Privacy Notice

The following Services are subject to this Privacy Notice:

• Completing a form on one of our apps or websites.
• Contacting us using call back or online chat features
• Buying or enquiring about Kite products and/or services, whether on- or off-line.
• Taking part in research, for example a survey.
• Using one of our service portals.
• Attending one of our events, or attending one of our kiosks at an event.
• Taking a query from you, for example about the repair or upgrade of a service or product we offer, and fulfilling our obligations to you.
• Our marketing of goods and services we think may be of interest to you and your business.

We collect personal information in the following circumstances:

• When you have expressed interest in a product or service we offer: We will collect your business contact details.  For example, if you approach us online, attend our stall at an event and/or call us about a potential service or product, we will make a note of your details so that we may follow up on your query as well as offering other products and services that may be of interest to your business.
• Upon registering for a Service we offer: You will be asked for several personal details that are necessary to create a service portal account and offer you our Services. Some of these fields are marked as compulsory. If you do not provide us with information which is marked as compulsory we may be unable to provide all or part of the Services to you.
• When you use our Services: We may collect and process personal information regarding your use of such Services to improve your overall experience and to fulfill our obligations to you.
• When we research our market and find potential buyers: To make sure we are reaching the appropriate business audiences, we may from time to time purchase marketing lists and other databases providing contact details. These may contain your name, business email address and business phone number. However, we do not buy marketing lists which contain your private, outside-of-work contact details.
• To improve your user experience and the overall quality of our Services: Knowing your basic personal details lets us  personalise any communications we send to you. For example, we collect your role information to ensure we provide marketing which is relevant to your role in your business.

We go into more detail on how we use the information we collect in these circumstances, below.

1. To Provide Online Accounts
   This is personal information you give us when setting up an online account (for example, our service portals) which personally identifies you rather than your business, such as your name, position within your business, business email address or telephone number. There are a number of reasons we need this information:
   • To verify your identity and assist with the identification of users: For example, your email address may act as your username to sign into your online account and access Kite Services.
   • To send important notices: For example, we ask for your email address so that we can send you a confirmation of your orders or service updates. We will also send you communications about purchases or changes to our terms, conditions, and policies.
2. Responding to customer queries
   Your personal details will be processed to respond to queries and assist with the identification of users. For example, your contact information will be collected when you submit a call back form or use our customer chat features and may then be used as an identifier in future. Whenever you fill in  a form on our website or app, we may store relevant identity data so that we can trace the history of your query and deal with it more efficiently.
3. Events management
   We collect your information to register you for an event, webinar or seminar which you have expressed interest in, process your payment for the event (where applicable) and provide you with the relevant materials for that event:For example, and depending on the kind of event involved, we collect your name, telephone number (please supply your business telephone number only), emergency contact details (where absolutely necessary), dietary requirements and any other information necessary to enable you to get the most out of your experience.
   
4. To learn about your activities
   1. Browsing Behaviour, Device Information and Interaction
      We sometimes record details of your actions (for example, repeated site visits, interactions, keywords, online content production) when you access and use our Services so that we can build a customer ‘picture’ over time. It also includes information about the devices and methods you use to interact with Kite Services and content, including via a service portal.We may combine behavioral information (such as your browsing activity) with your personal details, but we will not store any personal details related to fields left blank by you during your sign-up process. When the use of information which personally identifies you is not necessary to achieve the purposes set out in this section, we will only process behavioral information on an aggregate basis.

      We capture information about your Operating System and Internet Browser when you visit a Kite  website or use our Services, including information that is automatically logged when you use our Services (for example, requested information, timestamp, IP address, and, where applicable and necessary, various network infrastructure and server identifiers).

      We will process your behavioural, device and interactions information for the following purposes:

