event of any complaints or challenges.
Protection of your personal information
We will hold your personal information securely whilst it is under our control, including where it is processed by third party service providers on our behalf. We train our employees in respect of their obligations under data protection laws, and we ensure that only relevant employees, contractors and agents have access to your personal information. We take the security of our physical premises, our servers and the website seriously and we will take all appropriate technical measures using recognized security procedures and tools in accordance with good industry practice to protect your personal information across all of these platforms. Whilst we use all reasonable endeavours to protect your security in the manner described above, we consider that it is appropriate to advise you that data transmission over the Internet and the World Wide Web cannot always be guaranteed as 100% secure, and therefore that you use the website at your own risk.
Subject to applicable law, you may have some or all of the following rights in respect of your Personal Information:
All questions relating to data and your privacy are welcomed and should be addressed to our support team. If you have any questions, contact our support at https://kobofunds.com/contact-us.
You can also find some helpful guidance on ICO website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/.
In relation to the website, you can update, correct or delete your personal information by referring to the "My Account" section of the website. You can also use the "Update settings" and "Unsubscribe" links in our emails to prevent us from sending you direct marketing communications.