Depending on how you wish to interact with KIKOS, we may need to collect personal information from you and share some of it with 3rd parties on a need-to-know basis.
This diagramme summarises the main types of data we will collect from you and the 3rd parties we will share it with.
We collect personal data from you so that we can perform our service, which is to help you book a shared day trip. This data is used for communication between us, payments and compliance with various legal obligations.
We may also use some data for our research, in order to improve our service to you. In this case however, this data will be in an aggregated and de-personalised form so that you cannot be identified either directly or indirectly.
We will only keep your personal information for the time needed to provide you with our service and satisfy any regulatory requirements. After that, unless you explicitly consent to us keeping it for longer, we will destroy it or anonymise it so that it is no longer personal and cannot be associated with you.
You can always request a copy of the data that we hold on you, free of charge. Just contact us with your request and we will respond straight away. Please note that we will need to verify your identify first!
In accordance with the latest regulation on data protection in Europe (GDPR frame), you have the right to request from us to erase any data we hold on you (provided this is justified and does not conflict with our regulatory requirements), amend it for you (if it is incomplete or inaccurate), restrict its usage (in certain cases) and send it to you in a machine-readable format.
You also have the right to file a complaint if you feel that our practices are not inline with the applicable law.
For the purposes of this document, in line with GDPR, the terms “personal data” and “personal information” mean any information which identifies you or which allows you to be identified when combined with other information. The term “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
KIKONCEPT LTD (“We”), registered in the United Kingdom, under Company No. 11338727 and registered office at 20-22 Wenlock Road, N1 7GU, London UK, are the controller responsible for the processing of your personal data that is collected through KIKOS.
We may also process personal data for the benefit of 3rd parties such as (i) the supplier (operator) of your boat trip, (ii) dedicated payment service providers that we employ to process your payments and (iii) any competent local authorities (such as the local Port Authority). In this case we are the processor of personal data. If we are the processor of your personal data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect the following categories of data:
When you register through KIKOS we collect the following identity and contact information that you voluntarily provide to us:
We need this information in order to communicate with you as we try to provide you with the service that you expect of us, which is to find a shared day trip for you, invite you to it and facilitate the booking procedure.
If you contact us for any reason (including leaving to us comments or complaints), we may keep a record of that correspondence to the extent that such record is necessary to provide you with the service you have requested us, to improve our quality of services in the future and to comply with any relevant record-keeping laws and regulations. We will not share any Correspondence Data with 3rd parties without your consent, unless we are required by law to do so.
We will collect and store Transaction Data in order to comply with our corporate obligations (accounting and tax reporting) as set out by the law. Transaction Data means all information about transactions (bookings of trips) you have made through KIKOS, including but not limited to the details of your booked trip and any related amounts paid by you to us or to the boat operators.
Transaction Data does not mean personal financial information, such as bank account details. Such information may be included under Financial Data, as described below.
When your credit or debit card account information is being transmitted through KIKOS, it will be protected by cryptographic protocols. To be clear, KIKONCEPT does not itself store your credit or debit card account information, and we do not have direct control over or responsibility for your credit or debit card account information. We use specialised 3rd party payment processors (such as PayPal and MangoPay) that are the controllers of your credit card information. Our contracts with these 3rd parties that receive your credit or debit card account information require them to keep it secure and confidential. We would urge you however to read carefully through their individual policies on data privacy.
When you book a boat trip and prior to your embarkation, you are required by law to provide to the local Port Authority certain identifying details about yourself and all other passengers that are travelling with you under your booking. These details are used to complete forms such as the Charter Party and the Passengers' List which are required by law. The details may include full name, email address, phone number, passport or ID card number, date of birth, gender and nationality for each passenger.
Typically, these details are collected by the boat trip operator and conveyed to the local Port Authority. For convenience, the boat trip operator may request a copy of the ID card or the photo page of the passport for each of the passengers, as such copy would contain most of the required information. Such copies however may include further information than what was outlined above. By providing such copies you consent to the processing of this information.
