KEYSTONE PRIVACY NOTICE

KEYSTONE PRIVACY NOTICE

This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

General Data Protection Regulations (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.

Keystone uses the information collected from you to make telephone contact or to email you in connection with our business. In you making initial contact you consent to Keystone maintaining a marketing dialogue with you until you optout (which you can do at any stage).

Some personal data may be collected about you from the forms and any surveys you may complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses. Keystone may from time to time use such information to identify its visitors. Keystone may also collect statistics about the behaviour of visitors to its website.

Our website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We use cookies to help identify and track visitors and your website access preferences. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Keystone website.

As part of our terms of business, Keystone will collect, process, secure and use personal data to provide quality service for customer and business needs. Any information Keystone holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtain about you from public sources and our own suppliers.

We are committed to being transparent about how we collect and use the data and meeting our data protection obligations. Keystone will only collect the information needed so that it can provide you with our services, we will never sell or broker your data.

The address and contact details of the data controller (Keystone) are set out at the end of this privacy notice.

1|Page

PrivacyNotice_1.0

What information do we collect?

Keystone collects a range of information about you. This includes:

2|Page

PrivacyNotice_1.0

Where necessary, we may keep information relating to your health and criminal convictions. This information will be used to comply with our legal and compliance obligations – we will also need this data to administer and manage our service to you.

Where we are processing data based on your consent, you have the right to withdraw that consent at any time.

In keeping with Keystone’s data security policies, we may monitor and record telephone conversations. We may also keep computer records by way of the Relay system and Relay iCloud system.

If in the future, we intend to process your personal data for a purpose other than that which it was collected we will provide you with information on that purpose and any other relevant information.

Who has access to your data?

Your information may be shared internally for legitimate business purposes only. This includes all employees of Keystone involved in the provision of a service to you, managers in the business area and IT staff if access to the data is necessary for the performance of their roles.

We will only disclose information about you to third parties, by consent, if we are legally obliged to do so or where we need to comply with our contractual duties to you, for instance we will need to pass on certain information to our list of approved insurance providers.

Keystone may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Keystone requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Keystone do not broker or pass on information gained from your engagement with the agency without your consent. However, Keystone may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Keystone, its clients and/or the wider community.

How does Keystone protect your data?

We take the security of your data seriously. We have technical measures and internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

3|Page

PrivacyNotice_1.0

For how long does Keystone keep data? Retention policy

Keystone will process personal data during the duration of any contract and will continue to store only the personal data needed on a manual file, on the Relay Applied Systems Software application and, on the Relay iCloud system. Your data will be held for a period of 7 years. This is to allow us to meet our legal obligations.

Data storage

Data is held on-site in Ireland using the Relay Applied Systems Software. Data is backed-up to the Relay iCloud servers based in Ireland. Keystone does not store personal data outside the EEA.

Your Rights

As an Data Subject you have a number of rights. You can: