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{
"organisationInformation": {
"name": "Kelkoo",
"number": "10015850",
"registrationCountry": "gb",
"description": "Price comparison shopping and travel website"
},
"organisationUrls": [],
"privacyNoticeUrl": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy"
},
"dataProtectionOfficer": {
"present": "present",
"name": "xNo name listed, only referred to as \"him\".",
"role": "Data Protection Officer",
"contactInfo": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"emailAddress": "dpo@kelkoogroup.com"
}
},
"rights": {
"isMissing": false,
"general": {
"contactInfo": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"emailAddress": "dpo@kelkoogroup.com"
},
"observations": "Clear explanation to contact their DPO with questions about data processing."
},
"access": {
"contactInfo": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"emailAddress": "dpo@kelkoogroup.com"
},
"observations": "The right to access is clearly spelled out with it's own heading."
},
"rectification": {
"contactInfo": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"emailAddress": "dpo@kelkoogroup.com"
},
"observations": "The right to rectification is clearly spelled out with it's own heading."
},
"erasure": {
"contactInfo": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"emailAddress": "dpo@kelkoogroup.com"
},
"observations": "The right to delete personal information is clearly spelled out with it's own heading."
},
"restrictProcessing": {
"contactInfo": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"emailAddress": "dpo@kelkoogroup.com"
},
"observations": "The right to restrict processing is clearly spelled out with it's own heading."
},
"dataPortability": {
"contactInfo": {
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"emailAddress": "dpo@kelkoogroup.com"
},
"observations": "The right to data portability is clearly spelled out with it's own heading."
},
"object": {
"contactInfo": {}
},
"automatedDecisionMaking": {
"contactInfo": {}
}
},
"dataCategoriesCollected": {
"isMissing": false,
"list": [
"date_of_birth",
"email_address",
"gender",
"location",
"names",
"telephone_number"
],
"observations": "They may collect personal financial information but are not specific (no mention of bank account details for example). They also list IP address specifically.\n\nThey define personal information as any information from which you \"can be identified directly or indirectly\". Perhaps a bit unclear what they mean by \"indirectly.\"",
"sourceText": "“Personal Information” means any information about you which is personally identifiable which may include (but might not be limited to) your name, age, gender, location, telephone number, email address, IP address, financial details and any other information from which you can be identified directly or indirectly and which you may disclose to us or otherwise provide to us via the Website or elsewhere at any time.\n"
},
"unusualProcessingPurposes": {
"isMissing": false,
"present": "not_present"
},
"thirdParties": {
"isMissing": false,
"list": [],
"specificity": "general",
"observations": "They mention no third parties by name.",
"sourceText": "HOW DO WE USE YOUR PERSONAL INFORMATION?\n\nWe may use your Personal Information in the following ways:\n\n• for fraud prevention and security on our Website and systems;\n\n• to help us understand what products you have viewed or purchased through the Website in order to provide a better and more personalised service to you, including advising you on and offering to you products, services, content and special offers;\n\n• to analyse the use of the Website and of the websites of our merchants and business partners, including user demographics, interest and behaviour to optimise the services we offer;\n\n• to allow you to participate in certain services we offer such as the Kelkoo Newsletter, the User Reviews or any competition, promotion, prize draw or survey launched on the Website or to inform you of changes to any of these services;\n\n• to investigate any suspected breach of the Terms of Use by you or relating to you;\n\n• to process registration of your account information and maintain the user account you may have with us;\n\n• to ensure that your purchase has been duly completed on the merchant’s or business partner’s website.\n\nDO WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?\n\nWe may pass on your Personal Information to other parties as follows:\n\n• to selected and trusted third parties who may use your Personal Information to provide you content (including advertising content) that may be of interest to you;\n\n• to business partners to assist us in providing services on our Website and any related services to you. Such business partners are required to maintain the confidentiality of your Personal Information and, unless you are otherwise advised, do not have any rights to use the Personal Information about you that we provide to them for any purpose beyond what is necessary to assist us;\n\n• some aggregated information about the Website users, sales patterns, traffic volumes and related matters to reputable third parties but these details will not include any of your Personal Information;\n\n• to regulatory bodies or legal advisers in connection with any alleged criminal offence or suspected breach of the Terms of Use or when required by law;\n\n• to any member of the Kelkoo group; and\n\n• in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets on a confidential basis."
},
"retentionRules": {
"isMissing": false,
"summary": "They keep your information as long as necessary for the purposes listed in \"How do we use your personal information\".",
"specificityCategory": "general",
"specificityTime": "general",
"sourceText": "We only hold Personal Information for as long as is necessary for the purposes described above in the paragraph headed “HOW DO WE USE YOUR PERSONAL INFORMATION?”"
},
"lawfulBases": {
"isMissing": false,
"consent": "- When you view or buy a product/service from a seller on Kelkoo\n- When you make a complaint or enquiry\n- When you give information to register for an account or give your contact details for an offer or prize",
"observations": "It is generally unclear under which lawful basis Kelkoo uses data."
},
"securityStandards": {
"present": "present",
"url": "http://www.kelkoo.co.uk/company-pages/privacy-policy",
"observations": "Nothing too specific (no mention of encryption or other security measures) beyond mention of \"industry standard practices\" and storing info on secure servers.",
"specificity": "general"
},
"dataProcessingAddendum": {
"present": "not_present",
"observations": "Personal information will not be transferred outside of the European Union."
},
"privacyShield": {},
"dataProtectionRegister": {},
"automatedDecisionMaking": {
"usesAutomatedDecisionMaking": "unknown"
},
"complaintInformation": {
"present": "not_present",
"observations": "They list their data processing authority but not specifically as a resource for complaints.",
"specificity": "general",
"sourceText": "Only address no email or phone number listed.\n\nCommission Nationale Informatique et Libertés\n3 Place de Fontenoy - TSA 80715 - 75334 Paris CEDEX 07\n\n"
},
"presentation": {
"plainLanguage": "pass",
"easyToFind": "pass",
"easyToFindInside": "pass"
}
}