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Privacy Policy (EMEA)

Kingston is a global organization comprising a group of entities affiliated with, controlled by or under common control with Kingston Technology Company, Inc. Accordingly references in this Privacy Policy and elsewhere on this website to ‘Kingston’, ‘our’, ‘we’ or ‘us’ mean Kingston Technology Company, Inc. and entities affiliated with, controlled by or under common control with it, as the context so requires. This Privacy Policy applies to all information, including personal information, collected about you by Kingston.

Any personal information collected by Kingston within the European Economic Area, Switzerland or United Kingdom is controlled by Kingston Technology Europe Co LLP and/or Kingston Digital Europe Co LLP, both are located at Kingston Court, Brooklands Close, Sunbury on Thames, Middlesex, TW16 7EP, UK.

Pursuant to Article 27 of the EU General Data Protection Regulation, Kingston Technology International Ltd has been appointed as Kingston’s representative in the European Union for data protection matters (see contact details below).

‘Personal information’ means any information that relates to an identified or identifiable individual.

At Kingston we know that protecting your privacy is important, which is why we have written this Privacy Policy to explain:

  • When we collect information
  • What type of information we collect, how and why
  • How we use information
  • How long do we keep your data
  • With whom we share information
  • The steps we take to protect your information.

When Do We Collect Information?

Kingston may collect information about you when you interact with us such as (but not limited to):

  • Accessing or browsing any website, web property, or web-based function directly created by or controlled by Kingston, or any of our social media accounts
  • Ordering Kingston products or services, engaging with customer care or product support
  • Communicating with us via e-mail, telephone, fax or other manner
  • Registering your Kingston product or filling out a survey
  • Participating in a Kingston promotion, including but not limited to rebates, contests, etc.
  • Requesting or registering to receive information about our products or services, whether with Kingston or an agent of Kingston
  • Meeting face to face or handing over your business card at a trade show, exhibition, corporate event, meeting, conference, PR event, training or technology seminar or any other event

Your Right To Object

You may, at any time, tell us to stop using personal information about you that we hold (including personal information that we’ve passed to anyone else) for direct marketing purposes. Upon receiving your objection we shall stop making any such use of your personal information.

If you object to the processing of your personal information which is based on our legitimate interests or those of a third party, you may contact us stating the grounds for your objection.

You can contact us by the following means:

Email: [email protected]

Phone: +44 (0) 1932 738888

What Information Do We Collect, How and Why?

General

Except for the circumstances which we explain later in the following paragraphs, we do not collect personal information, except when you specifically and knowingly disclose such information. This information is generally collected when you order our products or services, register your products on the website, provide information on a website, web property or web-based function directly created by or controlled by Kingston, or through any Kingston presence on a social media platform, fill in surveys, take part in promotional events (including competitions), correspond with us, discuss a service issue on the phone with an associate, sign up to receive Kingston product and service updates whether with Kingston or an agent of Kingston, or when we meet with you at meetings or events. If you disclose your personal information, we will only store and use such information that we need to meet your requests and our legitimate interests and business objectives, including, where you have consented, providing you with information about products and services that we consider may be of interest to you. We primarily use your personal information to perform our contractual obligations to you and fulfil our legal obligations, to run our business efficiently and to provide you with an improved and customised online experience and service.

If you have already consented to receiving information about our products and/or services and have viewed the website after following a link in an email that you have received from us, then we may use a targeting cookie to help us better understand which of our products and/or services interest you. This targeting cookie only collects data about which products and/or services you have shown a particular interest in. That data concerning your interest in our products and/or services is sent to a third party who notes it against the existing record of your consent to receive marketing communications from us.

Product Purchases

When purchasing through the website, we employ a registration process which requires that you provide us with your first and last name, billing and shipping information (which includes your home or other physical address, the name of your city or town, your telephone number, your e-mail address or other personal information). We use this information to perform our contract to supply you with our products. If you choose not to provide your personal information at the point of collection, you will not be able to purchase products through the website.

Product Registration

When you register, we may ask for your name, address, e-mail address, telephone number, type of product, serial number and date of purchase or other product-identifying information. We use this information to fulfil our contractual and legal obligations including providing you with support and information and our legitimate interests of managing our relationship with you. If you choose not to provide this information, you will not be able to register products on the website; however, you may continue to use the products.

