Last Modified september 2018
- Lawfulness, fairness and transparency
- Collection for specified, explicit and legitimate purposes
- Adequate, relevant and limited to what is necessary in relation to the purpose
- Accurate and, where necessary, kept up to date
- Stored for no longer than is necessary
- Secured and confidential
Controllers of Personal Data
The Personal Data provided by the customers to KegL media Ltd is controlled by KegL media Ltd, company incorporated in the Republic of Seychelles.
KegL media Ltd
Global Gateway 8,
Rue de la Perle, Providence,
We work with several partners in order to offer an excellent service. It is impossible to name all the partners beforehand. When we engage in a business relationship with our client we will notify them about the different controllers and processors that will have access to their data and we will request the client´s mandatory consent for such processing.
Purpose of the Data Processing
At KegL media Ltd we provide our Clients with several services such as:
- Risk Management
- Customer Service
- Traffic Optimization
- Online Payment Solutions
We primarily help our Clients to get Card Processing and help them to manage the Risk involved in online transactions, among many other services. These services imply complex tasks and need to process several Personal and Non-Personal Data in order to be compliant with the different regulations to which we and our partners are subject (National Laws, Supranational Laws, Banks Regulations, Card Schemes (Visa & MasterCard) Rules and AML/CFT (Anti-Money Laundering and Combating Financing of Terrorism)).
Personal Data Definition
‘Personal Data’ means 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
Types of Information Collected
We collect two types of information about our clients: Personal Data and Non-Personal Data. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our Site and our services.
Personal Data, as stated in the previous section. When you engage in certain activities on our Site, or if you contact us by any other means, we may ask you to provide certain information about yourself, and your company, by filling out and submitting an online form. It is completely optional for you to engage in these activities; however, we may ask that you provide us personal information, such as your first and last name, e-mail address, employer and telephone number, and other personally identifying information. Depending upon your activity, some of the information we ask you to provide is identified as mandatory. If you do not provide the mandatory data with respect to a particular activity, we will not be able to provide you with our services.
Non-Personal Data: this refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the website’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and/or your Internet Protocol (“IP”) address.
Collection Methods and Use of Information
In addition, we may also collect, or our third-party content server may collect, certain Non-Personal Data. Our servers automatically collect certain site use information each time you visit our Site. The Site user information includes but is not limited to the following: the domain names, operating system in use, browser and version, the website that referred you to us, and other similar information. This information may be aggregated to measure the number of visits, average time spent on our Site, pages viewed, time and date of visits, and other similar information. We may use and disclose site use information, for example, to measure the use of our Site, explain the utility of our Site, and to improve the content of our Site.
Period for which the Personal Data will be stored
KegL media Ltd´s aim is not to use or store the data for longer than necessary. The client can request the erasure of Data at any time and KegL media Ltd must destroy the data unless there is a legal requirement to keep those Data.
Data Protection by default
KegL media Ltd only processes strictly Personal Data which are necessary for accomplish and fulfil the purposes and the goals set out at the beginning or our business relationship.
We retain information provided to us indefinitely unless otherwise stated. In addition, we will keep some personal information you have asked us to remove for the following purposes: (i) troubleshoot problems; (ii) assist with investigations; or (iii) comply with legal requirements
Therefore, you should not expect that all of your Personally Identifiable Information will always be completely removed from our databases in response to your requests.
Transfer of Personal Data
We may disclose Personal Data to our affiliates. We work with several partners and we always will contact you to obtain your consent to the processing of your data with Third Parties. We have signed contracts with them and they must have Data protection policies in place to make sure the effective protection of all the interests involved. Occasionally, we may be required by law enforcement or judicial authorities to provide Personal Data to the appropriate governmental authorities. We will disclose Personal Data upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
We ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with Personal Data are contractually required to observe the intent of this Privacy Statement and our privacy practices. We sign agreements with them that ensure the appropriate use of policies and safeguards to keep all data secured.
We may also provide Non-Personal Data about our customers’ sales, traffic patterns, and related site information to third-party advertisers, but these statistics do not include any Personal Data.
Rights of the Data Subject
The Data Subject hast the following rights:
- Right of Access – To know whether or not personal data are being processed by us or our partners
- Right to Rectification of any incorrectness
- Right to Erasure (“Right to be forgotten”)
- Right to Restriction of Processing
- Right to Data Portability in a commonly used and machine-readable format
- Right to Object
- Right to lodge a complaint with a supervisory authority
The Data Subject can exercise these right at any time by contacting us in the contact section by clicking in the following link:
The Client who provides us with Personal Data must consent to the use and processing of data by us before providing the sensible data.
Without this consent, we are not allowed to process the data provided by the client and we will not have access to that data.
The request for consent will be presented in a clear and easily accessible form before inputting any Personal Data through our online form.
Security of Information
We believe that keeping Personal Data secure is one of our most significant responsibilities. We restrict access to Personal Data about you to those employees and others who need to know that information to assist us in our business or to provide products or services to you. We safeguard Personal Data according to established security standards and procedures, by maintaining physical, electronic, and procedural safeguards for the information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through our Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
KegL media Ltd. guarantees that the processing of Personal Data is conducted in a way that ensures the Confidentiality, Integrity, Availability and Resilience of such data; specially from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access; also, the ability to restore the availability and access to the data in a timely manner; and that processes for regularly testing, assessing and evaluating all these measures are in place.
In particular, we have implemented Technical measures such as:
- Encrypted Traffic Management (ETM) to selectively decrypt encrypted traffic for security screening purposes, before re-encrypting the data for transport to its intended destination
- Prevent Residual Data from being left hanging
- Prevent that Database Logs contain comprehensive copies of the deleted data
- Database Aggregation procedures in place to locate the relevant data in case of portability query or data erasure request
- Avoid the use of hybrid physical/electronic methods of data storage
- Avoid the storage of the Data in multiple formats, with varying levels of encryption and residual data
Privacy Policies of Third-Party Websites
Links to Other Websites
We may provide links to other websites for your convenience and information. These sites operate independently from our Site and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites.
Governing Law and Competent Court
This Policy is constructed according to the laws of the Republic of Seychelles.