Privacy Policy
Welcome to Kepler Interactive Limited’s privacy policy.
Kepler respects your privacy and is committed to protecting your personal data. This privacy policy
will inform you as to how we, our indirect and direct subsidiaries (collectively described as “Kepler”,
we”, “us” or “our”) and our third party marketing and advertising partners look after your personal
data, and tells you about your privacy rights and how the law protects you. This privacy policy applies
to the personal information we process when you visit (https://www.kepler-interactive.com/ ) and any
other websites operated by us, or when you use any applications or games operated by us, regardless
of where you access them from. It also applies to our marketing and advertising activities on all
platforms and any other services that we may provide to you from time to time. In this privacy policy
we refer to our websites, applications, games, marketing and advertising activities and other services
collectively as our "Services".
1.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Kepler collects and processes your personal
data through your use of the Services, including any data you may provide when you sign up to a
newsletter, purchase a product or service or take part in a competition.
The Services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing
policy we may provide on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This privacy policy supplements
other notices and privacy policies and is not intended to override them.
Controller
Kepler Interactive Limited is the data controller and is responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights,
please contact us using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the
following ways:
Address: Kepler Interactive Limited
7 Savoy Court
London WC2R 0EX
United Kingdom
Email address: legal@kepler-interactive.com
You have the right to make a complaint at any time to the UK Information Commissioner’s Office
(“ICO”), the UK regulator for data protection issues (https://ico.org.uk/ ). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so please contact us
in the first instance.
Third-party links
This website or our other Services may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party services and are not responsible for their privacy
statements. We encourage you to read the privacy policy of every website you visit.
2.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
data).
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together as follows:
Identity Data: includes first name, maiden name, last name, username or similar identifier,
marital status, title, date of birth and gender.
Contact Data: includes billing address, delivery address, email address and telephone numbers.
Financial Data: includes bank account and payment card details.
Transaction Data: includes details about payments to and from you and other details of products
and services you have purchased from us.
Technical Data: includes internet protocol (IP) address, your login data, browser type and version,
time zone setting and location, browser plug-in types and versions, operating system and
platform, and other technology on the devices you use to access our Services.
Profile Data: includes your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
Usage Data: includes information about how you use our Services.
Marketing and Communications Data: includes: your preferences in receiving marketing from us
and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data could be derived from your personal data but is not considered personal
data in law as this data will not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal data which will be used in accordance
with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health, and genetic and biometric data). Nor do we collect
any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you,
and you fail to provide that data when requested, 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 goods or services). In this
case, we may have to cancel a product or service you have with us but we will notify you if this is the
case at the time.
3.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms
or by corresponding with us by post, phone, email or otherwise. This includes personal data you
provide when you:
o apply for any of our products or Services;
o create an account on our website;
o subscribe to our service or publications;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us feedback or contact us.
Automated technologies or interactions. As you interact with our website and other Services,
we will automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit other websites employing
our cookies.
Third parties or publicly available sources. We will receive personal data about you from various
third parties and public sources as set out below:
o Technical Data from the following parties:
analytics providers such as Google;
advertising networks; and
search information providers.
o Contact, Financial and Transaction Data from providers of technical, payment and delivery
services.
o Identity and Contact Data from data brokers or aggregators.
o Identity and Contact Data from publicly available sources.
4.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with
you.
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.
Where we need to comply with a legal obligation.