Personal Contact Information

We use your contact information to complete and support your purchases from us, to facilitate and improve your use of the website, to communicate with you (including, if you have consented, sending marketing communications) and to comply with any requirements of law. We also use this information to respond to any questions you might have and, if you have consented, to provide you with information about special deals offered through the website. Your personal contact information may be disclosed to our staff and to third parties involved in the completion of your transaction, the delivery of your order or the support of your use of the website.

Credit Card Information

When you order any product through our website or at a Tradeshow or request an RMA (Returned Merchandise Authorization) on our website, you may be redirected to a third-party payment gateway service to provide your credit card information including the credit card number, card security code (also called CVV2, CVC2, CID code), the expiration date and the billing address. This information is used to perform our contract to supply you with our products or services and for our legitimate interest of collecting payments which may be due to us. The third-party payment gateway service is fully compliant with Payment Card Industry Data Security Standard (PCI DSS) for payment processing.

Online Surveys

In order to improve our products and services, we may use your personal information (including your identity, contact details, and usage data) to send you online surveys. These surveys help our legitimate interest of learning more about your experience with our products and services. Your responses to these surveys are treated as confidential information. If you do not wish to participate in a survey, you may simply decline when asked.

Product Updates and Promotional E-mails

We regularly send product updates and promotional e-mails as a service to our existing customers, and to individuals who have registered or consented to receive such updates and emails. We will use your personal information (including your identity and contact details) to send you newsletters and e-mails periodically listing current specials, promotions and deals only if you elect to receive these e-mails. If you have elected to receive these e-mails and wish to discontinue receiving them in the future, please follow the opt-out instructions provided on the e-mails or log into your account on the website and follow the instructions to make the appropriate changes.

Correspondence

If you contact us with feedback, comments, questions or for any other reason, we may keep records of that correspondence and collect your personal information for the legitimate purpose of processing your inquiries, responding to your requests and improving our services.

Visits to our website

We automatically collect certain information each time you visit the website. We may use cookies, tags, server logs and other technology to acquire or store this information. We collect this information so that we may better understand how people are using the website and to improve the overall quality of our users’ online experience.

Data collected when you visit our website such as statistical or demographic data (Aggregated Data) could be derived from your personal data but is not considered personal data in law as this data will 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

Cookies

Cookies are text files containing small amounts of information which are downloaded to your device when you visit our website. For information on the cookies we use and the purposes for which we use them, please read our Cookie Policy.

Log Files

Log files record a range of variables related to a visitor’s time on the website. This includes, but is not limited to: IP addresses, browser versions and types, internet service providers, pages visited, entry/exit pages, referring sites, platform types, demographic information, connection speed, etc. We use this information to understand how our visitors are using the website and to discover how we might modify the site to better serve our customers. This information is gathered automatically when you visit the website.

Navigational Data

As you browse the website and third party sites, we may gather technical, usage and navigational data that shows what pages are visited and how long various features are used. We use this information to facilitate and improve the website; to comply with any requirements of law; to serve, or have a third party serve specialized or relevant advertising content and/or recommendations to you on the website and third party sites; and for our internal purposes. We may from time to time supply the owners or operators of third party sites with information relating to the number of users linking to the website from their sites.

IP Addresses and System Specifications

When you access the website, our servers may record your IP address. We may use IP addresses for system administration and troubleshooting, ensuring user compliance with our terms of service, investigating security breaches and compiling anonymous non-personal information such as how many users visited the website.

How Long Do We Keep Your Data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorised use or disclosure, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your personal information. See the section headed “Your Rights” below for further information.

How Do We Share The Information That We Collect?

General

Personal information which we collect for a particular purpose will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Privacy Policy. We sometimes share anonymous non-personal information with third parties about our user base. Except as set forth in this Privacy Policy, we do not trade, share, rent, sell or give away information concerning you to third parties.

Our Affiliates

Subject to applicable data protection law, we may share your personal information with legal entities that are directly or indirectly controlled by us or who share common control with us. These affiliates may use your personal information only in accordance with this Privacy Policy and for the purposes and reasons it sets out.

Our Service Providers and Strategic Partners

We may disclose your personal information to certain businesses that provide services to Kingston. For instance (without limitation), we will disclose your credit card information to our financial service providers and banks for processing, data collected about our products and/or services which interest you will be used by the company which administers our customer mailing list, and your name and address will be disclosed to the delivery service that we use to deliver products you purchase on the website. These third-party service providers and partners will have access to the personal information needed to perform their functions but may not use it for other purposes.