      • To provide, maintain, protect and improve products and Services, and to develop new ones:
        • For example, information about how you browse our websites or search for products can be used for data analysis and research, to deliver better user journeys, provide more relevant search results or structure the way the information is shown in our Services.
      • To improve your user experience and the overall quality of our Services:
        • Your activity such as the pages you visit or the items you view teaches us what you find important and most interesting to you on our Services so that we can tailor your experience around what matters to you most and display personalised content.
        • Device and platform identifiers let us know which device you are using to access our Services in order to customise and optimise them to your device and improve your overall user experience (for example, providing more relevant content and advertising on the device or browser you are using).
        • Storing data locally on your device allows us to improve things like website performance and loading of content even when you are offline.
      • Subject to the requirements of applicable law, to provide you with marketing communications, for example, more relevant content and offers, and latest news about products and events which we think will be of interest to you and your business:
        • For example, following a link to a tutorial from a marketing email, or following Kite on Facebook or Twitter.
        • Understanding how and where you interact with Kite means we can provide you with more personalised and helpful information through your preferred communication channels.
      • To protect our other users and Kite:
        • We can monitor unusual or suspicious activities on Kite services, such as automated abuse, so that we can address it quickly and inform you about potentially fraudulent activities affecting your account.
        • We might also use your personal information for internal auditing, in order to comply with applicable legal requirements.
   2. Product Details, Product Usage and  Service & Support History
      This is information about your Kite products or solutions (such as service/s provided, software applications and purchase date), of how Kite products or solutions are set up and used (e.g. user set-up and preferences, installation and integration or other settings) and our Services, as well as details on your customer or managed Service,  Licenses held, Warranty and Repairs interactions with Kite. Sometimes, this information is linked to your business, but at other times it must necessarily be linked to you personally.Some of the information under this category does not qualify as personal information, but we will apply any necessary safeguards to ensure as well the privacy of this information. We will process this data for the following purposes:
      • To provide you with more useful information, more relevant content and offers, and latest news about our products, solutions, services and events: For example, personalised and helpful information, such as expert hints and tips, learning resources, software updates, installation or user guides, or details about relevant training courses.
      • To provide, maintain, protect and improve products and services, and to develop new ones: Understanding how our customers use our products help us identify features that we need to improve or add to future products.
      • To help solve any issues you might have with Kite products and Services:
        • We require your product information so that we can troubleshoot your queries more effectively, providing you with information which is specific to your Kite product.
        • Understanding your Operating System (OS) allows us to troubleshoot your query more effectively, for example, by providing you with information about relevant driver downloads.
5. For fulfilment purposes
   In order to support your business and perform our contract for the Services with you, we may need to collect personal data to fulfil orders and perform services. We may need to arrange appointments to do so, and therefore need to get the contact details of someone at your business. Examples include:
   
   
   • when you log a call to arrange for assistance with a service;
   • when you fill in a form we send you about one of our products, including online versions;
   • when we provide to you managed services information such as reporting, usage and utilization;
   • when we identity validation to verify for AML/KYC;
   • when we detect issues with your Kite software or hardware which we need to talk to you about; and
   • when you arrange site visits or equipment collection.
   • When we have to perform technical operations on your IT infrastructure, we may have access to personal data held by your organisation. Where we use third parties for our fulfillment activities, we make sure to choose trusted partners who have the same values that we do.
   • Depending on your role, we may need to use your information to contact you regarding online service availability (for example, updates relating to periodical maintenance) or changes to those services.
6. To find new customers
   To offer our products and services to others who may be interested in them, we sometimes obtain your contact details from our partners in the industry, as well as professional bodies who provide this information to businesses. When we obtain contact details this way we ensure that your contact details are not part of any national opt-out service.
   
7. To send out surveys and use the results to improve our products and services
   Kite occasionally send our customers surveys and feedback forms. Where you provide your name and contact details, we may use these to respond to any feedback, provide you with information we think you’ll be interested to hear given your responses and add you to our marketing database (you can opt out of this during the survey, if you’re not interested).
   
8. Purchase Information
   We keep records about goods and services you buy through Kite Services. These help us to provide, maintain, protect and improve products and services, and to develop new ones. We also send important notices, such as communications about purchases or changes to our terms, conditions, and policies.
   
9. Payment Information
   We do not process or store your bank or credit/debit card details used when purchasing goods and services through Kite Services. Payments for purchases are completed through third-party payment platforms which do not share your banking details with Kite.
   
10. Cookies and other technologies
    Cookies and similar technologies (e.g. web beacons) are small pieces of information used to store technical and/or personal details, identify users of a service and enable certain functionalities. To learn more about the cookies used by our Services and how to reject them, please visit the Cookie Notice applicable to each of the Services, which can be accessed through the homepage of our websites or the relevant section of our apps.
11. Legal and regulatory requirements and other business purposes
    We sometimes need to process your personal information to comply with applicable laws and regulations, for example where we have an obligation to report suspected fraud.There may also be other business-related purposes for processing your information, including negotiating, concluding and performing contracts, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations

Kite will only process your personal information where we have a legal basis to do so.

The legal basis will depend on which of the above purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

• The legitimate business interests of Kite: where it is necessary for Kite to understand our customers, promote our goods, products and Services and operate effectively as an IT service provider and manufacturer of photography products, solutions and Services. For more information see section 1 below.
• Performance of a contract with your business: where you have ordered or requested products or Services from us and we need to use your contact details in order to process your order and deliver the products or Services.
• Compliance with law: where Kite is subject to a legal obligation and needs to use your personal information in order to comply with that obligation.
• Consent: for example, where you have provided information to us voluntarily in order to enter a competition. You can withdraw your consent at any time.

1. Our Legitimate Interests
   Kite’s legitimate interests include where it is necessary for Kite to understand our customers in sufficient detail so we can create and publicise new products and Services, and offer our customers a better experience. For example:
   • We perform analytics on this legal basis as they are necessary to provide you with a tailored experience and so that we can improve, maintain and manage our products and Services in a way which meets your expectations as a customer;
   • We need to use your information so that we can better support your organisation and maintain the products and services which you use;
   • We use lead and campaign management technology to help us analyse how our customers interact with us and ultimately provide more relevant and interesting content to you;
   • We engage in product development to better our products and services and will use your feedback, from surveys and elsewhere, as part of this process; and
   • Like most businesses, where permissible we market new products and services which we think you may be interested in these, always offering you the option to unsubscribe.

