Privacy & Cookies Policy

Who we are

Kathie Kozlak LTD is the data controller responsible for your personal data. We are a company registered in England and Wales.

• Company number: 16947952
• Registered office: 35 Rutland Road, Bournemouth, England, BH9 1EQ
• Contact for privacy matters: contact@keffect.pl

All of our brands operate under this single company, so Kathie Kozlak LTD is the controller of your personal data regardless of which brand or website you interact with.

If you are located in the EU or EEA: the United Kingdom benefits from an adequacy decision from the European Commission, which recognises that the UK provides a level of data protection essentially equivalent to that of the EU.

Summary

We collect only the data we need to operate our websites, to provide and deliver our products and services, to handle payments, and to send communications you have asked to receive. We use a small number of trusted service providers to do this. We do not sell your personal data. You can ask to access, correct, or delete your data at any time, and you can withdraw your consent to marketing or to non-essential cookies whenever you wish.

The personal data we collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

• Identity data: your name and any preferred name you give us.
• Contact data: your email address and, where you provide it, your telephone number and postal address.
• Account and profile data: any username, preferences, or settings you create with us.
• Communication data: the content of messages you send us through forms, email, chat, or social media, and our correspondence with you.
• Transaction data: details of the products and services you have purchased, the price, the date, and the billing and tax information required to process and record the order. Payments are processed by our payment provider; we do not receive or store your full card details.
• Marketing and engagement data: the mailing lists and interest groups you belong to, your communication preferences, and whether you have opened or clicked our emails.
• Technical and usage data: where analytics are active on a site, your IP address, browser and device type, operating system, the pages you view, referring source, and how you use the site. This is described in section 9.

We collect most of this data directly from you. Some technical data is collected automatically through cookies and similar technologies, and some data may come from our service providers, such as our payment or email providers.

How we use your data and our legal bases

We use your personal data only where the law allows. The legal bases we rely on under the UK GDPR, and the EU GDPR where it applies, are:

• Performance of a contract (Article 6(1)(b)): to take payment, deliver the products and services you buy, provide access and support, and manage our relationship with you.
• Legitimate interests (Article 6(1)(f)): to respond to your enquiries, administer and improve our websites and services, keep proper business records, ensure the security of our sites, and send existing customers short, relevant information about a product or service they have purchased from us. You can object to this processing at any time.
• Consent (Article 6(1)(a)): to send marketing communications and newsletters where consent is required, and to set non-essential cookies. You can withdraw consent at any time without affecting processing carried out before withdrawal.
• Legal obligation (Article 6(1)(c)): to comply with our legal and regulatory duties, including tax, accounting, and record-keeping requirements under UK law.

We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

Marketing and your choices

If you subscribe to one of our newsletters or mailing lists, sign up through a form on one of our sites, or purchase a product, we will send you the communications relevant to what you signed up for or bought. You can change your preferences or unsubscribe at any time using the link in every email, or by contacting us.

Our brands serve different audiences. We will not use your data to market a different brand or venture to you unless you have chosen to receive it. You can manage exactly what you hear about, and from which brand, through our email preference page, and we act only on the choices you make there.

We do not sell or rent your personal data, and we do not share it with third parties for their own marketing.

Who we share your data with

We share your personal data only with the service providers and parties that help us operate our business, and only to the extent they need it to perform their service for us. Each provider that processes data on our behalf does so under a written agreement and is responsible for its own data-protection practices. We recommend reviewing their privacy policies.

• Email and marketing platform (MailerLite, operated by MailerLite UAB): to manage our mailing lists, interest groups, preference page, and to send our communications. Privacy policy: https://www.mailerlite.com/legal/privacy-policy
• Payment processor (Stripe, operated by Stripe, Inc.): to process payments securely and to calculate and handle applicable taxes. Privacy policy: https://stripe.com/privacy
• Analytics and fonts (Google LLC): for website analytics on sites where it is active, and to serve web fonts. See section 9.
• Advertising and measurement (Meta Platforms, Inc.): for advertising measurement and retargeting on sites where the Meta Pixel is active. See section 9.
• Scheduling and messaging tools (Google LLC for appointment scheduling via Google Calendar appointment schedules; ManyChat, Inc. for automated chat) on sites where they are active.
• Website hosting and platform providers, including WordPress and Automattic Inc. services such as Gravatar and Jetpack: to host and operate our websites.
• Spam-prevention services: to help detect and filter spam submissions.
• Professional advisors, such as accountants and lawyers, bound by confidentiality, and regulatory or government authorities where we are required by law to share data.

