Privacy Policy
Important information on who we are and how and why we collect, store, use and share your personal information.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
1. Key terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Krystal Hosting Ltd (trading as Katapult) a company incorporated in England and Wales whose registered number is 07571790 and whose registered office is at 124 City Road, London, EC1V 2NX |
| Our data protection officer | David Kimberley Email: Dave@katapult.io Tel: 0208 050 1337 |
| Personal information | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data data concerning health, sex life or sexual orientation |
2. Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number and company details
- information to enable us to check and verify your identity, eg your date of birth
- your gender information, if you choose to give this to us
- location data
- your billing information, transaction and payment card information
- your personal or professional interests
- your contact history, purchase history and saved items
- information from accounts you link to us
- information to enable us to undertake credit or other financial checks on you
- information about how you use our website, IT, communication and other systems your responses to surveys, competitions and promotions
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
3. How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg: sanctions screening providers; credit reference agencies;
- customer due diligence providers;
- from a third party with your consent;
- from cookies on our website—for more information on our use of cookies, please see our cookie policy;
- via our IT systems, eg: automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.
4. How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| To provide services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you or Katapult | For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you |
| Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with legal and regulatory obligations that apply to our business | To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party, ie to promote our business to existing and former customers |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services |
| External audits and quality checks, eg for ISO and the audit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
5. Promotional communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it with other organisations outside the Krystal Hosting Ltd group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by contacting us at team@katapult.io, using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts or updating your marketing preferences on our Katapult Console
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. Who we share your personal information with
We routinely share personal information with:
- companies within the Krystal Hosting Ltd group
- third parties we use to help deliver our services to you, eg payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies;
- third parties approved by you, eg social media sites you choose to link your account to or
- third party payment providers;
- our insurers and brokers;
- our banks.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
7. Where your personal information is held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.
8. How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary: to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly; to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
9. Transferring your personal information out of the UK and EEA
We share your data within the Krystal Hosting group, including Krystal Hosting’s subsidiary companies and on occasion with third party suppliers. This might involve transferring your data outside the United Kingdom (UK) / European Economic Area (EEA). Many of our external third parties are based outside the UK and/or European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK / EEA. Whenever we transfer your personal data out of the UK / EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific approved contracts which ensure an essentially equivalent level of protection for personal data. For example, the UK’s International Data Transfer Agreement / Addendum, and the EU’s Standard Contract Clauses.
We ensure your personal data is protected by requiring all our third parties to follow the same rules when processing your personal data.
10. Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal information (the right of access) |
| Rectification | The right to require us to correct any mistakes in your personal information |
| To be forgotten | The right to require us to delete your personal information in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal information in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations |
| To object | The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please complete a data subject request form as detailed in Annex 1 below and email it to us; or email, call or write to our Data Protection Officer (see below: ‘How to contact us’) and let us have enough information to identify you (eg your full name and address), let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and let us know what right you want to exercise and the information to which your request relates.
11. Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
12. How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
13. Changes to this privacy policy
This privacy notice was published on 3rd July 2020 and last updated on 7th March 2023. We may change this privacy notice from time to time. When we do we will inform you either via email or in your Katapult Console or by updating the policy on our website.
14. How to contact us
Please contact us or our Data Protection Officer by email, by telephone or by post, if you have any questions about this privacy policy or the information we hold about you. Please note that it is likely that you will have a faster response if you contact us by email or by telephone.
Our contact details are shown below:
Name: David Kimberley (Data Protection Officer)
Email: Dave@katapult.io
Telephone number: 0208 050 1337
Postal address: Krystal Hosting Ltd, 124 City Road, London, EC1V 2NX
Annex 1
Please see suggested Data Subject Access Request Form on the Information Commissioner’s Office website here: https://ico.org.uk/your-data-matters/your-right-to-get-copies-of-your-data/preparing-and-submitting-yo ur-subject-access-request/