1.0 Introduction

Keela is committed to protecting your personal privacy. This Privacy Notice is to help you understand how we collect and use information about you.
We hope that the contents of this Privacy Notice will answer your questions but if not please contact us. Contact details can be found in the “Any questions for us” section at the end.

2.0 Who We Are

Keela International, also known as Keela
When you are using the Keela website, Keela is the data controller and as controller we are responsible for, and control the processing of, your personal data.
Our website address is: https://keelatactical.com

3.0 The Legal Basis For Collecting And Processing Your Personal Data

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Contractual Necessity
In certain circumstances, we need your personal data to comply with our contractual obligations. For example:-
If you order an item from us for home delivery, we’ll collect your address details and pass them to our courier

Legitimate Interests
In certain situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example:-

– We may use your purchase history to send you or make available personalised offers
– We may also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services
– We may use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you

Legal Compliance
We may process your personal data if we have a legal obligation to do so, for example to co-operate with an investigation pursuant to a court order.

Consent
In specific situations, we can collect and process your data with your consent. For example, when you tick a box in order to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

4.0 When Do We Collect Your Personal Data?

– When you create an account with us
– When you visit our website, and use your account to buy products and services, or redeem vouchers on the phone, or online
– When you make an online purchase and check out as a guest (in which case we just collect transaction-based data)
– When you purchase a product or service by phone or by email but don’t have (or don’t use) an account
– When you engage with us on social media
– When you contact us by any means with queries, complaints etc.
– When you ask one of our team to email you information about a product
– When you enter prize draws or competitions
– When you book any kind of appointment with us or book to attend an event
– When you choose to complete any surveys we send you
– When you comment on or review our products and services
– Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the member of our team who helped you, it may be passed on to them if requested
– When you’ve given a third party permission to share with us the information they hold about you
– When you leave a comment (including images)

5.0 What Sort Of Personal Data Do We Collect?

– If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
– Details of your interactions with us via phone or email or online. For example, we record notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, wish list choices, voucher redemptions, web pages you visit and how and when you contact us.
– Details of your visits to our websites and which site you came from to ours
– Personal details which help us to recommend items of interest. For example, you might tell us your clothing size, which we then may use to guide our suggested items.
– Your comments and product reviews
– To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
– Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback
– Information gathered by the use of cookies in your web browser – please see our Cookies Policy
– When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
– If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
– If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
– Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

6.0 How And Why We Use Your Personal Data?

Our aim is to give you the best possible customer experience. One way we can achieve this is by combining the data we have about so that we can offer you promotions, products and services that are likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers so that we can provide them the highest level of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are your rights over your personal data?’ section below.
However, please remember that if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:-
– To process any orders that you make by using our website, by phone or email. If we don’t collect your personal data we won’t be able to process your order and we won’t be able to comply with our legal obligations. For example, we may need to pass your details to a third party to supply or deliver the product that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
– To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
– To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
– To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
– If we discover any criminal activity or alleged criminal activity through fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
– With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on – of course, you are free to opt out of hearing from us by any of these channels at any time
– To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest – of course, you are free to opt out of hearing from us by post at any time.
– To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
– To display the content that is likely to be of most interest to you on our websites, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
– To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
– To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
– To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
– To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. Of course, you are free to opt out of receiving these requests from us at any time.
– To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured by Keela and by third parties (for example list of attendees at trade shows) and data from other publicly-available lists as we have described in the ‘What Sort of Personal Data do we collect?’ section above. We will do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends.

Please note that Keela does not buy lists.

7.0 Who Do We Share Your Personal Data With?

We sometimes share your personal data with trusted third parties, but only in order to fulfil contractual necessity e.g. we would share your address details with couriers so that they could deliver an item that you have bought from us.
We will never share your personal data with a third party for their own purposes e.g. so that they can market their products to you.
In order that your data is kept safe and that your privacy is protected we apply the following policy when sharing your data with a third party:
– We provide only the information they need to perform their specific services
– They may only use your data for the exact purposes we specify in our contract with them
– We work closely with them to ensure that your privacy is respected and protected at all times
– If we stop using their services, any of your data held by them will either be deleted or rendered anonymous
– Visitor comments may be checked through an automated spam detection service.

8.0 How We Protect Your Personal Data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
Access to your personal data is password-protected and payment card information is secured and tokenised to ensure it is protected.
We secure access to all transactional areas of our websites using ‘https’ technology.

9.0 How Long Will We Keep Your Personal Data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

10.0 Where Your Personal Data May Be Processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).
For example, if you are based outside the EEA and place an order with us, we will transfer the personal data that we collect from you to our UK business where your data will be treated with care in accordance with this Privacy Notice.
If you live outside the EEA we may transfer personal data that we collect from you to a third party (e.g. a courier) who is based outside the EEA so that we can fulfil our contractual obligation and deliver a product to you.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA.

11.0 What Are Your Rights Over Your Personal Data?

An overview of your different rights
You have the right to request:
– Access to the personal data we hold about you, free of charge in most cases
– The correction of your personal data when incorrect, out of date or incomplete
– That we stop using your personal data for direct marketing (either through specific channels, or all channels)
– That we stop any consent-based processing of your personal data after you withdraw that consent
– Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision)
– You have the right to request a copy of any information about you that Keela holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Keela, 52-53 Nasmyth Road, Glenrothes, Fife , KY6 2SD. To ask for your information to be amended, please update your online account, or contact our Sales team.
– If we choose not to action your request we will explain to you the reasons for our refusal

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Your right to withdraw consent:-
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest:-
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing:-
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity:-
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

12.0 How Can You Stop The Use Of Your Personal Data For Direct Marketing?

There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop sending these email communications to you.
If you have an account that has “preferences” settings, log in into your account and change your preferences
Write to Keela at 52-53 Nasmyth Road, Glenrothes, Fife , KY6 2SD.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

13.0 Contacting The Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

14.0 Any Questions For Us?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
However, if you have any questions or concerns please write to us at Keela, 52-53 Nasmyth Road, Glenrothes, Fife , KY6 2SD.

Privacy Notice last updated 24th May 2018