International data transfers

Some of our service providers are based outside the UK and the EEA, including in the United States. Where your personal data is transferred outside the UK or EEA, we ensure it is protected by appropriate safeguards recognised under data-protection law, such as an adequacy decision, the UK International Data Transfer Addendum, or the European Commission Standard Contractual Clauses, so that your data continues to receive an equivalent level of protection.

How long we keep your data

We keep personal data only for as long as we need it for the purposes set out in this policy, after which we delete or anonymise it. Our standard retention periods are:

• Customer and financial records: for the duration of our relationship and then for six years from the end of the relevant tax year, to meet UK tax and accounting requirements.
• Enquiry data where you contacted us but did not become a customer: up to two years from your last contact.
• Mailing-list and subscriber data: until you unsubscribe or ask us to delete it, after which we remove it, though we may keep a minimal suppression record so that we do not contact you again.
• Payment records held by our payment processor: for the period required by that provider and by law.
• Analytics data: for the retention period set in the relevant analytics tool, typically up to fourteen months.
• Website comments: retained while the relevant page is published, and removed on request.

Cookies and similar technologies

Cookies are small text files placed on your device when you visit a website. We use cookies and similar technologies to make our sites work, to understand how they are used, and, on some sites, for marketing. The specific cookies and third-party tools active on a site depend on which of our sites you visit and the features you use.

We classify cookies as follows:

• Essential cookies are necessary for our sites and checkout to function, and are set without consent.
• Analytics cookies help us understand how visitors use our sites so we can improve them.
• Marketing cookies are used to measure and deliver advertising.

Analytics and marketing cookies are non-essential. Where they are used, we rely on your consent, which you can give, refuse, or change at any time.

The third-party tools that may set cookies or collect data across our sites are set out below.

Managing cookies: you can control or delete cookies through your browser settings. Each major browser (Chrome, Firefox, Safari, and Edge) has its own cookie controls. You can opt out of Google Analytics at tools.google.com/dlpage/gaoptout, and you can adjust your advertising preferences in your Facebook and Instagram account settings. Disabling some cookies may affect how our sites function.

Other information about our websites

Comments: when you leave a comment on one of our sites, we collect the data shown in the comment form, together with your IP address and browser user-agent string, to help detect spam. An anonymised string created from your email address may be sent to the Gravatar service to check whether you use it. After approval, your comment and profile picture are visible to the public.

Media: if you upload images to a site, please avoid uploading images that contain embedded location data, as visitors can download and extract that data.

Embedded content: our pages may include embedded content, such as videos or images, from other websites. Embedded content behaves as though you had visited the other website, and those sites may collect data about you, set their own cookies, and track your interaction with that content.

Children's privacy

Our websites, products, and services are intended for adults aged 18 and over. We do not knowingly collect personal data from children. Where any of our products are designed to be used by a family, the account holder is the adult who registers and pays, and any information entered by the user into a third-party tool, such as an AI assistant, is processed within that user's own account and is governed by that third party's privacy policy, not ours. If you believe a child has provided us with personal data, please contact us and we will delete it.

Your rights

Under UK and EU data-protection law, you have the right to:

• access a copy of the personal data we hold about you;
• have inaccurate or incomplete data corrected;
• have your data erased where we are not required to keep it;
• restrict or object to our processing of your data, including objecting to direct marketing and to processing based on legitimate interests;
• data portability, meaning you can receive your data, or have it transferred, in a structured, commonly used, machine-readable format;
• withdraw consent at any time where we rely on consent;
• not be subject to decisions based solely on automated processing that significantly affect you.

To exercise any of these rights, contact us at contact@keffect.pl. We will respond within one calendar month. There is normally no charge.

Complaints

If you are concerned about how we have handled your personal data, please contact us first so we can try to put it right. You also have the right to complain to a supervisory authority.

In the UK, this is the Information Commissioner's Office (ICO), ico.org.uk, telephone 0303 123 1113. If you are in the EU or EEA, you may complain to the supervisory authority in your country.

Changes to this policy

We may update this policy from time to time as our products, websites, or service providers change. When we make changes, we will post the updated version here and revise the effective date at the top. The version published at the time governs how we handle your personal data.

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