Privacy Policy for our Social Media Profiles
Version 2.1 updated December 12, 2023.
In addition to our website, we maintain publicly accessible profiles on social media platforms such as Facebook. In the following segment we would like to inform you about handling of your personal data when you visit our profiles.
Who is the data controller?
A data controller is an organisation that collects and uses personal data and decides how that personal data is used and managed.
If you visit one of our social media profile pages (e.g. Facebook), we
Kontri Ltd.
49 Hevea Road
Burton-on-Trent DE13 0SH
United Kingdom
Email: privacy@kontri.co.uk
(+44) 20 3129 1615
are responsible for data processing within the meaning of the General Data Protection Regulation ( GDPR), insofar as we process the data transmitted to us by you via social media sites exclusively ourselves.
In addition, the respective operators of the social media platforms are also responsible for data processing. For certain types of processing, we and the platform operator also act as joint controllers, within the meaning of Art. 26 GDPR. Please see below, in the section related to particular social media platform for more information.
In most instances, we have no influence on data processing performed by the operator of the social media platform and we do not know exactly what data they process. The platform operator is responsible for the entire IT infrastructure of the service, maintains its own data protection regulations and has its own user relationship with you.
We are registered with the Information Commissioner's Office (ICO): registration number ZA903038
Our EU representative pursuant to art. 27 GDPR is:
Kontri Sp. z o.o. address: Jacka Kuronia 3, 15-569 Bialystok, Poland, email: rodo@kontri.pl
Data processing through social media platforms
When you visit our social media profile page, certain information about you is processed. If you have your own user account in the social media platform and are logged in to this account, all data related to your visit will be assigned directly to your existing account.
Social media platforms can generally analyse your user behaviour comprehensively, when you visit social media profiles or websites with integrated social media plugins (e.g. “like” buttons or advertising banners). They store data collected about you as user profiles and can use them for advertising and market research purposes.
Under certain circumstances, your personal data can also be recorded if you are not logged into your social media account or do not have one at all. In this case, data is collected mainly via cookies that are stored on your end device or by recording your IP address.
When you visit our social media profile page, we process your actions and interactions with our social media profile page (e.g. the content of your messages, inquiries, posts or comments that you send to us or if you like or share our posts), as well as, your publicly visible profile data (e.g. name of your social profile and your profile picture). Which personal data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in your settings on the social media platform.
The purpose of data processing by us on our social media profile pages is to inform customers about our offers, products, campaigns, promotions, company news and to interact with visitors to those social media profiles, as well as to answer corresponding questions, praise or criticism. The legal basis for processing by us is to fulfil our legitimate interests.
If your contact with us is aimed at the conclusion of a contract (for example, placing an order in our online store) or relates to an existing contract with us, then processing of your personal data is to perform our contract with you or for any pre-contractual obligations.
From time to time we also offer participation in promotions such us contests, completions etc. on our social media profile pages. Unless specified otherwise in the data protection section of respective promotion or you have not given us further express consent, personal data you provide us in the course of participating in our promotion will only be used to administer the promotion (e.g. determine the winner, winner notification, sending the prize). If your social media account is under a real name or you are recognizable on photos in your profile, identification by other users of the social media platform cannot be ruled out.
We process your data related to your participation in our promotions as part of our contract obligation with you. We will only share your data with relevant third parties to assist in management and fulfilment of our promotions. If you have given your consent in the course of our promotion, you have the right to withdraw your consent at any time with future effect. The data categories related to administering of a promotion are as follows: social profile name (if your social media account is under a real name than your name and last name), contents of your entry. For winners: first and last name, email address, delivery address, phone number.
Data processing by social media platforms may be based on different legal bases that have to be specified by the operators of the social media platforms.
Social media platforms in detail
We have profiles on:
1) Facebook
Insofar as the data you transmit to us via Facebook is also or exclusively processed by Meta as the operator of Facebook (Page Insights), Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland, is also responsible for data processing within the meaning of the General Data Protection Regulation (GDPR). In this respect, data processing is carried out on the basis of an agreement between jointly responsible parties in accordance with Art. 26 GDPR, which you can view here: https://www.facebook.com/legal/terms/page_controller_addendum
Furthermore, for the use of certain Facebook products, such as the so-called "Facebook Business Tools", and for data processing carried out in this way, an additional agreement between us and Meta Platforms Ireland Ltd. as joint controllers pursuant to Art. 26 GDPR applies, which can be viewed here: https://www.facebook.com/legal/terms/page_controller_addendum
For more details, see Facebook's privacy policy: https://www.facebook.com/about/privacy/
You can contact Facebook's data protection officer using the online contact form provided by Facebook at https://www.facebook.com/help/contact/540977946302970.
- Data processing for statistical and marketing purposes
Page Insights
Facebook provides us with a tool called Page Insights https://www.facebook.com/business/a/page/page-insights . This is summarized data, through which we can obtain information about how people interact with our site. Page Insights can be based on personal data that is collected in connection with a visit or an interaction on or with our site and its content. These statistics are generated and provided by Facebook. We have no influence on its generation and display. We cannot turn off this function and cannot prevent generation and processing of this data.
