UK GDPR Privacy Policy

KONG toy

Privacy Notice

1Introduction
1.1The KONG Company EU GmbH and the KONG Company Limited (hereafter “we”, “us”, “our”) are committed to protecting the privacy and security of your personal data.
1.2This privacy notice describes how we process your personal data, in accordance with the applicable legal acts, in particular, the European General Data Protection Regulation (hereafter “GDPR”).
1.3We are joint controllers. This means that we are jointly responsible for deciding how we process your personal data. We are happy to notify you in accordance with Art. 13, Art. 14 and Art. 26 GDPR, Art. 25 Telecommunications and Telemedia Data Protection Act (hereafter “TTDSG”).
1.4This privacy notice aims to inform you on how we process your personal data on our website and in our back office.
1.5We hope that you read and - if you like - retain this privacy notice, so that you in particular are aware of how and why we are using your personal data and what your rights are.
2Contact Information
2.1Our contact details, that means of each of the controllers and the contact details of the data protection officer of the KONG Company Limited and the EU Representative of the KONG Company Limited are:

THE KONG Company EU GmbH
Solmsstraße 71, 60486 Frankfurt am Main, Germany
Telephone: +44 1722 783211
email: datacompliance@kongcompany.com

THE KONG Company Limited
Units 7 High Post, Salisbury, England, SP4 6AT
Telephone: +44 1722 783211
email: datacompliance@kongcompany.com

Data Protection Officer of the KONG Company Limited
Units 7 High Post, Salisbury, England, SP4 6AT
Telephone: +44 1722 783211
email: datacompliance@kongcompany.com

