How Kybri Consulting Limited collects, uses and protects personal data.
Kybri Consulting Limited is a company incorporated in the Isle of Man. We provide business and regulatory consulting services to businesses operating in the digital sector. In this policy, “the business”, “we”, “us” and “our” refers to Kybri Consulting Limited.
This website collects personal data from users and visitors. Please read this privacy policy carefully, as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint.
Personal data is any information that can identify an individual, either directly or when combined with other data, as well as data concerning health, sex life or sexual orientation. The data subject is the individual that the personal data relates to.
We collect, use and retain certain personal data about you subject to the Isle of Man Data Protection Act 2018 and/or the United Kingdom General Data Protection Regulation (UK GDPR). This personal data enables us to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.
How we collect your data. Directly from you (telephone, text, email) and via our website (for example, registration and during the course of the business relationship with you). We may also collect information from credit reference agencies, due diligence providers, sanctions screening providers, third parties such as banks and building societies, website cookies and IT systems (for example, performance monitoring and tracking solutions).
Why we use your personal data. Your personal data can only be used if there is a valid reason: to comply with legal and regulatory obligations; where you have given your consent; for the execution and pre-requisites of a contract with you; for our legitimate interests; or for a third party’s legitimate interests.
What we and third parties use your personal data for. To create and manage your account with us; to improve our services; preventing and detecting fraud against you or us; providing services to you; auditing; investigations; regulation; legal requirements; compliance; privacy; analysis; security; statutory requirements; marketing; and credit checks.
Who we may share your personal data with. Regulators, credit reference agencies, insurers, banks, social media platforms, marketing agencies, law enforcement agencies, regulatory bodies, auditors and service providers. If you would like more information about who we share data with and why, please contact us.
We take all reasonable measures to ensure third parties take appropriate actions to protect your personal data. It may be necessary for us to share your personal data with third parties outside the Isle of Man and UK if you are based outside the Isle of Man and UK, or where there is an international element to the services we are providing to you.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the Isle of Man and the UK where: the UK government has decided the country or organisation has an adequate level of protection (an “adequacy decision”); there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or a specific exception applies under data protection law, for example where you have explicitly consented to the proposed transfer after being informed of the possible risks, or the transfer is necessary to establish, exercise or defend legal claims. Other countries we may transfer data to may not have an adequacy decision; this does not necessarily mean they provide poor protection, but we must rely on alternative grounds such as appropriate safeguards or an exception. Please contact us for further information.
Your personal data may be held at our offices and by third-party agencies, service providers, representatives and agents, and will be kept for as long as you have an account with us or we are providing services to you. Once you terminate your account, or there is a period of 12 months of no activity, we will keep your personal data for as long as is necessary to respond to any questions, complaints or claims made by you or on your behalf, to show that we treated you fairly, and to keep records required by regulation and law. We will not keep your personal data for longer than necessary, and when it is no longer necessary we will delete or anonymise it.
We, and third parties, may use your data for marketing purposes. You have the right to opt out of receiving marketing communications at any time by contacting us.
You have the following rights, which you can exercise free of charge: access (a copy of your personal data); rectification (correction of mistakes); erasure (deletion in certain situations); restriction of processing (in certain circumstances, for example if you contest the accuracy of the data); data portability (receiving the data you provided in a structured, commonly used, machine-readable format, and/or transmitting it to a third party, in certain situations); the right to object at any time to processing for direct marketing (including profiling) and, in certain other situations, to our continued processing, for example processing carried out for our legitimate interests; and the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of these rights, including the circumstances in which they apply, see the Isle of Man Information Commissioner or the UK Information Commissioner’s Office. To exercise any of these rights, please contact us.
You also have the right to lodge a complaint with the Isle of Man Information Commissioner, the UK Information Commissioner or any relevant European data protection supervisory authority. The Isle of Man Information Commissioner may be contacted at inforights.im/contact-us or on +44 1624 693260. The UK Information Commissioner may be contacted at ico.org.uk/make-a-complaint or on 0303 123 1113.
We have implemented appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator where we are legally required to do so. For guidance on protecting your own information, see Get Safe Online.
Please contact us if you have any questions about this policy or the information we hold about you. Use the contact form at kybri.io/contact, or write to our registered address: Kybri Consulting Limited, Flat 5 Derby Court, 42 The Promenade, Castletown, Isle of Man, IM9 1BG.