The data that Facebook makes available to us helps us, among other things: to get in touch with our followers and interested parties, to understand the use and scope of our posts, to evaluate content and to identify user preferences. This data processing takes place on the basis of our legitimate interests.
You can object to the processing of your data for the aforementioned purposes at any time by changing your settings for advertisements in your Facebook user account at https://www.facebook.com/settings?tab=ads .
According to “Page Insights Controller Addendum” to the existing contractual agreement with Facebook, Meta Platforms Ireland Ltd assumes the responsibility for compliance with the applicable obligations under the GDPR for the processing of Page Insights (including, but not limited to, Articles 12 and 13 GDPR, Articles 15 to 21 GDPR, Articles 33 and 34 GDPR). Page Insights Controller Addendum can be viewed at https://www.facebook.com/legal/terms/page_controller_addendum.
Facebook Lead Ads
We use the "Lead Ads" function of Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook") to collect and process certain personal data of interested parties - so-called leads - via a contact form displayed on Facebook websites (so-called "instant form"). The content and scope of the data requested in this form depends on the focus of the respective lead campaign.
The processing of the data is strictly bound to the purposes pursued with the respective lead ad campaign. These purposes are clearly stated in the lead ad or on the form provided before the specified data is transmitted. Depending on the focus of the lead ad campaign, the legal basis for data processing is either your express consent in accordance with Art. 6 para. 1 lit. a GDPR (e.g. for direct advertising measures such as registration for e-mail newsletter dispatch) or our legitimate interest in optimising the marketing of our offer in accordance with Art. 6 para. 1 lit. f GDPR. The data will not be passed on to third parties.
As part of the aforementioned services, data transmitted via instant forms may be stored on servers of Meta Platforms, Inc, 1601 Willow Rd, Menlo Park, CA 94025, USA.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Further information on data processing via Facebook Lead Ads can be found in Facebook's data policy at https://www.facebook.com/privacy/policy/
2) Instagram
Insofar as the data you provide to us via Instagram is also or exclusively processed by Instagram, Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland, is also responsible for data processing within the meaning of the General Data Protection Regulation (GDPR).
For more details, see Instagram’s privacy policy: https://help.instagram.com/519522125107875
You can contact Meta’s data protection officer using the online contact form provided by Facebook at https://www.facebook.com/help/contact/540977946302970.
3) Pinterest
Insofar as the data you transmit to us via Pinterest is also or exclusively processed by Pinterest, are Pinterest Europe Ltd. Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland and Pinterest, Inc. 651 Brannan St., San Francisco, CA 94107, USA, also collectively responsible for data processing within the meaning of the General Data Protection Regulation (GDPR), in their capacity as Joint Controllers.
For more details, see Pinterest’s privacy policy: https://policy.pinterest.com/en-gb/privacy-policy
You can contact Pinterest’s data protection officer using the online contact form provided at https://help.pinterest.com/en/data-protection-officer-contact-form
4) X (fromerly Twitter)
Insofar as the data you transmit to us via X is also or exclusively processed by Twitter, Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, is also responsible for data processing within the meaning of the General Data Protection Regulation (GDPR), provided that you are resident of the European Union, of EFTA States, or the UK. If you live in any other country the data controller is X Corp.,1355 Market Street, Suite 900, San Francisco, CA 94103 USA.
For more details, see X privacy policy: https://twitter.com/en/privacy
You can contact Twitter’s data protection officer using the online contact form provided at https://twitter.ethicspointvp.com/custom/twitter/forms/data/form_data.asp
5) TikTok
Insofar as the data you transmit to us via TikTok is also or exclusively processed by TikTok, are TikTok Information Technologies UK Limited, 6th Floor, One London Wall, London, EC2Y 5EB, United Kingdom; and TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland, also collectively responsible for data processing within the meaning of the General Data Protection Regulation (GDPR), in their capacity as Joint Controllers.
For more details, see Tiktok’s privacy policy: https://www.tiktok.com/legal/privacy-policy
When using TikTok, personal data may also be transferred to servers outside the European Economic Area. In this case, personal data is processed on the basis of the Commission's model contracts for the transfer of personal data to third countries (so-called standard contractual clauses). For a copy of these standard contractual clauses, please contact TikTok at privacy@tiktok.com.
You can contact the TikTok data protection officer using the online contact form provided at https://www.tiktok.com/legal/report/privacy?lang=en
6) Tumblr
Insofar as the data you transmit to us via Tumblr is also or exclusively processed by Tumblr, Tumblr, Inc, 60 29th Street 343 San Francisco, CA 94110, USA, is also responsible for data processing within the meaning of the General Data Protection Regulation (GDPR).
