Kenlighten Privacy Policy

Effective Date:27th April 2020

This privacy policy operates between you (hereinafter referred to as you or your) and Mavenz Management and Technology Services Private Limited, a Limited company registered in India under the Companies Act, 1956 having company incorporation number U74140GA2004PTC003693 (hereinafter referred to as Kenlighten, we, our or us). At Kenlighten, we are committed to safeguarding your privacy. This privacy policy provides information on the processing of personal data by Kenlighten. We want you to feel secure when we are collecting and sharing your data and therefore, we want you to know how we collect, use, share, and keep the information about you and the choices that are available to you as a data subject. As such, this privacy policy is concerned with how we handle the personal data of users of Kenlighten (the Privacy Policy). The Privacy Policy applies to the Kenlighten website, as well as your use of or access to any of our online services.

Your use of our website and services (the Services) and any dispute arising over privacy is subject to this Privacy Policy and any of our applicable terms and conditions for the use of our services.

We reserve the right to, at all times, and with or without any particular notification, make changes to this Privacy Policy. We might need to do so in the case of new developments, activities, online services, or when the applicable laws are amended. We therefore advise you to regularly check this Privacy Policy to make sure you are up to date on any possible adjustments.

1. When does this Privacy Policy apply?

This Privacy Policy is applicable to the processing of personal data of all users of the Kenlighten website and platform, and possibly other individuals. This Privacy Policy does not apply to the processing of data of employees in the context of their employment or assignment relationship at Kenlighten.

When processing personal data of data subjects who are in the EU in connection with our Services, Kenlighten acts as a data controller and as a data processor. When Kenlighten determines the purpose and the manner of processing your personal data, Kenlighten is deemed to be a data controller. We apply a similar approach to protecting your personal data whether we are acting as a data controller or a data processor.

Kenlighten is committed to adequately protecting your personal data in accordance with the applicable laws and regulations, regardless of your location and where we process it. Similarly, we are committed to providing the appropriate protection framework when transferring your data outside of the EEA.

