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Data Protection & Privacy Policy 

1. Introduction 

 1.1. DK2 Seaport Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will give you information on how DK2 Seaport Ltd collects and processes your personal data and tell you about your privacy rights.

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1.2. This privacy notice applies to all services we provide

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1.3. We keep our privacy notice under regular review and we may amend it. 

2. WHICH PERSONAL DATA MIGHT BE COLLECTED? 

 2.1. When we use the term "personal data", we mean any information about you (as individual) from which you can be identified like: 

  • Identity Data – e.g. first name, last name, username or similar identifier, title; 

  • Contact Data – e.g. billing address, email address and telephone numbers; 

  • Financial Data – bank account and payment card details; 

  • Transaction Data – details about payments to and from you and other details of Services you have purchased from us; 

  • Marketing and Communications Data – e.g. your preferences in receiving marketing from us and, as the case maybe, our third parties and your communication preferences. 

3. WHAT TO INCLUDE IN THE PRIVACY POLICY

We do not collect any special categories of personal data about you (like 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 information about criminal convictions and offences. 

4. How is your personal data collected? 

We use different methods to collect data from and about you including through: 

4.1. Data you provide us directly when you provide this data via email, by filling in forms or by corresponding with us by post, phone, or otherwise. This includes personal data you provide when you apply for our services, request marketing to be sent to you, or give us feedback or contact us. 

5. How do we use your personal data? 

5.1. We will only use your personal data when the law allows us to.

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5.2. When collected, we will use your personal data to perform a contract with you, to comply with a legal obligation or where it is necessary for our legitimate interests and they’re not overridden by your rights.

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5.3. This includes using your personal data for the following purposes: 

  • to manage our relationship with you; 

  • to communicate with you; 

  • Þ to assist you; 

  • to improve our services, marketing, customer relationship and experiences and develop new services; 

  • to protect you from fraudulent activities, administer and protect our business; 

  • to market to you (refer to details below); and

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5.4. Generally, we do not rely on consent as a legal basis for processing your personal data and we may process your personal data without your knowledge or consent, in compliance with this privacy notice, where this is required or permitted by law.

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5.5. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

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5.6. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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5.7. Specific case of Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

6. HOW CAN WE SHARE your personal data?

6.1. If we need to share your personal data with third parties, we will only disclose it to: 

  • professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

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6.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 

7. CAN YOUR PERSONAL DATA BE TRANSFERRED TO ANOTHER COUNTRY? 

If and when we share data, it may be transferred out of the country you reside, we will ensure your personal data is protected by, in addition to any other safeguards we may put in place, ensuring transfer of your personal data only to overseas organisations which are bound (either by law, contract or otherwise) to provide a standard of protection which is comparable to that under the UK Data Protection Act 2018. 

8. HOW ARE YOUR DATA SECURED?

8.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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8.2. 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. 

9. How long MAY WE use YOUR personal data for?

9.1. We will only retain your personal data for as long as we have a relationship with you or as long as it is reasonably necessary to fulfil the purposes we collected it for. Following that period, we will make sure it is deleted or anonymised (in which case we may use this information indefinitely without further notice to you). 

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9.2. However, we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

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9.3. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

10. WHAT ARE Your legal rights? 

10.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data: 

  • Request access to your personal data – 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 your personal data – 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. 

  • 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 override your rights and freedoms. 

  • Request restriction of processing your personal data – this enables you to ask us to suspend the processing of your personal data in the following scenarios: 

- if you want us to establish the data's accuracy; 

- where our use of the data is unlawful but you do not want us to erase it; 

- 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; and 

- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

  • Request 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. 

  • Right to 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

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10.2. If you wish to exercise any of the rights set out above, please contact us at paula@k2advisor.com. 

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10.3. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

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10.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you 

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