Privacy Policy

Kaizen Policies logo

Effective Date: January 1, 2020.

Kaizen Compliance Solutions Limited (herein after referred to as, “Kaizen”, “us” “our” or “we”) understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with Kaizen’s business activities, like conferences and events, and client services, and on websites, applications, and communications that post a link to this Privacy Policy (collectively, “the Kaizen website”), in our capacity as data controllers.

Please see our Terms of Use for more information about our online terms and policies in general.

Information we collect

Kaizen collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of our website when you create a user profile i.e. the contact us page, (or) register for Kaizen newsletters and alerts; where available, (or) sign up for conferences and events, and; when and where available, participate in our discussion forums and surveys. The personal data collected varies and may include information that you provide, such as your name, job title, mailing address, e-mail address, telephone number, mobile number or fax number.

We may also automatically collect information about the devices you use to interact with our Kaizen website. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our website. We may also automatically collect information about how you use the Kaizen website, such as what you have searched for and viewed on our website. The information automatically collected may be associated with a unique identifier as well as with any other personal data you may have provided.

Kaizen may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities. We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Kaizen, in compliance with applicable law.

Use of information

Kaizen uses your personal data to fulfil your requests for information, process your requests to participate in our conferences and events; wherever and whenever applicable, personalize content that you may view or receive on the Kaizen website, evaluate and improve our services, distribute newsletters and alerts to you that we may create and send from time to time, recruit and evaluate job applicants; whenever we post jobs from our websites or through other channels, analyse the website’s performance and functioning, publish your essays, articles, reviews or comments, or enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Kaizen’s agreements, and accomplish other purposes you may initiate or request.

 

In some situations, the collection of personal data may be required for the operation of the Kaizen website, or we may use it in the course of our business activities, including in connection with some client services, for example, to provide certain services or products such as our benchmarking or due diligence products. We may combine and/or analyse personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you.

 

Kaizen and its external service providers may use first and third party cookies and other tracking technologies, including web beacons, to manage our Kaizen website and our services and collect analytics about how you use them. Kaizen and its external service providers may also collect information about whether you open or click any links in the insight page, contact page or event communications that we send to you. The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to our Cookie Policy for more details regarding our use of Cookies and Other Tracking Technologies.

 

Note that the Kaizen website does not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.

Use of information collected via mobile devices

In certain instances where Kaizen provides a service or notification in connection with our mobile applications, we may use third party service providers to analyse user experience and activity in order to fix errors, monitor usage, and improve the performance of the mobile applications. Such instances/experience or activities could include but are not limited to Kaizen receiving reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, reports of certain errors occurring within mobile applications and other events occurring within our apps.

In addition, in certain instances where Kaizen provides a service of notification or personalized list of recommendations directing you to our website content that we think you will find interesting, we will not and do not share your viewing history or trends with other users or any external third parties; irrespective of whether or not they are affiliated with Kaizen Compliance Solution

Personal data collected in the course of Kaizen Compliance Solutions business activities, including in connection with some client services, as well as on our website may be transferred from time to time to our affiliates and their personnel/employees/staff, as well as to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Where required by law, and in instances where we hold and process your data, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that may be processed by Kaizen Compliance Solution; either directly or through its known affiliates and third party service providers, including the transfer of your personal data to countries other than the one in which you reside.

 

Our processing of your personal data for the purposes mentioned above is based:

 

· in part, on our legitimate interests in promoting and protecting Kaizen Compliance Solutions Limited, building and maintaining relationships with our existing and prospect clients, for recruitment purposes, survey analysis and continuous improvements to our products and services;

· in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our web-sites;

· in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.

Disclosure of personal data – covering data recipients and international data transfers

Kaizen Compliance Solutions will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. Kaizen Compliance Solutions may provide access to your personal data to third party service providers engaged by us to provide services related to the Kaizen website as well as related to Kaizen Compliance Solutions business activities, especially in the field of Data Cleansing, KYC/CDD Remediation or similar managed services. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

We also may share your personal data or that of your end clients i.e. in our Management Services Remediation offerings, with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing due diligence checks,  recruitment materials, administering surveys or contests, or communicating with you.

In addition, we may disclose information about you:

·        If we are required to do so by law or legal process;

·        To law enforcement authorities or other government officials;

·     When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;

·        If disclosure is necessary to protect the vital interests of a person;

·        To enforce our Terms of use;

·        To protect our property, services and legal rights;

·        To prevent fraud against Kaizen Compliance Solution, our affiliates and (or)our business partners;

·        To support auditing, compliance, and corporate governance functions; or

·        To comply with any and all applicable laws.

 

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

User Forums

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others.

Kaizen Compliance Solutions is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on our website.

Kaizen Compliance Solutions may provide links to third party websites or information as a service to our users. If you use these links, you will leave the website. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Kaizen of the third party, the third party website, or the information contained therein, and Kaizen shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those 3rd party website.

Social Networking

Whenever activated by Kaizen Compliance Solutions, our website may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Kaizen. The website; when activated to offer such facility, may allow you to log in to a Kaizen account using certain social network account credentials.

By associating your social network account with Kaizen or logging in to a Kaizen account using your social network account credentials, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location.

We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with Kaizen and other connected applications and to manage the data that is shared through your account, including information about your activities using our website.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.

Security

Kaizen Compliance Solutions has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Kaizen personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential in the strictest sense possible. Despite these precautions however, Kaizen Compliance Solutions cannot guarantee that unauthorized persons will not obtain access to your personal data.

Data Retention

Kaizen Compliance Solutions may retain personal data; where necessary and possible, for the duration of the relevant business relationship.

We may also retain personal data for longer than the duration of the business relationship; should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules.

If you request that we delete your personal data in line with GDPR provisions and the right to be forgotten principles, we will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Your Rights

Where granted by applicable law and in accordance with the provisions of the General Data Privacy Regulations (GDPR) provisions, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data. If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at info@kaizencs.co.uk

To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable laws i.e. the UK Data Protection Act and GDPR provisions.

Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.

In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority i.e. the ICO (Information Commissioners Office) in the United Kingdom.

Unsubscribe

If you have registered for Kaizen’s newsletter or alerts, or you receive invitations to surveys or events from Kaizen Compliance Solutions and you prefer not to receive future email communications from us, please review the communications settings in your profile on www.kaizencs.co.uk , follow the instructions on the insight page of our website where you have provided such information, subscribed or registered in order to unsubscribe from all Kaizen communications.

By using our Kaizen website, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on our website. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent in line with existing GDPR rules by either through an email to your registered email address or by prominently posting information about the changes on our website.

If you have any questions about our Privacy Policy, please contact us at our email of info@kaizencs.co.uk or our address at:

Kaizen Compliance Solutions Limited

Level 18, 40 Bank Street, Canary Wharf,

London, E14 7NR

Tom Brown
CEO (Chief Executive Officer)
Kaizen Compliance Solutions Limited
United Kingdom,
January 2020

Neil Marshall MICA
COO (Chief Operating Officer)
Kaizen Compliance Solutions Limited
United Kingdom,
January 2020