2. Which types of personal data do we collect and why?

  1. (1) To deliver you our website’s functionalities and for their technical and functional management
    1. (i) What does this purpose encompass?
      For any person that accesses and uses our website, we process technical data to be able to offer you all our website’s functionalities and to allow our website’s administrators and developers to manage and improve our website’s performance. If you enter data into our website, such as your location to receive relevant information and functionalities, Kenlighten processes this data to provide you with the requested information or functionalities. Furthermore, we process your personal data in order to allow you to save your data (or preferences) to configure your device.
    2. (ii) What legal ground justifies the processing of personal data for this purpose?
      We process your personal data for this purpose based on our legitimate interest. We do so to improve our overall marketing and communication efforts and to inform and update key stakeholders.
    3. (iii) Which personal data do we process for this purpose?
      For this purpose, we process any personal data that you have entered into our website yourself, or that is generated by the functionalities described under (i), which includes your IP-address, operating system, geolocation, the internet browser you use and anything else that constitutes our server logs.
    4. (iv) How long will we hold on to your personal data?
      We will store such personal data gathered for this purpose for a maximum of 1 year. After this period, we will permanently delete your personal data from our systems.
  2. (2) To allow you to contact us or connect with us (e.g. on social media)
    1. (i) What does this purpose encompass?
      Kenlighten maintains active accounts on several social media platforms. When you contact us via one of these platforms, we process your personal data in order to answer your queries, to respond to the messages or requests, and subsequently to contact you in relation to any campaigns we might run through these platforms from that point onwards.
      Additionally, when you click any of the buttons included on our website to be able to contact us, we will refer you to the website or app of the applicable third party, whether this is your email provider or a social media platform. For more information, read the Section on Cookies below.
    2. (ii) What legal ground justifies the processing of personal data for this purpose?
      We process your personal data based on a legitimate interest. Being able to communicate with (potential) clients is vital to our business. It can also improve our overall marketing and communication efforts.
    3. (iii) Which personal data do we process for this purpose?
      For this particular purpose, we process via the communication channel which you have chosen to use to connect with us, and we process the personal data you used to connect with us and chose to supply to Kenlighten. This includes your (user) name, address, email address, gender, and any additional personal data you included in your message. Moreover, if you accessed our social media through one of the buttons on our website, the relevant third party might place cookies on your device.
    4. (iv) How long will we hold on to your personal data?
      We will store the data collected for this purpose for a maximum of 10 years. After this period, we will permanently delete all this data from our systems.
  3. (3) For answering your questions and handling of complaints
    1. (i) What does this purpose encompass?
      If you get in touch with us at our office(s), via a contact form, or contact any of our employees in any possible form, we will use your personal data in order to reply to and answer your question or to respond to and handle a complaint.
    2. (ii) What legal ground justifies the processing of personal data for this purpose?
      We process your personal data based on consent and legitimate interest. In this case, the legitimate interest is constituted by our intent to carefully deal with your complaints and questions.
    3. (iii) Which personal data do we process for this purpose?
      To the end of this purpose we process your name, contact details, your correspondence with Kenlighten about your question or complaint and all other personal data which are necessary to answer your question or to handle your complaint.
    4. (iv) How long will we hold on to your personal data?
      We will retain your personal data for as long as we need to execute your request or handle the complaint, plus a maximum of 1 month, after which the data will be deleted from our systems.
  4. (4) To ensure correct enforcement and respect of your rights included in this Privacy Policy
    1. (i) What does this purpose encompass?
      As a result of the rights you have as a person whose personal data is processed by us, which can be found in Section 6 of this Privacy Policy, we process your personal data in order to execute and administer your requests to us in relation to these rights. For example, if you want to exercise your right to be forgotten, we need to register a minimum amount of data in order to make sure that we do not contact you anymore.
    2. (ii) What legal ground justifies the processing of personal data for this purpose?
      Processing of this personal data is based on our legitimate interest. The legitimate interest we have is that we intend to respect your choices and thus, we want to ensure that if you exercise your right to be forgotten, we will never contact you again for any purpose.
    3. (iii) Which personal data do we process for this purpose?
      For this purpose, we process contact details such as your address and email address, and personal details such as your name.
    4. (iv) How long will we hold on to your personal data?
      Due to the nature of this purpose, we need to hold on to this data for an unlimited period.
  5. (5) To set up an Account for you
    1. (i) What does this purpose encompass?
      We use personal data for the purpose of entering into relationships with (prospective) users, and to perform any contractual obligations under the contract that we have with clients. One of these obligations is that, upon your registration, we create an account for you. We process your personal data for administrative purposes, such as sending invoices. We might also use your personal data for the implementation and execution of our Services. The agreement comes into force from the moment the user creates an account and accepts our Terms and Conditions.
    2. (ii) What legal ground justifies the processing of personal data for this purpose?
      We process personal data for this purpose based on our contract with you and legitimate interest. We do so on the basis of the contract that you have engaged in with Kenlighten relating to the provision of the specific service between you and Kenlighten. Our legitimate interest to process your data follows from our intent to comply with applicable law.
    3. (iii) Which personal data do we process for this purpose?
      For this purpose, we process your details such as your address, time zone, currency, password, security question and answer, language, phone number, and email address, personal details such as name and date of birth, gender, payment and credit information, tax information, order history and other data stored in our database with all relationships of Kenlighten. You are free to supply your profile with extra data such as a description about you, educational qualifications, work experience, awards and achievements, and personal interests or hobbies.
    4. (iv) How long will we hold on to your personal data?
      Your personal data will be held on to for 7 years after the end of our relationship with you. After this term, your personal data will be deleted from our systems.
  6. (6) For relationship management and marketing
    1. (i) What does this purpose encompass?
      Kenlighten could possibly use the information stored in its contractual relationship database to send you newsletters and email alerts, as well as to provide customer services and perform account management. We also use your personal data for the development, execution, and analysis of market surveys and marketing strategies. In addition, users of our website might enter your email address on our website to refer you to our website.
    2. (ii) What legal ground justifies the processing of personal data for this purpose?
      We process your personal data for this purpose based on your consent. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before withdrawal. If your email address is referred to us by a user of our website or platform, we will ask for your consent before sending you any (marketing) communication.
    3. (iii) Which personal data do we process for this purpose?
      For this purpose, we process you contact details such as your address and email address, personal details such as your name and date of birth, contact preferences, payment information, order history, and correspondence with us.
    4. (iv) How long will we hold on to your personal data?
      Personal data will be retained for a maximum of 10 years after the termination of our relationship. After this term, your personal data will be deleted from our systems.
  7. (7) To protect child safety
    1. (i) What does this purpose encompass?
      Because our Services are also offered to children below 13 years of age, we maintain high standards when it comes to their privacy and safety. We collect as little information as possible from children. This information is supplied through the Child Account (defined in the Terms and Conditions) on our website, which has to be authorized by a parent or legal guardian.
    2. (ii) What legal ground justifies the processing of personal data for this purpose?
      We process this personal data on the basis of consent only.
    3. (iii) Which personal data do we process for this purpose?
      For this purpose, we will process the child’s name, gender and date of birth. We will also ask for an email address and phone number to be provided, which are that of the parent(s) or legal guardian(s).
    4. (iv) How long will we hold on to your personal data?
      We will hold on to this personal data for as long as you use our Services plus a maximum of 1 year.