1. Within Kite
   We restrict access to personal data to people within our company who have a “need to know” such information. For example, we may pass personal data we collect about you to our local sales businesses or local service centres in order to provide our Services where you are located.
2. Outside Kite, to our partners and third parties
   Except as described in this Notice or where you have provided your consent, the personal information processed when you use our Services will not be shared with or disclosed to other individuals or businesses, for their own use, other than Canon group companies.We may disclose your personal information to the following third parties, amongst others, for the purposes described here:
   • Vendors or other subcontractors with whom we have a business relationship and who  provide products and services to us so that we can provide our Services to you (such as warehousing and delivery, maintenance and servicing partners, software development, website hosting, printing partners and management);
   • Third-party service providers which carry out marketing campaigns, lead generation or run customer surveys on our behalf;
   • Payment processing companies, credit reference agencies and anti-fraud screening service providers in order to process payments and (where necessary) to carry out fraud-screening;
   • With our professional and legal advisers for the purposes of obtaining commercial, financial or legal advice;
   • In the event that we sell any business assets, personal information may be disclosed to a potential buyer. In these circumstances, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Notice;
   • In exceptional circumstances, personal information may be shared with third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets;
   • We may also disclose your personal information if it is necessary to comply with a legal obligation in any jurisdiction, including where that obligation arises as a result of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision).

Your personal information is held on secure servers and is not processed for any purposes other than those set out in this Privacy Notice. The servers Kite uses to store this information are accessible to authorised staff only and Kite ensures that adequate security measures are in place.

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at the contact details below.

We use vendors and service providers based around the world. Consequently, your personal information may be processed in countries outside of the country where you live, including if you live in Europe, and such countries may include some where you may have fewer legal rights in respect of your personal information than you do under local law. If we transfer personal information outside of the European Economic Area to a country that provides a lower standard of legal protection for your personal information, we will ensure that your privacy rights are protected by appropriate safeguards, in particular through the use of the EU’s standard contractual clauses.  Please contact us if you would like more information about these safeguards.

Kite and/or other Canon group companies may use your personal information for marketing purposes and to inform you about other products and services, which Kite thinks might be of interest for you and your business. You can specify whether you wish to receive such information by ticking the appropriate box in our forms, or by telling us your preference where we interact in person.

You will be able to opt out from receiving such information at any time  by unsubscribing using a link/mechanism provided in all applicable communications. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (for example, to confirm an order you have made or to confirm delivery details).

In certain jurisdictions you have the right to access, correct, update, restrict, receive a machine-readable copy of your personal information or delete your data as well as any other right applicable in your jurisdiction. You can request to exercise these rights by contacting us using the contact details set out at the end of this Notice.

We will delete your personal information once it is no longer necessary for the purposes for which it was originally collected.

You also have the right to object to your personal information being used for certain purposes, including to send you marketing. See ‘Marketing Communications’ above, for more details of how to opt-out of marketing.

We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal information, or if you have any questions or concerns regarding your personal information, you should contact us using the details below. You are also entitled to raise your concerns with your local data protection authority.

Kite will keep your personal information for as long as we need it for the purposes set out in section 2 of this Privacy Notice and in accordance with any retention periods required by applicable laws and during the relevant statutes of limitations. This term should typically not exceed 6 years in most jurisdictions. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint about a product or our Services) for as long as is necessary to protect us from a legal claim. Where we no longer have a need to keep your personal information, we will delete it. Please note that where you unsubscribe from our marketing communications, we will keep a record of your communication information to ensure we do not  market to you in future.

Kite will not delete your personal information where it refers to an active relationship or a product or service explicitly requested by you ( for example, a recent purchase).

You guarantee the quality of the information provided in our Services. All personal information you send to Kite must be real, accurate and kept up to date. You take full responsibility that your information is accurate, updated and that it complies with this principle.

We will update our Privacy Notice from time to time to ensure you are promptly informed of Kite’s data processing activities. We will not engage in any processing operations that might put  at risk your personal information, and will gather your explicit consent where necessary to safeguard your right to privacy. We will keep you updated on any changes to this Privacy Notice through the Services. We will also use any of the communication methods provided by you to inform you on important changes to this Privacy Notice. If you continue using our Services after having been unequivocally informed on the updated Privacy Notice, you agree to be bound by the updated terms

Please contact Kite with any questions or comments about this Privacy Notice  directly at DataProtectionOfficer@canon-europe.com.

We hope that Kite will be able to resolve any concerns you may have. However, if you are still not satisfied, you may raise your concerns with your local data protection authority.

In the Privacy Notice, “Kite” shall mean  Kite Tech Ltd. with its registered address at 3 The Square, Stockley Park, Uxbridge, UB11 1ET, UK (a Canon group company) and/or its affiliates  and is referred to in this notice as “we”, “us”, “our” or “Kite”.

Last Modified: 2018-05-25

Version: 1.0