To facilitate the booking process, we may from time to time collect these details from you in order to convey them to the boat trip operator. However, we will not use any such data that is in excess of the Identity & Contact Data for any other purpose than what is described in this clause and we will duly erase it from our records as per the Data Retention clause in this Policy.
Information from 3rd party sources:
If you use a 3rd party service to register to KIKOS (such as Facebook or Instagram), some information about you from your public profile may automatically be shared with us, depending on whether the 3rd party service and your account settings allow such sharing.
With regards to any information other than your name, email address and mobile phone number, that may have automatically been shared with us by such 3rd party services in the process of your registration to KIKOS, we commit (i) not to use or share it with other parties and (ii) to duly erase it from its systems.
We may automatically receive and store certain anonymous types of information whenever you interact with KIKOS. Such information may include the user's IP address, domain server, and type of Internet browser. Furthermore, we may ask you from time to time to complete anonymously surveys that we use for research purposes, although you do not have to respond to them. This information helps us, among other things, to analyse trends and improve our service to you. This information is anonymous and contains no personally identifiable data.
We may also collect and process Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity. For example, we may aggregate information about how you use KIKOS (traffic data) in order to understand how we can improve our platform and service you better. We will never link such information to your identity.
The safety and privacy of children is extremely important to us. If you are aged 16 or under you are considered a “Minor”.
Minors are strictly prohibited from registering into KIKOS. If we learn that a Minor has registered into KIKOS, we will terminate this person's account and delete as soon as possible all personally identifiable information that we may hold on this person. If you believe that a Minor may have registered into KIKOS, we kindly ask you to contact us at email@example.com straight away.
We may only receive and process personal details of Minors that are travelling with you under your booking in the context of complying with the requirements of the local Port Authority as described in Section II (Additional Identity Data) and for no other purpose. As mentioned in this section, we will duly erase these details from our records as per our Data Retention clause (at the latest within 1 week after the completion of the trip).
We use information held about you in the following ways:
We will only process your personal data if we have a lawful basis for doing so, such as consent, contractual necessity, legitimate interest or legal obligations as described below:
We process the following categories of personal data as a matter of contractual necessity. This means that without this data we cannot perform our service to you:
|Identity & Contact Data||Additional Identity Data||Financial Data|
|(used to communicate with you in order to invite you to shared trips, offer related assistance or support, enforce our Terms and Conditions of Use or resolve disputes)||(used to comply with legal requirements to the local Port Authority prior to your embarkation)||(used to make payment through our 3rd party payment processors, PayPal or MangoPay)|
|Full name||Full name †||Credit/debit card details required to make electronic payment|
|Email address||Passport or ID card No. †|
|Mobile phone number||Date of birth †|
|† Also required for all other passengers travelling under your booking|
We process the following categories of personal data in cases where we think it promotes the legitimate interest of KIKONCEPT or the relevant boat operators, including the improvement of our products and services, discreet marketing of our products and services, provision of customer support, protection from fraud and compliance with legal obligations:
|Identity & Contact Data||Correspondence Data||Transaction Data|
|Full name||Any communication content from you to us||Details of your booked trips and amounts paid|
|Mobile phone number|
In addition, we may process non-personal data to improve our services, such as IP address(es), anonymous surveys or any aggregated traffic data on KIKOS.
We process any personal data held by us to comply with legal obligations, or if requested by a competent public authority.
All information you provide to us via KIKOS is stored on our secure servers. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Once we have received your personal information we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information we cannot guarantee the security of your personal information transmitted to or through KIKOS; any transmission is at your own risk and we cannot be held responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information. We will notify you and any applicable regulator of any data breach that is likely to have unfavourable consequences for your privacy in accordance with applicable law.
We do not rent or sell your personal information to anyone. We may share your personal information on a need to know basis with the following 3rd parties:
What we will share with them
Suppliers of boat trips (boat trip operators) and, more specifically, the ones that are providing the trip(s) that you have booked.
