Kingscote and Palace Investments Limited

Privacy & Data Protection Policy

Policy Statement  
 
‘Talking Kiteboards’ and the ‘Talking Kiteboards Game’ is a trademark of Kingscote and Palace Investments Limited and is also used under licence by Flexifoil International Limited. ‘Flexifoil’ and the ‘Flexifoil Logo’ are trademarks of Flexifoil International Limited and are used under licence by Kingscote and Palace Investments Limited.
 
Kingscote and Palace Investments Limited wants to be transparent about why we need the personal details we request when you engage with us and how we will use them. We take your privacy seriously and your information will be used in accordance with the General Data Protection Policy 2018 (GDPR). GDPR serves one purpose – It protects individuals’ rights regarding personal data balanced against the rights of the organisation holding their personal data. 
 
Kingscote and Palace Investments Limited is committed to protecting the personal data that we collect and process about you. We aim to be clear and transparent and not do anything you wouldn’t reasonably expect. 
 
We collect and use personal data to ensure that we can manage our relationships with our stakeholders and to allow us to communicate more efficiently and effectively. 
 
Please read this policy carefully to understand how we collect, use and store your personal information.  
 
The privacy policy covers the following: 
 
1. Who we are 
2. Where Kingscote and Palace Investments Limited collects its information from 
3. What information may Kingscote and Palace Investments Limited collect about you 
4. How Kingscote and Palace Investments Limited will use the information we collect 
5. Where Kingscote and Palace Investments Limited will disclose your details 
6. How to access, correct or delete your information 
7. How we keep your data safe 
8. How long we store your data for 
9. Links to other websites 
10. Review of this Policy 
 
By providing us with personal information you consent to the collection and use of this information in accordance with this privacy policy. In accordance The General Data Protection Regulation (GDPR) became effective on May the 25th 2018. It became the UK’s new data protection law. The GDPR modifies and extends the outgoing Data Protection Act 1998. We will communicate any changes to this policy via email with a copy of the updated version. If you have any questions about this privacy policy please contact gaming@flexifoil.com 
 
Definitions & Abbreviations  
 
Kingscote and Palace Investments Limited as Data Controllers 
 
Third party platforms such as Microsoft Office 365, Shopify, ClickFunnels, Mailchimp as Data Processors 
 
Information Commissioners Office (ICO) 
 
General Data Protection Rule (GDPR) 
 
The laws governing how your personal data can be used are: 
 
The General Data Protection Law (GDPR) 25th May 2018 
 
The Privacy and Electronic Communications Regulations 2003 
 
1. Who we are?  
 
Kingscote and Palace Investments Limited is a UK based private limited company that designs computer games. Kingscote and Palace Investments Limited is registered as a company in England & Wales (registration number 02709479). The registered office address is 11 Southdown Road, Hersham, Surrey KT12 4PP, United Kingdom. 
 
2. How do we collect information from you?  
 
Information you give us via Third Party Platforms 
 
Kingscote and Palace Investments Limited obtain personal information from you when, for example, you enter a competition. We use third party platforms such as Mailchimp for competition sign ups. We will only receive data from third parties in this way if you have given your consent for your data to be passed on to us. You should check their Privacy Policy when you provide your information to understand how they will process your data. Data obtained in this manner will be covered by this privacy policy. 
 
Consent to receive communications from Kingscote and Palace Investments Limited
 
You will have to actively opt in to receive communications from Kingscote and Palace Investments Limited, boxes are not pre-ticked. 
 
Data collected through newsletter sign-ups will be Full Name and Email address. To subscribe you have actively opt-in. 
 
You can unsubscribe at any time, by clicking unsubscribe or by contacting Kingscote and Palace Investments Limited via phone or email.  
 
Information we get from your use of our website and services.
 
We may collect information about the services you use and how you use them, like when you watch a video on YouTube, Facebook, visit our websites or view and interact with our ads and content. 
 
Information in the public domain 
 
We may obtain some information from publicly available sources such as Companies House, newspaper articles or open postings on social media such as Facebook and LinkedIn. 
 
3. What type of information is collected from you?  
 
Different information is required from different stakeholders, for example: 
 
Customer, purchase and delivery information must be collected during the sales process so orders can be fulfilled. These details are stored within our database and in a third party email communication tool for 15 years or until you request to be removed from the database. Your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions. 
 
Competition Entrants and Newsletter Subscribers have only their Names and Email addresses and Country of residence stored securely in a third party email communication tool for 15 years or until you request to be removed from the database. 
 
Supplier’s data (Full Name, Email address and Full Business Details as well as notes on previous, current and future involvement) will be stored in the Kingscote and Palace Investments Limited database for 15 years or until you request to be removed from the database. 
 
