Privacy Policy

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KINBRAE CONSULTING LTD

PRIVACY NOTICE

1. Who we are

We are Kinbrae Consulting Ltd, a company incorporated and registered in Scotland with registered number SC84593 and having its registered office address at 8 Lawrence Street, Buckhaven, Leven, Fife, Scotland, KY8 1BQ.
We are a controller for the purposes of the UK General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act 2018, except in relation to certain services we may carry out for our clients where we may be a processor.

2 How to contact us

If you have any questions about this privacy notice, including any requests to exercise your legalrights, please contact us using the details set out below.

• By post: 8 Lawrence Street, Buckhaven, Leven, Fife, Scotland, KY8 1BQ.

• By phone: 0330 133 44 77

• By email: contact@kinbraeconsulting.

• Online: www.kinbraeconsulting.com/contact

3. Privacy Information

We are committed to protecting your personal data and your privacy. It is important that you read this privacy notice so that you are fully aware of how and why we are using your personal data. 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. This version of our privacy notice was last updated on 15 October 2025.
4. To whom does this privacy notice apply?

This privacy notice applies to:

Website visitors: all individuals who visit our website: https://www.kinbraeconsulting.com/ (or any other domain name registered in our name) (the “Website”);
Customers: all individuals who enquire about our services, purchase our services or are otherwise existing, former or prospective customers of Kinbrae Consulting Ltd;
Customer contacts: all individuals who are our customer contact persons where the individual's organisation is or has been our customer;
Business contacts: all individuals who are our business contacts where the individual or the individual's organisation are our sub-contractors, supply goods or services to us, provide professional services, have expressed an interest in us (including by contacting us by post, telephone, e-mail, social media or other means) or have any other business relationship with us (including where the individual's organisation is a public authority, an industry body or regulatory authority or similar).

5. About the personal data that we collect and process

“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”). “Special categories of personal data” 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. We do not intentionally obtain special categories of personal data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data which includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account 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, device ID and other technology on the devices you use to access this Website.
Usage Data includes information about how you interact with and 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 also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

6. How is your personal data obtained?
We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services; create an account on our Website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us.
Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.kinbraeconsulting.com/cookie-policy for further details.
Third parties or publicly available sources. We do not currently receive or collect personal data about you from any third parties. This privacy policy is reviewed regularly and will be updated accordingly if this were to change in the future.

7. How is your personal data used?

Lawful Basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract, we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

Purpose/Use	Type of data	Legal basis
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your services order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(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 will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Marketing and Communications	(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 manage our relationship with you)
To enable you to take party in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(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 deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve you.	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).strategy).strategy).strategy).
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	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 send you relevant marketing communications	(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) Consent, having obtained your prior consent to receiving direct marketing communications
To carry out market research through your voluntary participation in surveys		Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services)develop our products and services)develop our products and services)develop our products and services)

8. Failure 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 services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

9. Marketing

If you are an individual customer (including a prospective customer), we will only provide you with direct marketing communications where you have consented to receive such communications or you have contacted us directly to request specific information about our products. You can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us using the contact details above at paragraph 2.
If you represent another business (you are a business contact), we may provide you with direct marketing communications (by e-mail, post or telephone) where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us using the contact details above at paragraph 2 (or by clicking “unsubscribe” at the bottom of any marketing e-mail.)
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.

10. With whom do we share your personal data?

There may be circumstances in which we may also need to share your personal data with certain third parties (on a confidential, business need-to-know basis). The third parties to which we may transfer your personal data include:

Service providers acting as processors who provide IT and system administration services (including managed IT service providers).
Professional advisers including lawyers, accountants, auditors and insurers who provide consultancy, legal, insurance and accounting services.
Any relevant regulatory authority or law enforcement agency, including HM Revenue & Customs, courts or tribunals who require reporting of processing activities in certain circumstances.
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 inaccordance with our instructions.

11. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Our main service provider is Zoho Corporation Limited (Company number 09639140) and their data centres are mainly based in the EU.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We may transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely countries within the European Union as governed by the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
We may also use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. Where we do use these contractual safeguards, you can obtain a copy of them by contacting us at contact@kinbraeconsulting.com.

Otherwise, we generally do not transfer your personal data out of the United Kingdom. Whenever we do transfer your personal data out of the United Kingdom to countries which have laws that do not provide the same level of data protection as the United Kingdom law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

we will only transfer your personal data to countries that have been deemed by the United Kingdom to provide an adequate level of protection for personal data.
we may use specific standard contractual terms approved for use in the United Kingdom which give the transferred personal data the same protection as it has in the United Kingdom, namely the International Data Transfer Agreement the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards , please contact us at www.kinbraeconsulting.com/contact.

12. How long do we retain your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. 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. 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 In some circumstances you can ask us to delete your data: see paragraph 14 below for further information.

13. Data security

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. We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner's Office of a breach where we are legally required to do so.

14. Your rights

Your personal data is protected by legal rights, which include your rights 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 haveany 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. 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, following 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.
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: 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; or 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 (data portability). 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us using the contact details above at paragraph 2.

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.
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. 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.

15. Complaints

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 before you approach the ICO so please contact us in the first instance.

16. 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 we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.