Privacy Statement
Thank you for visiting kinkprojects.com.  The personal 
data of our readers is treated with great consideration and privacy.  It
 is important that the personal and private data we hold about you is 
accurate and current.  Please keep us informed if your personal data 
changes during your relationship with us.
What personal data do we collect?
Personal
 data, or personal information, means any information about an 
individual from which that person can be identified.  It does not 
include data where the identity has been removed (anonymous data).
When
 you visit our website, we may collect, use, store and transfer 
different kinds of personal data about you which we have grouped 
together as follows:
- Identity Data includes [first name, last name, username or similar identifier, title, date of birth and gender].
- Contact Data includes [billing address, delivery address, email address and telephone numbers].
- Financial Data includes [bank account (if required) and payment card details].
- Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
- Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the services you use to access this website].
- Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
- Usage Data includes [information about how you use our website, products and services].
- Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
We do not collect any Special Categories of Personal Data about
 you (this includes details about your race or ethnicity, religious or 
philosophical beliefs, sex life, sexual orientation, political opinions,
 trade union membership, information about your health and genetic and 
biometric data).  Nor do we collect any data about criminal convictions 
and offences.
If you fail to provide personal data
Where
 we need to collect personal data by law, or under the terms of a 
contract we have with you and you fail to provide that data when 
requested, we may not be able to perform the contract we have, or are 
trying to enter into with you (for example, to provide you with goods or
 services).  In this case, we may have to cancel a product or service 
you have with us, but we will notify you if this is the case at the 
time.
When do we collect your personal data?
We collect personal data when you:
- purchase products
- subscribe to our email newsletters
- contact our customer services with an enquiry or comment
We may receive your personal data if you have bought one of our
 products as a gift. In this situation, the data will be provided by the
 person who has bought the gift.  In this context, we will collect the 
gift recipient's name, address, email address, and telephone number.
How do we use your personal data?
We
 will only use your personal data when the law allows us to.  Most 
commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for 
processing your personal data.  Where we rely on consent, you have the 
right to withdraw consent to marketing at any time by contacting us.
The following list provides general details about the types of data we process, why we process it, and the lawful basis upon which we do so:
- 
To register you as a new customer
 a) Types of data: Identity, Contact
- 
To process and deliver your order
- Types of data: Identity, Contact, Financial, Transaction, Marketing and Communications
- Lawful basis: a) Performance of a contract with you, (b) Necessary for our legitimate interests (to recover debts due to us)
 
- 
To manage our relationship with you which may include
 notifying you about changes to our terms or privacy policy, or updating
 you about the status of your subscription
- Types of data: a) Identity, b) Contact, c) Profile, d) Marketing and Communications.
- Lawful basis: a) Performance of a contract with you, b) Necessary to comply with a legal obligation, c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
 
- 
To enable you to partake in a prize draw, competition or complete a survey
- Types of data: a) Identity, b) Contact, c) Profile, d) Usage, e) Marketing and Communications
- Lawful basis: a) Performance of a contract with you, b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
 
- 
To administer and protect our business and this 
website (including troubleshooting, data analysis, testing, system 
maintenance, support, reporting and hosting of data)
- Types of data: a) Identity, b) Contact, c) Technical
- Lawful basis: a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), b) Necessary to comply with a legal obligation
 
- 
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
- Types of data: a) Technical, b) Usage
- Lawful basis: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
 
- 
To make suggestions and recommendations to you about goods or services that may be of interest to you
- Types of data: a) Identity, b) Contact, c) Technical, d) Usage, e) Profile
- Lawful basis: Necessary for our legitimate interests (to develop our products/services and grow our business)
 
