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Keller Technology Corporation – Privacy Notice

I. Introduction

A. Keller Technology Corporation (“Keller”) is committed to safeguarding the privacy rights of our website visitors and customers, in compliance with the Data Protection Act 1998 (DPA) and the new General Data Protection Regulation (GDPR).

B. This Notice applies where we are acting as a data “controller” with respect to the personal data of our website visitors and customers. Keller Technology acts as a controller of personal data when we determine the purposes and means of the processing of that personal data.

C. We use cookies on our website. To the extent that cookies are not strictly necessary in connection with the operation of our website and the provision of our products and services, we will ask you to consent to our use of cookies when you first visit our website.

D. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via [URL].

E. In this Notice, “we”, “us” and “our” refer to Keller Technology Corporation. For more information about us, see Section VIII.

II. How We may use your personal data

A. Generally

1. In this Section II we will explain:

a. the general categories of personal data that we may process;

b. in the case of personal data that we did not obtain directly from you, the source of that data;

c. the purposes for which we may process personal data; and

d. the legal bases (under the GDPR) of the processing.

2. In addition to the specific purposes for which we may process your personal data (stated below in this Section II):

a. We may process your personal data where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 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.

b. We may process your personal data 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.

c. 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.

B. Usage Data

1. We may process data about your use of our website and our products and services (“usage data”). Usage data may include your IP address, geographical location, referral source, length of visit, page views and website navigation paths, as well as information about the frequency of your use. The sources of this usage data include:

a. Google Analytics, and primary tracking vendors we may use in the future;

b. WhatConverts, and

c. ThomasNet.

2. This usage data may be processed for the purposes of analyzing the use of our website and our products and services.

3. The legal basis for this processing under the GDPR is our legitimate interests, namely, monitoring our website and improving our products and services. Where our legitimate interests are not a sufficient legal basis, we will ask for your consent to use your personal data.

C. Profile Data

1. Profile data is the information in your personal profile on our website, which may include may include your name, address, telephone number, and email address.

2. We may process your profile data for the purposes of permitting and monitoring your use of our website and to enable you to purchase our products and services.

3. The legal bases for this processing are:

a. our legitimate interests, namely the proper administration of our website and the operation of our business, and

b. the performance of a contract between you and us, or our taking steps, at your request, to enter into such a contract.
Where our legitimate interests are not a sufficient legal basis, we will ask for your consent to use your personal data.

D. Service Data

1. Service data includes personal information provided in the course of the use of our products and services.

2. We may process service data for the purposes of administering our website, offering and providing our products and services, ensuring the security of our website and products and services, and communicating with you.

3. The legal bases for this processing are:

a. our legitimate interests, namely the proper administration of our website and the operation of our business;

b. the performance of a contract between you and us, or our taking steps, at your request, to enter into such a contract.

E. Inquiry Data

1. We may process information contained in any inquiry you submit to us regarding our products or services for the purposes of offering, marketing and selling relevant goods and/or products and services to you.

2. 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. Where this is not a sufficient legal basis, we will ask for your consent to use your inquiry data.

F. Notification Data

1. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”).

2. Notification data may be processed for the purposes of sending you the relevant notifications or newsletters.

3. The legal basis for this processing is the performance of a contract between you and us, and/or our taking steps, at your request, to enter into such a contract.

III. Providing Your Personal Data to Others

A. 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 defense of legal claims, whether in court proceedings or in an administrative or out–of–court procedure.

B. In addition to the specific disclosures of personal data set out in this Section III, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out–of–court proceeding.

IV. Retaining and Deleting Personal Data

A. This Section IV states 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.

B. 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.

C. We will retain your personal data only as long as the retention of such information is necessary in light of our legitimate interest or other lawful basis for using such personal data.

D. Notwithstanding the other provisions of this Section IV, 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.

V. Amendments

A. We may update this Notice from time to time by publishing a new version on our website.

B. You should check this page occasionally to ensure you are happy with any changes to this Notice.

C. We may notify you of significant changes to this Notice by email.

VI. Your Rights

A. General

1. In this Section VI, we have summarized the most important rights that you have under the GDPR. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

2. Your most important rights under the GDPR are:

a. the right to access;

b. the right to rectification;

c. the right to erasure (the “right to be forgotten”);

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.

3. You may exercise any of your rights in relation to your personal data by written notice to us using the contact form on our website.

