Your Personal Data: A Privacy Notice
Company Information
KLS is the trading name of Kwil Legal Services Ltd which is registered in England and Wales no. 13224969 and is regulated by the Solicitors Regulation Authority no. 826341, whose registered trading address is 30 Clarendon Road, Watford, WD17 1JJ.
Definitions
User: The individual who is making payments to a company through KLS.legal’s application. Within the context of this Privacy Notice, a User may be referred to as ‘you’.
Client Company: A company or body that is owed money by individuals and uses KLS.legal to set up instalment payment plans for those individuals to settle outstanding debts.
Your Initial Invitation
A Client Company will use KLS.legal to issue invitations to individuals (data subjects) who owe a debt, and to whom the Client Company wishes to provide the option to pay this debt in instalments. This will invite an individual to create a KLS.legal account.
At this point, KLS.legal acts only as a Data Processor for the Client Company, who will be the Data Controller. KLS.legal does not access any of the data subjects’ information, except to send this invitation, on behalf of the Client Company.
Becoming a User – What data KLS.legal will need
When an individual creates a KLS.legal account, and becomes a User, KLS.legal will be what is known as the ‘Controller’ of the personal data provided to us. Unless otherwise agreed with a User, we will only collect basic personal data, which does not include any special categories of personal information (often known as ‘sensitive personal data’).
This information does, however, include the likes of a User’s name, home address, email address, telephone number and other details required for that User to log-in to KLS.legal’s website, and process payments.
Why we need this data
We need to know basic personal data in order to provide you with KLS.legal’s service, which requires the creation of a unique user account. Personal information is required to verify identity for security purposes. Initial information from the Client Company, including a User’s email address will also be necessary to send an invitation to set-up an account with KLS.legal.
Details regarding any debts a User has with a Client Company will be processed for the purposes of setting up a scheduled payment plan through KLS.legal, and information relating to payments, missed payments and payment completions will be shared with the Client Company.
In the initial sharing of data from the Client Company to issue an invitation to create a KLS.legal account, the legal basis for processing this data is the Client Company’s legitimate business interest. When an individual becomes a KLS.legal User, it is that User’s consent, our contractual obligation, and legitimate business interest that form KLS.legal’s legal basis for processing their personal data, as the Data Controller.
What we will do with your data
All the personal data we hold about a User will be processed by our staff in the United Kingdom and Spain. Data will be shared and exchanged with the Client Companies that a User confirms they wish to have payment plans created with via KLS.legal.
How a User’s personal data is processed by a Client Company will be down to that company, and a formal relationship and agreement should already be in place between a User and any Client Company to whom the User owes a debt, which is to be settled using KLS.legal.
Please be aware that your information may be stored on a cloud-based system whose servers are located within the European Union.
We take all reasonable steps to ensure that your personal data is processed securely.
Your Payment Card data
It will be necessary to use a payment card (debit or credit) to set up regular payments through KLS.legal, which will go to the Client Company or Companies, with whom a User has set up a plan.
All card payments are processed using Stripe. KLS.legal does not store any payment card information. All payment card information that is entered using our website and/or app is sent to Stripe and stored within their servers. The payments are then processed through Stripe and made directly to the Client Company that the User has set up a payment plan with.
How long we will keep your data
We will retain a User’s personal data if that User has an active KLS.legal account. Should the account be closed, for any reason, the User’s data will be retained for a period of six years after the point of closure, unless a specific request is received to purge it.
Checking your details
If you wish to verify the details you have submitted to KLS.legal, you may do so by contacting us via e-mail or writing to the address given below.
Prevention of Money Laundering
We may use and search the records of credit reference or fraud prevention agencies to check a User’s identity, to prevent money laundering, unless that User has furnished other satisfactory proof of identity.
What are your rights?
If at any point you believe the information which we process on you is incorrect, you can request to see this information and even have it corrected or deleted. If you wish to object to your data being processed by KLS.legal, or you would like to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office (ICO) by contacting them on 0303 123 1113 or visiting ico.org.uk.
Our Data Protection Officer is Edward Beesley, and you can contact them at dataprotectionofficer@socialicity.co.uk.