The type of personal information that Kingscote and Palace Investments Limited collects may include: 
 
Your title and name 
Your contact details (address, email, phone number) 
Contact preferences 
Your IP address, location, browser type and information on how you interact on our website 
If you purchase a product or service from us, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions, as explained below. 
Any other information provided by yourself at the request of Kingscote and Palace Investments Limited. 
 
Where appropriate we may also ask you further demographic questions, but we will never make these question mandatory, and only want to know the answer if you are comfortable providing us with that information. 
 
In some limited circumstances, the personal information that Kingscote and Palace Investments Limited collects may include information that is considered “sensitive data”. This may include personal information regarding demographics. 
 
17 or Under 
 
We are concerned to protect the privacy of children aged 17 or under. If you are aged 17 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information or when sending sensitive information to anyone online. 
 
4. How is your information used?  
 
We will mainly use your data to: 
 
Send you communications through our newsletter or promotional emails 
 
Provide you with the services, products or information that you asked for; as well as information about other services, products or information we think might interest you where you have consented to being contacted 
 
Administer your product purchase 
 
Send you surveys 
 
Invite you to relevant events 
 
Keep a record of your relationship with us and record the contact we have with you 
 
Ensure we know how you prefer to be contacted 
 
Use anonymised data to create statistics 
 
Details will never be passed on to third parties unless specified otherwise 
 
Tools may be used to improve the effectiveness of Kingscote and Palace Investments Limited communications with you, including tracking whether you open the emails we send you and which links you click within a message. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us. 
 
5. Who might we share your information with  
 
We will not share your information with any third parties for marketing purposes. We are committed to protecting your data and therefore it will never be disclosed or sold to external organisations other than those acting as agents and data processors carrying out work on our behalf. Where we enter into a relationship with an external party, any such arrangements will be subject to a formal agreement between Kingscote and Palace Investments Limited and that organisation to protect the security of your data. They only act under our instructions and we maintain full responsibility for your data. 
 
Third Parties Kingscote and Palace Investments Limited work with: 
 
Data processors (for example Microsoft 365, Shopify, ClickFunnels, Mailchimp and other third party platforms) which are compliant with GDPR. 
 
When you are using our secure online payment pages, your payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us. 
 
Suppliers 
 
6. How you can access and update your information  
 
We continuously review records of customers and subscribers to ensure your data is as accurate as possible and always appreciate it if you let us know if your contact details change. If you change email address, or any of the other information we hold is inaccurate or out of date please email us at gaming@flexifoil.com. 
 
You have the right to ask for a copy of the information we hold about you. 
 
7. How will we store your information and keep it safe?  
 
Prior to the deadline of the GDPR policy on 25th May 2018 a data review has been carried out. During the audit all existing data was reviewed and updated or deleted as appropriate. Existing users were contacted and given the option to opt into future communications. 
 
Kingscote and Palace Investments Limited store personal details on a database system which can only be accessed by Kingscote and Palace Investments Limited staff. The system is password protected. If products are bought, personal information will also be stored with our ecommerce platform. 
 
Kingscote and Palace Investments Limited accessible by relevant staff only. Password protected Excel files are only saved on the desktop of a password protected device with up to data anti –virus protection for the duration that they are needed. Data is only printed if absolutely necessary and shredded immediately after use. 
 
The information provided will be securely stored within our database and our third party email communication tool. Your data will only be accessed by authorised personnel and authorised parties who are responsible for the maintenance and security of our digital systems. Within our offices all of our staff receive training on handling data securely. 
 
In the event of staff leaving the company user accounts will be removed and passwords changed. 
 
An up to date anti-virus software is installed on all devices with access to personal information. 
 
Passwords are changed every 6 months. 
 
In case of breach Kingscote and Palace Investments Limited will notify both users and the ICO within 72 hours. Despite all of our precautions no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we will always strive to protect your personal information, we cannot fully guarantee the security of any information which you disclose to us and so wish to draw your attention that you do so at your own risk. 
 
8. For how long will we store your data  
 
You have a choice about whether or not you wish to receive information from us. We will store full details that are customer, supplier, competition entrant or subscriber relevant on our database for 15 years after you opted-in or purchased. You can request your details to be removed from the database at any time. 
 
If you do not want to receive direct marketing communications from us then you can opt out by emailing us gaming@flexifoil.com or clicking ‘unsubscribe’ on any email communication you receive from us. 
 
If you request to opt out of communications your account will be made ‘dormant’ and the data will still be visible for reference but you will no longer be contacted. You can request for your data to be deleted by emailing gaming@flexifoil.com and your data will be deleted from all systems. 
 
If you request that we stop sending you emails we will usually keep a record of your contact details to enable us to comply with your request not to be contacted by us, we won’t keep any information that we don’t need. 
 
9. Links to other websites  
 
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. 
 
We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our website. 
 
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site. 
 
10. Review of this Policy  
 
We keep this Policy under regular review. This Policy was last updated: 7th April 2023
 

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