3. Cookies

Kenlighten uses cookies in offering its Services. A cookie is a small and simple file that can be stored on the hard disk of a computer. Kenlighten’s cookies are merely temporary, not permanent, and contain no personal data.

  1. (1) Functional Cookies
    Kenlighten uses a cookie to see whether or not a visitor to our website accepts the cookies on our website(s). This functional cookie registers your consent.
    Features: This cookie belongs to Kenlighten and is deleted automatically after 1 month.
    Sharing: This information is not shared with third parties.
  2. (2) Analytics Cookies
    Our website keeps visitor records and metrics, such as most visited pages. This allows Kenlighten to optimize the layout of its website(s). To this end, we use Google Analytics, and we use this data to improve our website(s), to compile statistics, and to measure the popularity of different aspects of our website(s). Kenlighten uses this data in an aggregated form and therefore this cannot be traced back to any computer or individual. To prevent this from happening, you can install the ‘Google Analytics Opt-out Browser Add-on’ to prevent our websites from informing Google Analytics about your visits.
    Features: This cookie belongs to Google and will be deleted after a maximum of two years.
  3. (3) Social Media Cookies
    We display various buttons and widgets on our websites which link to social media networks such as Facebook, Twitter, YouTube, LinkedIn, and Instagram. These are pieces of code from the social media platforms themselves and use a cookie. This cookie remembers that you are logged in. To know the exact details of what these social media platforms do with your data, you need to review their individual privacy statements (which are also subject to change). You can disable this feature by installing a program such as ‘Disconnect’ for Chrome and Firefox.

We give you the possibility to give your consent to the use of cookies when you first access the website. If you, at a later point in time, wish to disable these cookies, you can follow the instructions below. You can also set your browser to notify you as soon as you receive a cookie or to deactivate cookies. In doing so, it is possible that our websites will not function optimally.

Here we offer some specific information about cookies for the most commonly used browsers, and more specifically, how to disable these:
Cookies and Internet Explorer, see: https://privacy.microsoft.com/en-us/privacystatement#maincookiessimilartechnologiesmodule
Cookies and Firefox, see: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Cookies and Google Chrome, see: https://policies.google.com/technologies/managing?hl=en
Cookies and Safari, see: https://www.apple.com/legal/privacy/en-ww/cookies/
Cookies and Opera, see: https://help.opera.com/en/latest/web-preferences/

4. Who has access to your personal data?

Kenlighten is committed to securing your personal data and has taken the necessary steps in this regard. Only our employees are authorised to access personal data, yet, only to the extent necessary to properly perform their individual jobs.