Please see the definition of “lawful basis” in section 10 below to find out more about the types of
lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we
will get your consent before sending third party direct marketing communications to you via email or
text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground
has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including
basis of legitimate interest
To manage our relationship
(a) Identity
(a) Performance of a contract with
with you which will include:
you
(b) Contact
(a) Notifying you about changes
(b) Necessary to comply with a legal
(c) Profile
to our terms or privacy policy
obligation
(d) Marketing and
(b) Asking you to leave a review
(c) Necessary for our legitimate
Communications
or take a survey
interests
(to keep our records
updated and to study how customers
use our products/services)
To enable you to partake in a
(a) Identity
(a) Performance of a contract with
prize draw, competition or
you
(b) Contact
complete a survey
(b) Necessary for our legitimate
(c) Profile
interests
(to study how customers
use our products/services, to develop
(d) Usage
them and grow our business)
(e) Marketing and
Communications
To administer, protect,
(a) Identity
(a) Necessary for our legitimate
improve, personalise and
interests (for running and expanding
(b) Contact
expand our business (including
our
business,
provision
of
developing new products,
administration and IT services,
(c) Technical
services, features, and
network security, to prevent fraud
functionality) and Services
and in the context of a business
(including troubleshooting,
reorganisation or group restructuring
data analysis, testing, system
exercise)
maintenance, support,
(b) Necessary to comply with a legal
reporting and hosting of data)
obligation
To deliver relevant content and
(a) Identity
Necessary for our legitimate interests
advertisements to you as part
(to study how customers use our
of any of the Services and
(b) Contact
products/services, to develop them,
measure or understand the
to grow our business and to inform
(c) Profile
effectiveness of the advertising
our marketing strategy)
we serve to you
(d) Usage
(e) Marketing and
Communications
(f) Technical
To use data analytics to
(a) Technical
Necessary for our legitimate interests
improve our Services,
(to define types of customers for our
(b) Usage
marketing, customer
products and services, to keep our
relationships and experiences
Services updated and relevant, to
develop our business and to inform
our marketing strategy)
To make suggestions and
(a) Identity
Necessary for our legitimate interests
recommendations to you about
(to develop our products/services
(b) Contact
goods or services that may be
and grow our business)
of interest to you
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think
you may want or need, or what may be of interest to you. This is how we decide which products,
services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the
opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, warranty registration, product/service
experience or other transactions.
Cookies
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 this website may
become inaccessible or not function properly.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain
the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
5.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table
in section 4 above.
Internal Third Parties as set out in section 10.
External Third Parties as set out in section 10.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their
own purposes and only permit them to process your personal data for specified purposes and in
accordance with our instructions.
6.
International transfers
Your personal data may be transferred to, stored, and processed in a country other than the one in
which it was collected. It may also be processed by staff operating outside the UK and the European
Economic Area (“EEA”) who work for Kepler Interactive Limited, other legal entities owned by Kepler
Interactive Limited or for our or their third-party service providers. In such cases, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
we will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data; and/or
we may use specific contracts approved for use in the UK and the EEA which give personal data
the same protection it has in the UK and the EEA.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the UK or the EEA.
7.
Data security
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have
a business need to know. They will only process your personal data on our instructions and they are
subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.
8.
Data retention
How long will you use my personal data for?
We will only retain your personal data 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. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship
with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal, regulatory, tax, accounting or other
requirements.
In some circumstances you can ask us to delete your data: see section 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes, in which case we may use this information indefinitely
without further notice to you.
9.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
data:
Request access to your personal data (commonly known as a “data subject access request”).
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing of your personal data.
Request the transfer of your personal data to another party, when possible.
Right to withdraw consent.
For further details on these rights, please see “YOUR LEGAL RIGHTS” in section 10. If you wish to
exercise any of the rights set out above, please contact us and specify which right(s) you wish to
exercise.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to receive it. We
may also contact you to ask you for further information in relation to your request to speed up our
response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
10.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make
sure we consider and balance any potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We do not use your personal data
for activities where our interests are overridden by the impact on you (unless we have your consent
or are otherwise required or permitted to by law). You can obtain further information about how we
assess our legitimate interests against any potential impact on you in respect of specific activities by
contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Kepler Interactive Limited and other companies owned by Kepler Interactive Limited acting as joint
controllers or processors, who are based in the UK and provide IT and system administration services
and undertake leadership reporting.
External Third Parties
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers who
provide consultancy, banking, legal, insurance and accounting services.
Tax authorities, regulators and other authorities acting as processors who require reporting of
processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This
enables you to receive a copy of the personal data we hold about you and to check that we are lawfully
processing it.
Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the
accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have the right to ask us to
delete or remove your personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will be notified to you,
if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of
a third party) and there is something about your particular situation which makes you want to object
to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct marketing purposes. In
some cases, we may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third
party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us
to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your consent.
11.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 7 March 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.