1.1 The Pivot Trader (KDW Group) is committed to safeguarding the privacy of our website visitors and customers.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. ‘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.
1.4 The Pivot Trader is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). For more information about us click here.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data is primarily processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“company/personal account data“).For our free newsletters/videos and reports we only collect your first name, your email address and IP address. For customers the account data may include your name, address, email address and telephone number. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and or taking steps at your request to enter into such a contract.
2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number and email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include the products we have provided you. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering and selling relevant goods and/or services to you. The legal basis for this processing is taking steps at your request to enter into a contract.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests.
2.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We will not disclose any of your details to any third parties accept in the where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to carry out the delivery of our goods and service as described in 3.2 and 3.2 below.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.
3.3 We may disclose name and address to our suppliers or subcontractors such as delivery couriers insofar as reasonably necessary to deliver your order.
3.4 Financial transactions relating to our website and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at the Stripe website.
4. International transfers of your personal data
4.1 We use Keap as our data processor, they are based in the United States. They are committed to providing the highest level of security for our clients personal data. Keap have released their own data processing addendum which can be read by clicking here
4.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) Customer Data will be retained for a maximum period of 10 years following our last engagement. With this exception of financial transactions that we are bound to retain for 7 years.
5.4 Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Data Security
7.1 The Pivot Trader has put in place appropriate security measures to prevent your personal data from being accidentally lost, misused or accessed in an unauthorised way, altered or disclosed.
7.2 We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know, only sharing or disclosing information for the performance of the contract between us and the customer. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Your rights
8.1 In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to request access to your personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.]
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In the UK this will be the Information Commissioner’s Office (ICO).
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data in writing to us at our registered office address.
9. Our Company Details
9.1 Our website is owned and operated by the KDW Group.
9.2 We are registered in England and Wales under registration number 13877029, and our registered office is at our accounts Novakovic & Co Crofton House, 27 St Cuthberts Street, Bedford MK40 3JG
9.3 Our principal place of business is at The KDW Group, 50A High Street, Blisworth, NN7 3BJ
9.4 You can contact us:
(a) by post, to the postal address given above;
(b) Using our website contact form;
(c) by telephone on ++44 (0)1604 859618
(d) by email, using firstname.lastname@example.org
10.1 Legitimate Interest – the interest of our business in conducting and managing our business to enable us to give you the best product/service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
10.2 Performance of Contract – Processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Performance of a contract can include but is not limited to; printing and engraving of goods in line with our business practices, data loading services as well as delivery of products to their final destination and fulfilment of payment.
10.3 Comply with a legal or regulatory obligation – processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we, as a company, are subject to.