PRIVACY POLICY
Kamla-Kay McKenzie, professional model and model coach shall be referred to as “Kamla-Kay McKenzie”, “we”, “us”, “our” throughout this privacy policy.
Kamla-Kay McKenzie respects your privacy and is committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR), and any country-specific data protection regulations applicable to Kamla-Kay McKenzie and her content.
This privacy notice will inform you as to how Kamla-Kay McKenzie and her content partners look after your personal data, your privacy rights and how the law protects you when you visit our website www.kamlakay.com (regardless of where you visit or access it from).
1. IMPORTANT INFORMATION
PURPOSE OF THIS PRIVACY POLICY
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you request us to contact you either via the website, mobile app or recommended tab link.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
DATA CONTROLLER
Kamla-Kay McKenzie is the controller and responsible for your personal data collected through this website. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please use the contact form to submit your inquiry, request or concern.
CONTACT DETAILS
Should you need to contact us for any details regarding our policy, you can use the contact method below.
Name: Kamla-Kay McKenzie
Email: primeangles@kamlakay.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns first before you approach the ICO so please always contact us immediately to give us the opportunity to address your concern.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version is dated September 21, 2020 and we reserve the right to amend this privacy policy in line with any legal requirements at any time.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications (such as social media platforms or links to our partners’ websites). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Kamla-Kay McKenzie’s platform does not control these third-party websites and is not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
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).
We may collect, use, store and transfer different kinds of personal data about you through this website as follows:
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Identity Data includes first name, last name, or similar identifier and a brief description of your requirement and any other identity data that you provide through the Kamla-Kay McKenzie website.
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Contact Data includes address, e-mail address and telephone numbers and any other contact data you provide through the Kamla-Kay McKenzie website
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Profile Data includes personal description, qualifications, modeling/acting experience, and customer feedback
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Marketing & Communication Data includes products and services you have purchased, or expressed an interested in, business sector, exhibitions, meet-ups, coaching classes or events attended.
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Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
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Usage Data includes information about how you use our website..
We also collect and use and share Aggregated Data such as statistical or demographic data for purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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). For freelance models or those aspiring to gain modeling coaching or booking, we may require to collect disclosures of previous criminal convictions if a client project requires such disclosures such as projects relating to working with children.
We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), comments, feedback, product reviews, recommendations, and personal profile.
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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
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Direct interactions. You may give us your Identity and Contact Data by requesting further information, filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
— subscribe to our newsletter or publication;
— request a quote for further information about our services;
— request industry information to be sent to you;
— input information into Tabsview to create a staff profile; or
— give us some feedback.
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Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
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Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
— analytics providers;
— advertising networks;
— search information providers.
Cookies:
It's important to note that third-party services, such as Google Analytics or other applications offered through the Wix App Market, placing cookies or utilizing other tracking technologies through Wix´s services, may have their own policies regarding how they collect and store information. As these are external services, such practices are not covered by the Wix Privacy Policy.
Cookies are implemented in every site built by Wix. Take a look at the table below to view which cookies Wix implements on Wix sites:
Cookie name Lifespan Purpose
svSession Permanent Creates activities and BI
hs Session Security
incap_ses_${Proxy-ID}_${Site-ID} Session Security
incap_visid_${Proxy-ID}_${Site-ID} Session Security
nlbi_{ID} Persistent cookie Security
XSRF-TOKEN Persistent cookie Security
smSession Two weeks Identify logged in site members
4. HOW 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:
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Where we need to perform the contract we are about to enter into or have entered into with you.
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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.
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Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 where more than one ground has been set out in the table below.
1. To manage our relationship with you which will include:
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Responding to a request for a quote, to schedule coaching sesssions or offer of freelance work, or further information about our services
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Notifying you about changes to our terms or privacy policy
Types of data we will use for this purpose: Identity, Contact, Marketing & Communication,
Lawful basis for processing including basis of legitimate interest:
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Performance of a contract with you
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Necessary to comply with a legal obligation
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Necessary for our legitimate interests (to keep our records updated and to analyse how clients use our services)
2. 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 we will use for this purpose: Identity, Contact, Technical
Lawful basis for processing including basis of legitimate interest:
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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 restructure or group restructuring exercise)
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Necessary to comply with a legal obligation
3. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we publicize to you
Types of data we will use for this purpose: Identity, Contact, Usage, Marketing & Communication, Technical.
Lawful basis for processing including basis of legitimate interest:
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Necessary for our legitimate interests (to analyze how clients use our services, to develop our business and to inform our marketing strategy)
4. To use data analytics to improve our website, services, marketing, client relationships and user experiences
Types of data we will use for this purpose: Usage, Technical.
Lawful basis for processing including basis of legitimate interest:
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Necessary for our legitimate interests (to analyze how clients use our services, to develop our business and to inform our marketing strategy)
5. To make suggestions and recommendations to you about services that may be of interest to you
Types of data we will use for this purpose: Identity, Contact, Usage, Marketing & Communications, Technical.
Lawful basis for processing including basis of legitimate interest:
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Necessary for our legitimate interests (to develop our business)
6. To provide access to, and use of booking classes or modeling jobs.
Types of data we will use for this purpose: Identity, Contact, Profile,
Lawful basis for processing including basis of legitimate interest:
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Performance of a contract with you
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Necessary for our legitimate interests (or the legitimate interests of our clients)
We may contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, text messages, and postal mail.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical and Usage 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 services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We do not share your personal data with any company outside the Kamla-Kay McKenzie group for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a contract for services that you have with us.
CHANGE OF PURPOSE
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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External Third Parties as set out in the Glossary.
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Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL DATA TRANSFER
Some of our external third party service providers and clients may be based outside the European Economic Area (EEA), in which case, their processing of your personal data may involve a data transfer outside of the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
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We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (such as New Zealand or Switzerland).
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Where we use certain service providers, we may use specific contracts approved by European Commission which give personal data the same protection as it has under EU data protection law.
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Where we use service providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires the service provider to apply a similar standard of protection to personal data shared between EU and the US.
Alternatively, we may transfer your personal data outside the EEA where data protection law allows or requires us to do so.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to agents, coaches, photographers, stylists, make-up artists and affiliate 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.
Should we suspect a suspected personal data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorized 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 requirements.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data (as set out in more detail below), including the right to:
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Request access to your personal data.
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Request correction of your personal data.
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Request erasure of your personal data.
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Object to processing of your personal data.
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Request restriction of processing your personal data.
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Request transfer of your personal data.
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Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
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 may refuse to comply with your request in these circumstances. Fees will be used as it relates to booking a set service such as modeling, model coaching where such services is set-up as a pay to book offering.
WHAT WE MAY NEED FROM YOU
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 to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
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Service providers who provide IT, cloud storage, software development and system administration services, app services.
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Our clients, where you have input your personal data on kamlakay.com for the purposes of enabling our clients to undertake field reporting.
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Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide legal, banking, insurance, accounting and consultancy services.
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Tax authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
YOUR LEGAL 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.
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 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.