Ketpulse’s Privacy Notice
Last updated: September 2019
Ketpulse (referred to as "our", "us" and "we" in this notice) are help our clients to improve how they advertise and market, whether by print, post, email or on websites. We believe that the responsible use of data supports business growth and builds strong relationships between brand and consumer. As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact. We are committed to being transparent in our handling and processing of personal data at all times in accordance with applicable privacy and data protection laws.
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. Ketpulse is the data controller of any personal data you provide to us, including in relation to this website. (www.ketpulse.com)
This Privacy Notice explains the following:
Information we may collect
How we use this information
How we store your personal data
How we secure your personal data
Information sharing and disclosure
Our responsibility for website links
How to contact us
1. Information we may collect
We also collect information about you if you make use of any of the interactive features within our website that rely on a personalized response, or where you ask us to respond to a query you have, or sign up to receive our newsletters, or submit an enquiry in relation to a job or career opportunity. We do not collect sensitive information, such as your political or religious beliefs, ethnic background, sexual preference, health or any other sensitive information.
We do not actively seek to collect information about children aged 16 or under. If you have any concerns about your child’s privacy in relation to our services, or if you believe that your child may have entered personal data onto our Website, please contact us at email@example.com. We will delete such information from our records within a reasonable time.
2. How we use this information
Except where required by law, we only use the personal information you provide for the following purposes:
to deliver the specific information or services you have requested. For example, if you have requested further information on our services or content, or wish to subscribe to our newsletters, or apply for a job application, or submit an enquiry through this site. We will only use the email address you provide to us to respond to that request. Without your express consent, we will not use your contact details for any other purpose.
to analyse and/or improve our services; and to personalise the way our content is presented to you online.
Under data protection law we are required to advise you on the legal basis for processing your personal data. For the most part, the processing of your personal information is based either on a) our legitimate interests related to us providing you services you have requested or otherwise your customer relationship with us, or b) your consent, where requested.
In the table below we set out further information about the purposes for which we use your personal data and the legal basis we rely on for its use. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Types of personal data that may be processed
Lawful basis for processing including basis of legitimate interest
To send you information about our services:
Where you have requested information from us, such as white papers, reports or newsletters, we send such communications based on your consent.
It is in our legitimate interest to respond to communications that you send to us, inform you of relevant information in relation to the services that we provide and utilise your information to improve our business.
To share information within the Ketpulse group.
It is our legitimate business interest to share your data within the Ketpulse group in order to manage our business effectively and provide our products and services.
To share information with other third parties, such as regulator and law enforcement agencies.
We share your data as necessary for compliance with any legal obligation to which we are subject or in order to satisfy our legitimate business interests.
3. How long will we keep your information
We will keep your personal data for as long as is necessary for the relevant service, in accordance with our legal obligations. After this time, your personal data will either be securely deleted or anonymised so that it can be used for analytical purposes. You may request further information via the contact details given in this Privacy Notice.
4. How we secure your information
We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers do the same.
5. Information Sharing and Disclosure
Information shared with our third-party service providers
We use a number of third parties to perform business functions on our behalf, such as sending our newsletters and hosting our online services and customer relationship management. We will only disclose the information necessary to enable these third parties to perform their services. Our service providers are contracted to comply with our instructions and we require that they do not use your personal data for their own business purpose.
Information shared with other parties
Where required or permitted by law, personal data may be provided to others, such as regulator and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law.
We do not sell or rent any personal data about you to any third party.
6. Your rights
Object to our processing of your personal data where we are relying on legitimate interest (or those of a third-party), and you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have a right to object where we are processing your personal data for the purposes of direct marketing. You can object at any time and we shall stop processing the information you have objected to, unless we can show compelling legitimate grounds to continue that processing.
Access your personal data. If you make this kind of request and we hold personal data about you. We are required to provide you with information on it, including a description and copy of the personal data and why we are processing it. We will require you to prove your identity before granting access to your personal data. We will process your request within the timeframe required under the relevant law.
Request the transfer of your personal data. We will provide to you or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note, this right applies to the personal data you have provided to us; and if we use your personal data on the basis of consent or where we used the information to perform a contract with you.
Request erasure (deletion) of your personal data. You have a right to ask us to delete or remove your data where you have successfully exercised your right to object (see above), or where we are required to erase your personal data to comply with local law. Please note, we may be required to retain certain information by law and/or for our own legitimate business purpose. But when we do so, we will inform you
Request correction or updating of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request the restriction of our processing of your personal data in some situations. If you request this, we can continue to store your personal data but are restricted from processing it while the restriction is in place.
Withdraw your consent. Where you have provided your consent to our processing of your personal data you can withdraw your consent at any time. If you do withdraw consent, that will not affect the lawfulness of what we have done with your personal data before you withdrew consent.
Make a Complaint. We will do our best to resolve any complaint. However, if you feel we have not resolved your complaint, you have a right to make a complaint to your local data protection authority. If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
7. Our responsibility for website links
This Privacy Notice is limited to the personal data collected by Ketpulse. We do provide links within this site to other websites. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices as their data practices fall outside the scope of this Privacy Notice. Further, we can have no responsibility for or control over the information collected by any third-party website and we cannot be responsible for the protection and privacy of any information which you may provide on such websites.
This Privacy Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal data. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please do not continue to use our services and please refrain from sharing your personal data with us. You should check this notice frequently for updates.
9. Contact us
If you have any questions about this Privacy Notice, our approach to privacy or you would like to exercise any of the rights mentioned in this Privacy Notice you can contact our Data Protection Officer in any of the following ways:
Address: 2nd Floor, No.3 Building, No.627, Ningxia Road, Putuo District, Shanghai, China 200063