Owner and Data Controller

Kelvin Re Limited
P.O. Box 33
Dorey Court
Admiral Park
St Peter Port,
Guernsey,
GY1 4AT

Owner contact email: info@kelvinre.gg

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: first name; last name; email address; Cookies; Usage Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. For the avoidance of doubt, all Personal Data provided to the Owner via any application form provided on this Website is provided voluntarily by the User.

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website or provided to the Owner via any application forms provided on this Website and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration or consideration of application for funding) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, or in respect of any Data provided on any application form for the purposes specified on that Application Form, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Infrastructure monitoring, Contacting the User, Hosting and backend infrastructure, Analytics, Managing contacts and sending messages, Traffic optimization and distribution, Displaying content from external platforms, considering applications for funding and SPAM protection.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy.

• Contacting the User

  Contact form (this Website)

  By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data collected: email address; first name; last name.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.

  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts

  Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that allows this Website to incorporate content of this kind on its pages.

  Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

  Google Maps widget

  Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that allows this Website to incorporate content of this kind on its pages.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  DigitalOcean (DigitalOcean Inc.)

  DigitalOcean is a hosting service provided by DigitalOcean Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United Kingdom – Privacy Policy.

• Infrastructure monitoring

  This type of service allows this Website to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.

  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.

  Bugsnag (Bugsnag Inc.)

  Bugsnag is a monitoring service provided by Bugsnag Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Mandrill (The Rocket Science Group, LLC.)

  Mandrill is an email address management and message sending service provided by The Rocket Science Group, LLC.

  Personal Data collected: email address; Usage Data.

  Place of processing: US – Privacy Policy.

• SPAM protection

  This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Google reCAPTCHA

  Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant.

• Traffic optimization and distribution

  This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
  Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
  Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

  Cloudflare (Cloudflare)

  Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
  The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.

  Personal Data collected: Cookies; various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

• Application forms for corporate social responsibility funding

  By filling in any application form on this Website with their Data, the User authorizes the Owner to use these details to consider potential funding, carry out further enquiries, and contact the User or to reply to any other kind of request as indicated by the form's header and paragraphs.

  Personal Data collected: email address; first name; last name; name of organisation; postal address.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.