Privacy Policy

Last Updated: 3 February 2019

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This privacy notice tells you how we will collect and use your personal data.

Privacy and security are central to our work and will always endeavour to reply to your queries as quickly as possible.

Who are we?
 Kinzen’s mission is to put every individual in control of a daily news routine that respects their time, rewards their trust and broadens their minds. The Kinzen service is provided by Kinzen Ltd, a private company registered in Ireland.


What’s covered by this Privacy Notice?

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Where Kinzen Ltd processes personal data on its own behalf or where personal data is processed on its behalf, it is the Data Controller for all the data collected. If Kinzen Ltd processes data on a 3rd party’s behalf, it is the Data Processor for that 3rd party.


Why does Kinzen Ltd need to collect and store personal data?

In order for us to provide you with Kinzen Ltd’s services we need to collect personal data for correspondence purposes and/or for administrative purposes required for by our contractual obligations to you or others. In any event, we are committed to ensuring that the information we collect and use is appropriate for the purposes for which it is collected. Kinzen Ltd is a company which values its users’ data protection and privacy rights and we have no interest in collecting data beyond what we need to make the Kinzen Ltd services work for you.

If you are going to be contacted by us for marketing purposes, we will not rely solely on this notice, but will always seek an additional confirmation from you that it’s OK to do that.

In general we collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interactions with Kinzen Ltd. We are committed to transparency in this. If you require a more detailed account of how we use your personal data, we will will be happy to respond to requests made to privacy@kinzen.com


Our legal bases for processing personal data are:

  • Article 6.1(b), GDPR, Contract
  • Article 6.1(a), GDPR, Consent
  • Article 6.1(f), GDPR, Legitimate Interest
  • Any processing by us, or third parties we may use, relying on Art 6.1(f) is as follows:
  • Emergency Contacts for people who work with us, such as employees and Contractors for Health and Safety purposes.


The special categories of personal data which may be processed are:

  • Any special categories of special personal data which any user volunteers while using the Kinzen Ltd systems or any Kinzen Ltd website- for example in an email or personal statement form.
  • Any Health Data in respect of employees, contractors and other people who work with us which is supplied to us as part of our contractual relationships.


Will Kinzen Ltd share my personal data with anyone else?

Kinzen Ltd is a privacy focused organisation and our aim is to ensure that we don’t process or share your data any more than is absolutely required to deliver our services. But there are some times when we have to share your personal data with third-party service providers contracted to Kinzen Ltd in the course of dealing with you. For example, our Payments are handled by Apple and Stripe and our email is handled by Intercom and Mailchimp. We do this because these are some contractual services, such as managing the payments for our services, which will not work unless we are able to make these transfers. But you can be sure that any third parties that we share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our- and of course, your-behalf.

When they no longer need your data to fulfil this service, they will dispose of the details in line with Kinzen Ltd’s procedures. If we do need to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or if it is necessary to comply with a contract or we are legally required to do otherwise. If you would like an up-to-date register of all our third-party service providers, please contact us and we will be happy to provide it.


How will Kinzen Ltd use the personal data it collects about me?

Kinzen Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Kinzen Ltd maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed for the minimum amount of time required to meet the purpose for which it was collected. Kinzen Ltd is required to retain certain information in accordance with the Law, such as employee information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.


Can I find out what personal data Kinzen Ltd holds about me?

Kinzen Ltd at your request, can confirm what information we hold about you and how it is processed. If Kinzen Ltd does hold personal data about you, you have the right to request the following types of data:

  • The identity and the contact details of the person or organisation that has determined how and why to process your data (the Data Controller).
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Kinzen Ltd or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
  • You also have the right to make certain requests of us regarding your personal data. Each request will be assessed and acted upon as appropriate within the relevant statutory time limits.
  • Depending on the sensitivity of the data about you being released, we may ask you to verify your identity to protect your own data’s security.


You control your data

Agreeing to these terms is an unambiguous indication of your Consent to the processing outlined in it. By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for Kinzen Ltd to process both standard and sensitive types of personal data, but it must be explicitly given, your agreement to the terms set out in this Privacy Notice will suffice to demonstrate that consent.

If we ask you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice or any accompanying contractual Terms and Conditions (as applicable) (or any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.

You may withdraw consent at any time by the following process: Please identify your role in relation to Kinzen Ltd (if you are a user, Staff member, a 3rd party etc.), and the data you wish to withdraw consent to be processed.

Most data held by Kinzen Ltd is not held solely on the basis of consent, and where there is an alternative legal basis- such as legal requirement or contract- withdrawing consent may not result in our immediate erasure of data being stored or processed.


Data Transfers

Kinzen Ltd will pass on your personal data to certain third parties. Kinzen Ltd is an Irish company, working in a global market and it uses cloud services which may be accessed by Kinzen Ltd employees in any part of the world.

Details of the non-EU organisations to which we pass data and the legal safeguards we use to protect your data when we send it outside the EU to those organisations.


Third country (non-EU)/international organisation

Our advertising service partners sets cookies and collects information from your browser across the web and infers connections between your browsers and devices. This information is used to better understand your interests in order to select and deliver relevant advertising and offers, manage the frequency or ads you see, provide measurement and reporting to advertisers like us about the performance of their ads and helps our advertising service partners and us better understand web audiences.

We have different sections to our services with different partners;

Our iOS Mobile App only shares data with the following services;

  • Intercom
  • Mailchimp
  • Typeform
  • Facebook
  • Specifically we only share your opt-in Apple ID For Advertisers identifier when you make a purchase in our app. Furthermore we intentionally protect you by sending this IDFA via our servers and not directly from the iOS Mobile App. Kinzen never shares your name, email, or IP address with Facebook.

Our membership website at join.kinzen.com only shares data with the following services;

  • Google
  • Intercom
  • Mailchimp
  • Typeform

Our community website at community.kinzen.com shares data with the following services;

  • Mailchimp
  • Google

Our marketing website at kinzen.com shares some data with the following services;

Please note that kinzen.com does not know your name or email address, it is separate from our iOS Mobile App and other websites.

Safeguards in place to protect your personal data

Use of the EU’s Standard Contract Clauses, Privacy Shield and/or binding corporate rules as appropriate


Retention period

Kinzen Ltd will process different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact privacy@kinzen.com.


Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Where Kinzen Ltd are your Data Controller, you may make a request or query directly to the relevant privacy officer of the company using the email privacy@kinzen.com.
Where Kinzen Ltd are a Data Processor, and act on behalf of a Data Controller (such as a 3rd party partner company in a different country) any requests received by Kinzen Ltd will be passed on to the Data Controller.


Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Kinzen Ltd (or third parties as described above), or how a complaint has been handled, you have the right to lodge a complaint directly to with our supervisory authority.

The details of Contacts for where Kinzen Ltd are the Data Controller:

Data Controller contact:
Email: privacy@kinzen.com

Data Protection Authority:
Postal address: Data Protection Commission, Canal House, Portarlington, Co. Laois, R32AP23.
Email: info@dataprotection.ie
Telephone: +353 57 8684800

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