EU Representative of THE KONG Company Limited:
THE KONG Company EU GmbH

2.2We have appointed a Data Protection Compliance Team to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we process your personal data, please contact us and this team. They can be contacted via datacompliance@kongcompany.com or via the other contact details named in Section 2.1.
3Links on our website, Browser settings
3.1Our website may include links to third-party websites. Clicking on those links 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 notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3.2You can set your browser to decline all or some browser cookies, or to alert you when websites set or access cookies. If you disable or decline cookies, please note that some parts of this website may become inaccessible or not function properly.
4Which kind of information we process?
4.1Personal Data (hereafter “Data”) means any information about an individual by the means of which that individual can be identified.
4.2We may collect, use, store, transfer or otherwise process different kinds of Data about you which we have grouped together as follows:
4.2.1Contact Data: in particular first name, last name, username, delivery address, email address and telephone numbers;
4.2.2Business Contact Data: in particular business contact name, company name, trading name, , registered number, phone number, website, trading storefront name, business contact address;
4.2.3Request Data: in particular details of enquiry, comments, warranty requests, faults requests, action to resolve the enquiry or request;
4.2.4Product Data: in particular product name, product size, warranty;
4.2.5Order Data: in particular quantity of products, type of products;
4.2.6Pet Data: in particular type of pet, age, weight;
4.2.7Legal Data: in particular authorization to sell KONG products;
4.2.8Financial Data: in particular bank account and payment card details;
4.2.9Communication Data: in particular content of the communication, communication partner, your communication preferences;
4.2.10Technical Data: in particular meta data of the communication such as internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform;
4.2.11Usage Data: in particular information about how you use our website, products and services; and
4.2.12Marketing Data: in particular preferences in receiving marketing from us and third parties.
4.3The processing of your Data as described in this privacy policy is required neither by law nor by contract. However, it is required for achieving the purposes described in this privacy policy. If you fail to provide that data when requested, we may not be able to perform the purposes mentioned in Section 7, Section 8, Section 11.
5Aggregated Information
We may also collect, use and share aggregated information such as statistical or demographic information for any purpose. Aggregated information may be derived from your Data but is legally not considered data as this information 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.
6How is your Data collected?
6.1We collect your Data through our direct interactions, such as via our website, post, email or otherwise. We also collect when you use our customer services or give us some feedback.
6.2We collect information from third parties: the KONG Group companies, technical, financial services and logistic providers, our lawyers and other counsellors..
7How we will use your Data?
7.1We process your Data for the following purposes and on the following legal basis:
7.1.1In the cases, you have given us your consent. The legal basis for this processing is Art. 6. para 1 lit. a GDPR.
7.1.2In the case, that you have given your consent for the storage of Data or information in your end device or for the access of Data or Information already stored in it. The legal basis for this processing is Art. 25 Telecommunications and Telemedia Data Protection Act (TTDSG) in conjunction with GDPR, in particular Art. 7 GDPR.
7.1.3In case, it should be necessary for the performing of a contract, of which you are contractual partner, or in order to process your request prior to entering into a contract with you. The legal basis for this processing is Art. 6 para 1 lit. b GDPR.
7.1.4Where we need to fulfil a legal obligation, the legal basis is Art. 6 para 1 lit. c GDPR in conjunction with the applicable German, EU or International Law.
7.1.5To maintain and fulfil B2B and other relationships, to fulfil other contractual and quasi-contractual obligations, to work effectively in the KONG Group, to aggregate Data, to enable a due diligence or a company restructuring process, to document the processes, to optimize procedures, for the assertion of legal claims and defence in legal disputes, for business management purposes and to comply with legal requirements (in particular UK Laws). The legal basis for these processing is Art. 6 para 1 lit. f GDPR. The legitimate interests are identical with the named purposes.
7.1.6To manage and protect this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data. The legal basis is Art. 6 para 1 lit. f GDPR. The legitimate interests are identical with the named purposes.
7.1.7To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. The legal basis for this processing is Art. 6 para 1 lit. f GDPR. The legitimate interest is to be able to provide us with up-to-date information on the effectiveness and structure of our business, our website and our marketing resources as well as to measure the success of our products and services.
7.1.8The cost- and resource-effective implementation of the purposes mentioned in Section 7.1.1 to 7.1.7. The legal basis for this processing is Art. 6 Para 1 lit. f GDPR. The legitimate interest for the disclosing, transmitting and otherwise processing of your Data with the group companies and third parties, in particular IT service providers, logistic providers, lies in the cost- and resource-efficient implementation of these purposes mentioned in 7.1.1 to 7.1.7.
8Marketing
We strive to give you the possibility to choose regarding the use of your Data, particularly in relation to marketing and advertising actions. You will receive marketing communications if you have requested information or services from us (regarding the legal basis please see section 7).
9Data recipients
We may have to share your Data with third parties, including third-party service providers (IT service providers, financial providers, logistic providers) and other entities in the KONG Group, professional counsellors (such as lawyers, auditors) regulators and other authorities. We require third parties to respect the security of your Data and to treat it in accordance with the law.
10Transfer to Third Countries
We may transfer your Data outside the EU. If we do, you can expect a similar degree of protection in respect of your Data. We do not allow our third-party service providers to use your Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions. Thereby, we transfer your Data to the United Kingdom. The United Kingdom has according to the Adequacy Decision (Art. 46 GDPR) of the European Commission an adequate level of data protection. We might transfer your Data to the USA. There is no adequacy decision of the European Commission for a transfer of your Data to the USA. A transfer of your data therefore takes place in accordance with Art. 46 para 2 GDPR. If you would like to receive a copy of the contract or provisions that are relevant for you, please contact us or our data compliance team (contact details are in Section 2.1).
11When are we allowed to share my personal information with other entities in the group?
We will share your Data with other entities in the KONG Group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data (regarding the legal basis please see section 7).
12Data Security
12.1We have put in place technical and organizational measures to protect the security of your Data. We have put in place appropriate security measures to prevent your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
12.2We have put in place procedures to deal with any suspected data security breach and will notify you and all responsible regulators, in the cases we are legally obliged to do so.
13Data Retention
13.1We will only retain your Data for as long as necessary to fulfil the purposes we collected it for. The KONG Group has the following retention policy:
13.1.1The server log files are deleted after one month. The period begins with the collection of the Data.
13.1.2The session cookies are deleted after the session has ended. Other cookies are deleted after 18 months. The period begins with the collection of the Data.
13.1.3Your revoked consent or your enquiry is deleted after 3 years. The period begins with the end of the year in which consent was given.
13.1.4Your data which is processed in the context of a B2B relationship is deleted after 10 years. The deletion period begins with the end of the year in which the B2B relationship was terminated.
13.1.5In case of an unauthorized use of KONG product your Data is deleted after 10 years. The period begins with the end of the year in which we have gained knowledge of the unauthorized use and the relevant action occurred.
14Your Rights
14.1It is important that the Data regarding you, which is in our possession, is accurate and up to date. Please keep us informed if your Data changes during your business relationship with us.
14.2You have the right to:
14.2.1Request access to your Data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the Data we process and to check that we are processing it lawfully (Art. 15 GDPR).
14.2.2Request correction of the your Data we process. This enables you to have any incomplete or inaccurate information we hold corrected (Art. 16 GDPR).
14.2.3Request erasure of your Data. This enables you to ask us to delete or remove your 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 Data where you have exercised your right to object to processing (see below) (Art. 17 GDPR).
14.2.4Object to processing of your 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 (Art. 21 para 1 GDPR). You also have the right to object at any time and without reason in the cases when we are processing your Data for direct marketing purposes (Art. 21 para 2 GDPR).
14.2.5Request the restriction of processing of your Data. This enables you to ask us to suspend the processing of your Data, for example, if you want us to examine its accuracy or the reason for processing it.
14.2.6Request the transfer of your Data to third party (Art. 20 GDPR).
14.2.7In the cases, where you have provided your consent you have the right to withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on your consent before its withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
14.2.8Lodge a complaint with a supervisory authority at any time, in particular in the State Member where you reside, work or the alleged breach of the GDPR has occurred, Art. 77 GDPR.
14.3If you want to assert any of your rights please, contact us or our Data Protection Compliance Team (see our contact details are in section 2.1).
14.4The access to your personal information is free of charge (as well as the enforcement of any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, in certain circumstances, we may refuse to comply with the request.
14.5We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
15Changes to the privacy notice
We reserve the right to update this privacy notice at any time.
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