For more details, see Tumblr's privacy policy: https://www.tumblr.com/privacy
You can contact the TikTok regarding your privacy at https://www.tumblr.com/support
7) LinkedIn
Insofar as the data you transmit to us via LinkedIn is also or exclusively processed by LinkedIn, LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland, is also responsible for data processing within the meaning of the General Data Protection Regulation (GDPR), provided that you are resident in a country of the European Union, Iceland, Liechtenstein, Norway or Switzerland. If you are based in another country, LinkedIn Corporation, 1000 W Maude Ave, Sunnyvale, CA USA, is also responsible for data processing within the meaning of the GDPR in addition to us.
You can find more information in LinkedIn's privacy policy https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv
- Data processing for statistical and marketing purposes
Page Insights
Linkedin provides us with a tool called Page Insights https://www.linkedin.com/help/linkedin/answer/a547077?lipi=urn%3Ali%3Apage%3Aorganization_admin_admin_feed_index%3B231ca1f0-97f8-40e6-ab1d-f3bc2707c0f9 .
When a member visits, follows or engages with our company page on LinkedIn, LinkedIn processes personal data. In particular, LinkedIn will process data that was provided by the member to LinkedIn, such as job function, country, industry, seniority, company size, and employment status data from the member’s profile. Additionally, LinkedIn will process information on how a member has interacted with our Company page, e.g., whether a Member is a follower. Page Insights provided to us consist of aggregated data and are generated and provided by LinkedIn. We have no influence on its generation and display. We cannot turn off this function and cannot prevent generation and processing of this data.
The data that LinkedIn makes available to us helps us, among other things to: understand who’s following our page and how to best engage with them, evaluate the quality and topics of content shared with our page followers and visitors. This data processing takes place on the basis of our legitimate interests.
According to “Page Insights Joint Controller Addendum” to the existing contractual agreement with LinkedIn, LinkedIn Ireland Unlimited Company assumes the responsibility for compliance with the applicable obligations under the GDPR for the processing of Page Insights data (including, but not limited to, Articles 12-22 and Articles 32-34 of the GDPR). Page Insights Joint Controller Addendum can be viewed at https://legal.linkedin.com/pages-joint-controller-addendum
This addendum applies if personal data of members in the European Economic Area or Switzerland is affected.
8) Snapchat
Insofar as the data you transmit to us via Snapchat is also or exclusively processed by Snapchat, Snap Inc. 3000 31st Street, Santa Monica, CA 90405, USA is also responsible for data processing within the meaning of the General Data Protection Regulation (GDPR).
For more details, see privacy policy of Snap Group Limited here https://snap.com/privacy/privacy-policy
Your rights
You can exercise your rights in principle both with us, as well as, with the operator of the respective social media platform (e.g. Facebook).
If you would like to exercise your data subject rights with regard to a particular data processing over which we have an influence, please contact us. We then check your request (e.g. request for information or objection) ourselves or forward it to the responsible social media platform if required, provided that your request involves data processing by the operator of the social media platform.
You have the following rights towards us with regard to your personal data:
• Right to be informed about collection and use of your personal data.
• Right to access personal data we hold about you. This is known as a Subject Access Request.
• Right to correct your personal data when incorrect or incomplete.
• Right to withdraw your consent at any time.
• Right, under certain circumstances, to object to processing of your personal data (for example when we are processing your data for the purpose of our legitimate interest).
• Right, under certain circumstances, to restrict processing of your personal data (in this case we will not process your data for any other purpose than storage).
• Right under certain circumstances, to have your personal data erased, where we no longer have any legal reason to retain them.
• Right to request that we provide to you your personal data in a commonly used format, and if technically possible, that we transfer them to another data controller. This is applicable provided that your data is processed by automated means and that processing is based on your consent, on a contract which you are a part of or on pre-contractual obligations.
• You also have the right to make a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. In the UK this role is performed by the Information Commissioner Office https://ico.org.uk/
More about your right to object
You may object to processing of your personal data when:
• they are processed for the purpose of direct marketing, you can object at any time without providing any justification;
• they are processed under the following purposes: legitimate interest or statistical purpose; you must provide a specific reason and tell us why you are objecting to processing of your data (your grounds should be related to your particular situation).
Storage period
We will keep your personal information for the purposes set out in this privacy policy and in accordance with the law and relevant regulations. The length of time we need to keep the personal data will vary depending on the nature of the personal data and the reason we are need to hold it. If reasonably necessary or required to meet legal or regulatory requirements, prevent fraud, resolve disputes, we may keep hold of some of your information for longer than our general retention policy.
We have no influence on storage period of your data, which are saved by the operators of social media platforms for their own purposes. For details, please contact the operator of the social media platform directly.
All public posts by you on our social media profile pages remain in the timeline indefinitely, unless we delete them due to an update of the topic, a violation of the law or a violation of our guidelines, or you delete the post yourself.
Changes to this privacy policy
We reserve the right to update and change this Privacy Policy from time to time, to reflect any changes in legal requirements or the way we process your personal data. Please check back frequently to see any.