We may also disclose your personal information to other businesses so that they can provide you with information about products and services that may be of interest to you but only if you have consented to this by ticking the relevant box situated on the form on which we collect your information.

Enforcement

We may disclose your personal information or otherwise use such information to the extent that such disclosure or use may be required and to the extent necessary to meet Kingston’s legal obligations and the protection of Kingston’s legitimate legal and business interests, and its rights, property and employees.

We may also disclose any of your personal information in response to valid requests by public authorities, including to meet national security or law enforcement enquiries, or to other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as are reasonably necessary.

Aggregated General Information

We may share aggregated general information about the website with our corporate partners, investors, advertisers or others. Aggregate general information includes without limitation the number of users of the website, revenue including payments by the users, usage statistics and user feedback. Aggregated general information does not include any personal information that could be used to contact or identify you.

Change of Control

In the event that another company acquires a controlling interest in Kingston or if we experience some other change of control event such as merger, insolvency, bankruptcy or receivership, we reserve the right to include any or all user-related information (including personal information) among the assets transferred to the acquiring company. Any new owners of our business may use your personal information in the same way as set out in this Privacy Policy, and shall be required to respect the security of your personal information and treat it in accordance with the law and for the purposes specified in this Privacy Policy.

Children's Privacy

The website complies with the US Children’s Online Privacy Protection Act and all other applicable laws and regulations protecting children’s privacy on the Internet. We do not allow persons under 18 years of age to create user accounts.

Therefore, except as may be required by law, the website does not knowingly collect, maintain or disclose any personal information from children under the age of 18. If you are under the age of 18, please do not: (i) create or attempt to create an account on the website, (ii) sign up for any subscription service, or (iii) buy anything through the website.

Information For Parents/Guardians

As a parent or guardian, you can ask Kingston to remove personal information pertaining to your child that was submitted without your consent or by misrepresenting his or her age. At your request, we will remove such information from our database.

All such requests should include the same user name, password and e-mail address that your child submitted and should be sent to:

Email: [email protected]

Phone: +44 (0) 1932 738888

Where We Store Your Personal Information

The information that we collect from you may be transferred to, stored in, processed in or accessed from countries outside of the European Economic Area (EEA), Switzerland and/or the United Kingdom (UK). Whenever we transfer your personal information out of the EEA, Switzerland and/or the UK, 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 information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, the Swiss Federal Data Protection and Information Commissioner, or the UK’s Information Commissioner’s Office; or

Where we use certain service providers, we may use specific contracts approved by the European Commission, the Swiss Federal Data Protection and Information Commissioner, or the UK’s Information Commissioner’s Office which help to ensure that personal data continues to benefit from a high level of protection when transferred outside the EEA, Switzerland or the UK.

EU-U.S. & Swiss-U.S. Data Privacy Framework and UK Extension to the EU-U.S. Data Privacy Framework

Kingston and certain of its subsidiaries and affiliated entities listed here comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Kingston has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Economic Area in reliance on the EU-U.S. DPF and from the United Kingdom in reliance on the UK Extension to the EU-U.S. DPF. Kingston has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In cases of onward transfer to third parties, Kingston will only transfer personal data for limited and specified purposes. Kingston complies with the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF for all onward transfers of personal data from the EEA, the United Kingdom, and Switzerland, including the onward transfer liability provisions.

Kingston, subject to the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, holds and processes all Personal Data previously received from the EEA, UK and Switzerland in reliance on our EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF certifications and on the DPF Principles. In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Kingston commits to resolve DPF Principles-related complaints about our collection and use of your personal information. We respectfully request that any EEA, UK, or Swiss data subject that is located in the EEA, the UK, or Switzerland, respectively, and wishes to submit inquiries or file complaints first contact us by email at [email protected], or by postal mail at the following address:

Kingston Technology Europe Co LLP
Attention: Privacy Compliance
Kingston Court
Brooklands Close
Sunbury-on-Thames
Middlesex
TW16 7EP
UK

Any questions or concerns regarding the use or disclosure of personal information should be directed to Kingston at the address given above. Kingston will investigate and respond or attempt to resolve complaints and disputes regarding the use and disclosure of personal information in accordance with the principles contained in this Privacy Policy within a reasonable amount of time, not to exceed 30 days following the receipt of your question or complaint. In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Kingston commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK’s Information Commissioner’s Office (“ICO”), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Individuals covered by the DPF program may seek binding arbitration for limited types of claims. For additional information about the DPF arbitration process, please visit the DPF website. To learn more about how you may pursue binding arbitration through the DPF Arbitration Panel, please visit https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf.