With every third party who, on our behalf, processes personal data, we have entered into the required data processing agreements. Kenlighten only shares personal data with third parties if it is necessary to serve its applicable purpose as set out above. In all cases, we will ensure that third parties with access to your personal data have implemented appropriate technical and organizational safeguards to maintain our envisioned level of privacy and security. We furthermore insist that all data protection and privacy laws are adhered to at all times.

If your personal data is transferred to a recipient in a country outside the EEA or where an adequate level of protection of personal data is not provided for, Kenlighten will take measures to ensure that your personal data is adequately protected in those countries as well, such as entering into the EU Standard Contractual Clauses with these third parties.

When a third party processes your personal data, they can only do so following Kenlighten’s instructions. They therefore act as our data processor. We enter into the necessary agreement with the data processor where we include obligations to ensure your personal data is processed solely in order for the data processor to fulfil its duty to provide services to us.

Third parties that process data in order for us to bring about our purposes as set out above are:
  • - Banks/payment processors
  • - IT suppliers
  • - Identity verification suppliers
  • - Content providers on the platform
  • - Companies whose job vacancies you responded to
  • - Companies whose event you responded to

In any other case, your personal data will not be supplied to third parties, except where mandated by law. Kenlighten will not sell any of your data to third parties.

5. Security

Your personal data will be stored securely at all times. We value the protection of your privacy. We treat personal data very carefully, and, possibly together with third parties, we ensure that appropriate organisational and technical protection measures are implemented to safely store personal data. In this manner, we ensure that the personal data is only accessible to those particular individuals who are authorized based on their job function, and therefore is only used for its intended purpose. Additionally, we have implemented measures to guarantee your safe visit to and use of our websites. In doing so, we prevent any abuse of your data. These measures include computer safeguards and secured files and facilities.

Our websites have a certified Secure Socket Layers (SSL) certificate. This is the standard security technology for establishing an encrypted link between a web server and a browser. This link ensures that all data passed between the web server and browsers remain private and integral. Your financial transactions are managed by payment services providers that use secure technology systems.

The platform itself also provides several tools for you to handle your own privacy. For example, you can hide your personal details from certain users on the platform. You may choose to only share your personal details with your direct connections.

Kenlighten has taken the necessary technical and organizational measures to prevent, signal, rapport, and handle any breach in its data protection. In the event that a data breach does occur, however, Kenlighten will, without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the relevant Data Protection Authority.

6. Accessing, correcting or removing personal data

You have the right to access, correct, or remove your personal data that we have stored. You also have the right to withdraw your previously given consent to the processing of your personal data, or to object to the processing of your personal data by Kenlighten. Finally, you have the right to have a file sent to you, containing details of which of your personal data we have stored. You can send us a request to receive such a file in writing. Any request is subject to the applicable law, which means that we might need to keep the personal data stored.

We also want to inform and remind you of the ability to issue a formal complaint at the national Data Protection Authority.

If you object to Kenlighten using your personal data, want your personal data to be forgotten, want to withdraw your previously given consent to process your personal data, or you have a different enquiry concerning your personal data, you can at any time send a request to:
Kenlighten - Legal
Mavenz Management and Technology Services Private Limited
407, 4th Floor,
Kamat Towers, EDC Complex,
Patto-Plaza,
Panaji
Goa. 403 001.
India.
+91-832-2437611
legal@kenlighten.com

External links

Our website could sometimes display links to other websites. We are not responsible for the privacy policy that this other website adheres to, nor its content. We advise you to inform yourself by reading the privacy policies on these websites.

Any questions?

In the event you still have questions after reading this Privacy Policy, or when you have any suggestions or comments about its content, you can always contact us at: legal@kenlighten.com