B. Right to Access

1. You have the right to confirmation as to whether or not we process your personal data and, if we do, access to the 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.

2. Provided that 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.

C. Right of Rectification
You have the right to have any inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

D. Right of Erasure (Right to Be Forgotten)

1. In certain circumstances you have the right to have your personal data erased without undue delay. Those circumstances include:

a. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b. you withdraw consent to consent–based processing;

c. you object to the processing under certain rules of applicable data protection law;

d. the processing is for direct marketing purposes; and

e. the personal data have been unlawfully processed.

2. However, there are exceptions to this right. The exceptions include where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

E. Right to Restrict Processing

1. In certain circumstances you have the right to restrict the processing of your personal data. Those circumstances are:

a. you contest the accuracy of the personal data;

b. processing is unlawful but you oppose erasure;

c. we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and

d. you have objected to processing, pending the verification of that objection.

2. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it in the circumstances:

a. with your consent;

b. for the establishment, exercise or defense of legal claims;

c. for the protection of the rights of another natural or legal person; or

d. for reasons of important public interest.

F. Right to Object

1. 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 one of the following:

a. the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or

b. legitimate interests pursued by us or by a fourth party.

2. 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 defense of legal claims.

3. 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.

4. 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.

G. Right to Withdraw Consent

1. 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.

H. Right to Data Portability

1. You have the right to receive any personal data that you provided to us in a structured, commonly used and machine–readable format, and to transmit this data to another controller without interference from us, where:

a. the processing is based on (i) your consent, or (ii) the performance of a contract between you and us, or our taking steps, at your request, to enter into such a contract; and

b. the processing is carried out by automated means.

2. In exercising your right to data portability, you have the right to have the personal data transmitted directly from one controller to another, where this is technically feasible.

3. The exercise of your right to data portability shall be without prejudice to your to data erasure (see Section VI.D, above). Furthermore, your right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest, and shall not adversely affect the rights and freedoms of others.

I. Right to Lodge a Complaint
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. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

VII. About Cookies

A. Generally

1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

B. How We May Use Cookies

1. We may use cookies for the following purposes:

a. Authentication – We may use cookies to identify you when you visit our website and as you navigate our website.

b. Status – We may use cookies to help us to determine if you are logged into our website.

c. Personalization – We may use cookies to store information about your preferences and to personalize the website for you.

d. Analysis – We may use cookies to help us to analyze the use and performance of our website and products and services.

e. Cookie Consent. We may use cookies to store your preferences in relation to the use of cookies more generally.

f. Security – We may use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and products and services generally.

g. Advertising – We may use cookies to help us to display advertisements that will be relevant to you.

C. Cookies Used by our Vendors

1. Our vendors may use cookies and those cookies may be stored on your computer when you visit our website.

2. We use Google Analytics and WhatConverts to analyze the use of our website. These vendors gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy. WhatConverts’ privacy policy is available at: https://www.whatconverts.com/privacy/ . ThomasNet’s privacy policy is available at: https://www.thomasnet.com/privacy.html

3. We may also use other vendors who use cookies to gather information about website use by means of cookies, and use such information to create reports about the use of our website. When we use other vendors for these purposes, we will provide a link to their privacy policies in an amendment to this Notice.

D. Managing Cookies

1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary. You can however obtain up–to–date information about blocking and deleting cookies via these links:

a. https://support.google.com/chrome/answer/95647 (Chrome)

b. https://support.mozilla.org/en–US/kb/enable–and–disable–cookies–website–preferences (Firefox)

c. https://support.microsoft.com/en–gb/help/17442/windows–internet–explorer–delete–manage–cookies (Internet Explorer)

d. https://support.apple.com/kb/PH21411 (Safari)

2. Blocking all cookies will have a negative impact upon the usability and performance of many websites.

3. If you block cookies, you will not be able to use all the features on our website.

VIII. Information about Us

A. General Information

1. This website is owned and operated by Keller Technology Corporation, a New York corporation with its principal place of business located at 2320 Military Road, Tonawanda, NY 14150.

2. You can contact us as follows:

a. Using our website contact form.

b. By mail, to:
Keller Technology Corporation
2320 Military Road
Tonawanda, NY 14150
Attention: Peter Denes

c. By email, using the email address stated on our website from time to time.

B. Data Protection Officer

1. Our Data Protection Officer’s contact details are:
Peter Denes
Keller Technology Corporation
2320 Military Road
Tonawanda, NY 14150

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