Last Updated July, 1, 2019
By accessing the website at https://kurry.io, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.
2. User License
Permission is granted to temporarily download one copy of the materials (information or software) on Kurry’s website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:
• Modify or copy the materials
• Use the materials for any commercial purpose, or for any public display (commercial or non-commercial);
• Attempt to decompile or reverse engineer any software contained on Kurry’s website;
• Remove any copyright or other proprietary notations from the materials
• Transfer the materials to another person or "mirror" the materials on any other server.
This license shall automatically terminate if you violate any of these restrictions and may be terminated by Kurry at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.
The materials on Kurry’s website are provided on an 'as is' basis. Kurry makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, Kurry does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site. This site is not a part of the Facebook website or Facebook Inc. Additionally, This site is NOT endorsed by Facebook in any way. FACEBOOK is a trademark of FACEBOOK, Inc.
In no event shall Kurry or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on Kurry’s website, even if Kurry or a Kurry authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.
4. Accuracy of Materials
The materials appearing on Kurry’s website could include technical, typographical, or photographic errors. Kurry does not warrant that any of the materials on its website are accurate, complete or current. Kurry may make changes to the materials contained on its website at any time without notice. However Kurry does not make any commitment to update the materials.
Kurry has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by Kurry of the site. Use of any such linked website is at the user's own risk.
Kurry may revise these terms of service for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these terms of service.
7. Governing Law
These terms and conditions are governed by and construed in accordance with the laws of Michigan and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location.
• We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
• Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
• We will collect and use personal information solely for fulfilling those purposes specified by us and for other ancillary purposes, unless we obtain the consent of the individual concerned or as required by law.
• Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
• We will protect personal information by using reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
• We will make readily available to customers information about our policies and practices relating to the management of personal information.
• We will only retain personal information for as long as necessary for the fulfillment of those purposes.
Data protection policy
Kurry needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures Kurry:
· Complies with data protection law and follow good practice
· Protects the rights of staff, customers and partners
· Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach
Data protection law
The Data Protection Act 1998 describes how organisations — including Kurry must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act is underpinned by eight important principles. These say that personal data must:
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection People, risks and responsibilities
This policy applies to:
· The head office of Kurry
· All branches of Kurry
· All staff and volunteers of Kurry
All contractors, suppliers and other people working on behalf of Kurry It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
· Names of individuals
· Postal addresses
· Email addresses
· Telephone numbers
plus any other information relating to individuals
Data protection risks
This policy helps to protect Kurry from some very real data security risks, including: · Breaches of confidentiality. For instance, information being given out inappropriately. · Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them. Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Kurry has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:
The board of directors is ultimately responsible for ensuring that Kurry meets its legal obligations.
The data protection officer is responsible for:
-Keeping the board updated about data protection responsibilities, risks and issues.
-Reviewing all data protection procedures and related policies, in line with an agreed schedule.
-Arranging data protection training and advice for the people covered by this policy.
-Handling data protection questions from staff and anyone else covered by this policy.
-Dealing with requests from individuals to see the data Kurry holds about them (also called ‘subject access requests’).
-Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT Manager is responsible for:
-Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
-Performing regular checks and scans to ensure security hardware and software is functioning properly.
-Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The marketing manager is responsible for:
-Approving any data protection statements attached to communications such as emails and letters.
-Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
The only people able to access data covered by this policy should be those who need it for their work.
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
Kurry will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
In particular, strong passwords must be used and they should never be shared. Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When not required, the paper or files should be kept in a locked drawer or filing cabinet.
Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
Data printouts should be shredded and disposed of securely when no longer required. When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
Data should be protected by strong passwords that are changed regularly and never shared between employees.
If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
Servers containing personal data should be sited in a secure location, away from general office space.
Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Kurry unless the business can make use of it.
However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area. - Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Kurry to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Kurry should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
Kurry will make it easy for data subjects to update the information Kurry holds about them. For instance, via the company website.
Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by Kurry are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting its data protection obligations.
- If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at email@example.com. The data controller can supply a standard request form, although individuals do not have to use this. Individuals will be charged $25 per subject access request. The data controller will aim to provide the relevant data within 14 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Kurry will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Kurry aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.