Kingston is subject to the investigatory and enforcement powers of the Federal Trade Commission with regard to Kingston’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain circumstances, Kingston may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security

Kingston takes appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, users’ information. We restrict access to your personal information to employees who need to know that information in order to operate, develop or improve our products, services and the website. Our servers are protected by firewalls and are physically located in secure data facilities to further increase security.

We use Secure Socket Layer (SSL) technology for mutual authentication, data encryption and data integrity. While no computer is 100% safe from outside attacks, we believe that the steps we have taken to protect your personal information drastically reduce the likelihood of security problems to a level appropriate to the type of information involved.

Integrity

During the online account registration process, you can review, change or remove any information you have submitted. Our goal is to ensure that our information about you is as accurate as possible and encourage you to promptly update your information if it changes. You may, at any time, access your information to update, modify or delete any inaccuracies by accessing your account through the website.

Your Rights

As well as your Right to Object which is set out near the top of this Privacy Policy, you also have the following rights in relation to your personal information:

Right To Access And Right To Rectification

You have the right to know whether your personal information is being processed by us, the categories of personal information we hold on you, the purposes for which we intend to process your personal information, how long we intend to retain your personal information and who has received your personal information from us (which we may identify as actual recipients or as categories of recipients).

If the personal information we hold on you is inaccurate or incomplete, you can amend or delete any inaccuracies by accessing your account through the website, or you can email or phone us to ask that we correct it.

Right To Erasure

You can ask, by email or phone, for the personal information we hold on you (including personal information that we’ve passed to anyone else) to be erased if:

  • We no longer require the personal information to do what we collected it for; or
  • You have withdrawn your consent for us to use the personal information; or
  • We no longer have a legitimate interest in holding or processing your personal information
  • We have processed your personal information unlawfully; or
  • You object to its use for direct marketing purposes and we have no other reason for processing your personal information; or
  • The personal information we hold was submitted by a person who was under 13 at the time.

Upon receiving a request from you to erase your personal information for any of the above reasons, we will endeavour to remove as much information as legally allowable. However, as we generally keep information related to past transactions for the legitimate interest of keeping business records and to fulfil our legal obligations, we may not be able to completely remove all of your information. If we are unable to comply with your request to erase personal information we shall tell you in writing what data we have retained, the reasons for retaining it and how long we expect to retain it for.

Right To Restrict Processing

You can ask us, by email or phone, not to process your personal information or to restrict the way it is processed (including personal information that we’ve passed to anyone else) if:

You do not want us to process your personal information whilst we are checking its accuracy; or

We have processed your personal information without having a lawful basis to do so but you do not want us to erase your personal information; or

You have objected to us processing your personal information for purposes other than direct marketing and we are considering whether we have a lawful basis for continuing to process your personal information; or

We no longer need your personal information but you need us to keep it in order to establish, exercise or defend a legal claim.

Right To Data Portability

You have the right to receive personal information concerning you, which you have provided, and have the right to transmit that data to another controller. You have the right to have such personal information transmitted directly from us to another data controller where technically feasible. We shall supply the personal information in a structured, commonly used and machine-readable format. You may contact us about any of your rights by the following means:

Email: [email protected]

Phone: +44 (0) 1932 738888

If you believe that we have failed to process your personal information in accordance with your legal rights, and after informing us we have failed to address your concerns, then you may lodge a complaint with the relevant supervisory authority of the country where you live, where you work or where the alleged infringement of your rights occurred. You also have the right to take legal action against us or anyone that we have passed your personal information to if you believe that we (or the party that we have passed your personal information to) have failed to process your personal information according to your legal rights. Such legal action may be taken either in the courts of the country where you live, or where we (or the party that we have passed your personal information to) are established.

Our site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

EU Representative

Kingston Technology International Ltd (KTIL) can be contacted in addition to [email protected], only on matters related to the processing of personal data. KTIL can be contacted at:

Kingston Technology International Ltd
Stratus House,
Unit 1, IDA College Park,
Blanchardstown Road North,
Dublin 15, D15 PEC4,
Ireland

Email: [email protected]

Changes To Privacy Policy

We may update our Privacy Policy from time to time by posting a new version of it on the website. We encourage you to check the website regularly for information about revisions to this Privacy Policy. If you object to the change to our Privacy Policy, then you must contact us by any of the methods set out above regarding your objection.

This policy was last updated on 30th August 2023