We will share with them your Identity & Contact Data and Additional Identity Data, which they will need in order to complete all charter documents required by applicable law prior to your embarkation (such as the Charter Party and the Passengers' List), as well as any Correspondence Data on a need to know basis.
Payment service providers (such as PayPal and MangoPay)
We will share your Financial Data, which they will need to process your payments.
Competent public authorities
We will share with them any personal information that may be required by applicable law (such as your Additional Identity Data in the context of completing all charter documents prior to your embarkation).
Protection of KIKONCEPT and Others
We may release personal information when we believe in good faith that such release is necessary in order to:
Under the General Data Protection Regulation you have the right to:
You can request to obtain, within reasonable time and free of charge, information on whether or not your personal data are being processed. You can also request a copy of such personal data being processed in an intelligible form.
If you believe that any personal data that we are holding about you is incomplete or inaccurate, you can request that we supplement or correct as appropriate. We may need to verify, however, the accuracy of the new data you provide to us.
You can request that we delete or remove personal data where
If you make such a request under one or more of these cases and applicable law prevents us from executing it, we will inform you accordingly.
You can contact us to let us know that you object to the further use or disclosure of your personal data for certain purposes, such as if you feel that such use or disclosure impacts your fundamental rights and freedoms. In some cases however, we may demonstrate that we have compelling legitimate grounds to use or disclose your information which override your rights and freedoms.
You can ask us to suspend further processing of your personal data in the following cases:
You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
You have the right to file a complaint at any time with the competent supervisory authority about KIKONCEPT LTD's practices in processing your personal data. We would, however, appreciate the chance to address your concerns before you file any such complaint, so please contact us in the first instance at firstname.lastname@example.org.
To exercise any of these rights, please contact us at email@example.com. We may request you to provide us with certain information, which may include personal data, in order to verify your identity and nature of your request. We will respond to your request within the applicable statutory term.
You will not have to pay a fee to exercise any of these rights in a legitimate manner. If, however, your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee or, alternatively, we may refuse to comply with your request.
What is a cookie
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device. The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site. Cookies cannot be used by themselves to identify you.
Types of cookies we use
We use the following types of cookies:
|Strictly necessary||These are essential for the operation of our website. They do not record identifiable personal information and we do not need your consent to place them on your device.|
|Performance||They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.|
|Functionality||We use Functionality Cookies to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences and various settings on our Site The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites. By using our websites, you agree that we can place these types of cookies on your device.|
|Targeting||These cookies are used to deliver advertisements that are more relevant to you and your interests. They remember that you have visited our website, the pages you visited and the links you have followed. This information may be shared with other organisations such as our advertising partners.These cookies are used by trusted third parties to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. Information contained in these cookies is anonymous and doesn't contain your personal information.|
Should you wish, you can reject cookies completely by changing the settings of your browser. If you do this, however, you may not be able to access all or parts of KIKOS.
Third party cookies
We use popular social network sites like Facebook and Instagram to originate or syndicate some of our content. As a result, if you visit one of our pages on these sites, or a page on our site which has content embedded from them, you may be presented with their cookies. We do not control these cookies. You should check the relevant site for more information about the cookies placed on external third party sites.
We will retain your information for the period necessary to provide you with the service that you have instructed us (which is to assist you with the booking of a shared day trip) and as otherwise needed to satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period, we consider the nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and all applicable legal requirements. For instance:
In some circumstances we may anonymise your personal data (so that it exists in a depersonalised or aggregated form and can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
KIKOS may include links to 3rd party websites and plug-ins. Clicking on those links or enabling those connections may allow 3rd parties to collect or share data about you. Furthermore, 3rd party websites may contain links to KIKOS. We do not control these 3rd party websites and are not responsible for their privacy policies and encourage you to read carefully their individual privacy policies.
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