Marketing
We
 may use your Identity, Contact, Technical, Usage and Profile Data to 
form a view on what we think you may want or need, or what may be of 
interest to you.  This is how we decide which products, services, 
newsletters and offers may be relevant for you (we call this marketing).
You will receive marketing communications (including 
newsletters) from us if you have requested information from us or 
purchased goods or services from us, or if you provided us with your 
details when you entered a competition or registered for a promotion, or
 you have consented to receive marketing communications from us and, in 
each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages or adjust your marketing preferences at any time:
- by logging into your online account and checking or unchecking relevant boxes to adjust your marketing preferences;
- or by following the unsubscribe links on any marketing message sent to you;
- or by contacting us.
How we protect your data
Your
 personal data is stored securely on databases and servers that are 
maintained either by us, or by our third-party service providers.
For any of our website sections that process payment, or have 
password-protected areas, we use HTTPS - your web browser should 
indicate that such pages are secure.  Access to your personal data is 
password-protected, and sensitive data (such as payment card 
information) is secured by SSL encryption.
We maintain administrative, technical and physical safeguards 
to protect against unauthorised access, use, modification and disclosure
 of any personal data in our custody and control.  Internal access to 
personal data is restricted to specific employees.
We have put in place procedures to deal with any suspected 
personal data breach and will notify you and any applicable regulator of
 a breach where we are legally required to do so.
Who do we share your personal data with?
After
 we collect your personal data, we may transfer it to trusted 
third-party service providers who are required to maintain the 
confidentiality and security of your personal data and to use it only in
 compliance with data privacy laws, and for specified purposes in 
compliance with our instructions. Each service provider is also 
responsible for their use of your personal data, according to rules they
 set in their own privacy policies.
Here is an outline of how and why we pass your personal data to third parties, in three key areas:
- fraud protection
- online customer support
- email marketing
Your Rights
You have the right to:
- Request access to your personal data (commonly
 known as a "data subject access request"). This enables you to receive a
 copy of the personal data we hold about you and to check that we are 
lawfully processing it.
- Request correction of the personal data that we hold about you. This
 enables you to have any incomplete or inaccurate data we hold about you
 corrected, though we may need to verify the accuracy of the new data 
you provide to us. You can amend personal data we hold about you via 
your [account page](/account/].
- Request erasure of your personal data. This
 enables you to ask us to delete or remove personal data where there is 
no good reason for us continuing to process it.  You also have the right
 to ask us to delete or remove your personal data where you have 
successfully exercised your right to object to processing (see below), 
where we may have processed your information unlawfully, or where we are
 required to erase your personal data to comply with local law.  Note, 
however, that we may not always be able to comply with your request of 
erasure for specific legal reasons which will be notified to you, if 
applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or
 those of a third party) and there is something about your particular 
situation which makes you want to object to processing on this ground as
 you feel it impacts on your fundamental rights and freedoms. You also 
have the right to object where we are processing your personal data for 
direct marketing purposes.  In some cases, we may demonstrate that we 
have compelling legitimate grounds to process your information which 
over-ride your rights and freedoms.
- Request restriction of processing of your personal data. This
 enables you to ask us to suspend the processing of your personal data 
in the following scenarios: (a) if you want us to establish the data's 
accuracy; (b) where our use of the data is unlawful, but you do not want
 us to erase it; (c) where you need us to hold the data even if we no 
longer require it as you need it to establish, exercise or defend legal 
claims; or, (d) you have objected to our use of your data but we need to
 verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We
 will provide to you, or a third party you have chosen, your personal 
data in a structured, commonly used, machine-readable format.  Note that
 this right only applies to automated information which you initially 
provided consent for us to use, or where we used the information to 
perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However,
 this will not affect the lawfulness of any processing carried out 
before you withdraw your consent. If you withdraw your consent, we may 
not be able to provide certain products or services to you. We will 
advise you if this is the case at the time you withdraw your consent.
Cookies Policy
What are cookies?
Cookies
 are small text files, which are set by us in your web browser.  Cookies
 store data that enhances your experience of the website (for example 
saving your shopping bag between pages); they also enable us to gather 
anonymous information on website use, which we can use to improve our 
service to you; they are also used by some of our third-party service 
providers, again to track usage and to save data between pages.
How we use cookies
We use cookies to:
- Anonymously record and analyse website usage
- Enable signing in to your online account
- Have a shopping bag which saves your purchases as you shop online
- Store information that you set whilst using the website (e.g. the volume of the radio, the visibility of a notification)
- We may also use cookies to personalise your experience on our website, by recognising you and tailoring content or product and service offerings.
How to control or delete cookies
The
 majority of web browsers automatically enable cookies as a default 
setting.  To stop cookies being stored on your computer in future, 
you'll need to alter the settings of your web browser.  You should also 
be able to delete cookies via your browser settings.
You can find instructions on how to 
control or delete cookies by clicking 'Help' in your browser’s menu bar,
 or by following these browser-by-browser instructions from AboutCookies.org
For Google Analytics cookies you can also stop Google from 
collecting your information by downloading and installing the Google 
Analytics Opt-out Browser Add-on.
Please note that by deleting our cookies or preventing future cookies,  your experience on our website will be limited.
Third-Party Links
Our
 website may include links to third-party websites, plug-ins and 
applications. Clicking on those links or enabling those connections may 
allow third parties to collect or share data about you.  We do not 
control these third-party websites and are not responsible for their 
privacy policies or use of your personal data. When you leave our 
website, we encourage you to read the privacy notice of every website 
you visit.
You have the right to make a complaint at any time TO THE CHINA
 supervisory authority for data protection issues 
(www.kinkprojects.com).  However, we would appreciate the chance to deal
 with your concerns before you approach the authority, so please contact
 us in the first instance. 
Contacting Us
How to contact us
To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint, please contact  [email protected].  We aim to respond to all queries within 48 hours.
Controller
Name
 of Company - is the controller and responsible for your personal data 
(collectively referred to as, the 'company', 'we', 'us' and 'our' in 
this privacy policy). 
Email: service@kinkprojects.com
