Kontex Security Limited
This notice sets out details of how and why we (“Kontex”) and third parties collect and process personal information in connection with your relationship or associated interactions with us. We do this in compliance with our obligations under applicable data protection law. This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.
This notice applies to the collection and processing of personal information relating to individuals associated with you, such as directors, shareholders, trustees, beneficial owners, employees, representatives, agents, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates or you. You should ensure that this notice is provided to any individual whose personal data has been provided to us as soon as practicable.
Kontex receives and processes personal data collected as part of your engagement with us or associated interactions with us. Kontex may engage third party service providers to process such personal data on its behalf and those third parties act as Processors. If you have any questions about the use of your personal data, your data protection rights or if you want to exercise those rights, please contact [email protected].
Personal Data that we Process
Kontex collects personal data relating to you that is provided to us as part of our due diligence process, both from you and from public sources and in connection with our dealings with you or associated interactions with us, including your name, signature, postal address, email address, fax number, date and place of birth, nationality, curriculum vitae, bank account details, source of funds details, tax identification, credit history, signatures, other contact details, shareholder register, account numbers (or functional equivalent) and transaction details.
We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including your tax or social security ID number or equivalent; passport number; utility bills, photographic identification and verification such as copies of your passport, passport number, drivers licence and address verification.
We may collect and process personal data relating to you in connection with our on-going relationship with you, such as via correspondence and calls, and in connection with the administration of our relationship with you. Telephone calls with you may be recorded for the purposes of record keeping, security and training.
How we obtain your personal information
We collect information from you as part of our client on-boarding take on processes as necessary in the course of establishing a relationship with you. We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff, providing a business card or registering on one of our digital platforms or applications. We may also collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.
Purposes of Processing and Legal Basis
Personal data that you provide, or that we otherwise obtain in relation to you, will be processed for the following purposes:
- Processing the application to become an employee of Kontex.
- To manage and administer your relationship with Kontex.
- To communicate with you as part of your relationship with Kontex.
- Maintaining appropriate business records, including maintaining appropriate registers;
- Where required for local and global tax reporting purposes.
- Internal training and management of personnel.
- To respond to or evaluate any queries or requests for quotations in relation to new software or software renewal with our partner technology providers.
- Internal and external audits and, where necessary, investigations;
- Conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise.
- Preventing, investigating or detecting theft, fraud or other criminal activity.
- Pursuing our corporate and social responsibility objectives.
- Where you are an individual it is necessary to take steps at your request prior to entering into our contract with you and for the performance of our contract with you.
- In certain limited circumstances, your consent.
- For direct marketing purposes (that is, providing information on products and services) or for quality control, business and statistical analysis, market research or for tracking fees and costs or for customer service, training and related purposes.
- Complying with any other legislative and regulatory obligations in connection with our dealings with you.
Recipients of Data
Your personal data may be disclosed to various recipients in connection with the above purposes, including:
- The Board of Kontex (and in certain circumstances where there is legitimate interest, performance of a contract or legal obligation), our or employees.
- Our technology partners where a quotation or renewal has been sought.
- A Competent Authority in the relevant jurisdiction, the Workplace Relations Commission, Department of Social Protection, Pensions Authority, auditors, or equivalent bodies as requested or required by law.
- Other third parties who we engage to provide services to us, such as professional advisers, legal advisers, auditors and IT service providers.
- To screening and other reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations.
In connection with the above purposes your personal data may be transferred outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. These jurisdictions may include the United States of America. If and to the extent that we do so, we will ensure that appropriate measures are in place to protect the privacy and integrity of such personal data and in particular will comply with our obligations under GDPR and Irish Data Protection Acts governing such transfers.
Marketing and other emails
We use personal information to understand whether you read the emails and other materials, such as legal publications, that we send to you.
We may also use a Customer Relationship Management tool, to track and record the relationship between Kontex and our clients or potential clients. We use that information in order to assess, analyse and improve the services that we provide.
We will retain your personal data for the duration of your relationship with Kontex or for such a period of time after the relationship ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.
You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data as set out in more detail in the GDPR and Irish Data protection Acts:
- the right to access your personal data, together with information about our processing of that personal data;
- the right to rectify any inaccuracies in your personal data;
- the right to have any incomplete personal data completed;
- the right to erase your personal data (in certain specific circumstances).
- the right to request that your personal data is no longer processed for particular purposes (in certain specific circumstances);
- where the legal basis for processing is consent, the right to withdraw your consent at any time;
- the right to object to the use of your personal data or the way in which it is processed where Kontex has determined it to be necessary for the purposes of our legitimate interests;
- the right to data portability (in certain specific circumstances);
- The right to lodge a complaint with a supervisory authority, in particular, in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the requirements of the applicable data protection law.
Links to other sites
Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal information to those websites.
Changes to this Privacy Statement
We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Privacy Statement. Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Statement periodically for updates.