Privacy policy

Kreston PR LLC Privacy policy

This is the data privacy notice of Kreston PR, LLC. We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We will also tell you about your privacy rights and how the data protection law protects you. This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

  1. Who we are and important information
  2. The personal data we collect about you
  3. How we collect your personal data
  4. How we use your personal data
  5. Who we share your personal data with
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights
  10. Changes to this notice and your duty to inform us of changes
  11. Queries, requests, or concerns

1. Who we are and important information

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you use any of our contact forms or sign up to our newsletter. This website is not intended for children, and we do not knowingly collect data relating to children. You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

Kreston PR, LLC is the controller and responsible for your personal data (collectively referred to as “Kreston PR”, “we”, “us” or “our” in this privacy notice). Our contact details are 1509 FD Roosevelt Avenue, Suite 303, Guaynabo, PR 00968. For all data matters contact our data representative via our contact us page (www.krestonpr.com/contact-kreston-pr/).

Third-party links outside of our control

This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Federal Trade Commission | Protecting America’s Consumers (ftc.gov). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as:

  • (a) Identity Data includes First & Last Name, Title.
  • (b) Contact Data includes Billing Address, Email Address & Telephone Number.
  • (c) Usage Data includes information about how you use our website.
  • (e) Marketing & Communications Data includes your preferences in receiving marketing from us and our third parties/your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. How we collect your personal data

We use different methods to collect data from and about you including through:

Information you give us

You may give us your identity and/or contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Apply for our services;
  • Request support;
  • Create an account on our website;
  • Subscribe to our newsletter or alternative publications;
  • Request marketing to be sent to you.

Information we collect

As you interact with our website, we may automatically collect certain technical information. This includes:

  • Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources

We may receive information about you if you use any of the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contract. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Legitimate Interest. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our data representative.
  • Comply with a Legal or Regulatory Obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting our data representative.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our data representative if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

TO REGISTER YOU AS A NEW CLIENT / MEMBER
Type of data:
 (a) Identity & (b) Contact
Legal basis: (a) Performance of a contract with you

TO PROCESS YOUR REQUEST TO DOWNLOAD DOCUMENTS
Type of data:
 (a) Identity & (b) Contact
Legal basis: (a) Performance of a contract with you & (c) Necessary for our legitimate interests (to develop our products/services and grow our business)

TO PROCESS YOUR REQUEST FOR SUPPORT OR AN ENQUIRY ABOUT OUR SERVICES
Type of data:
 (a) Identity & (b) Contact
Legal basis: (a) Performance of a contract with you & (c) Necessary for our legitimate interests (to develop our products/services and grow our business)

TO MANAGE OUR RELATIONSHIP WITH YOU
(this will include notifying you about changes to our terms or privacy policy and/or asking you to leave a review or take a survey)
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Technical, (e) Usage & (f) Marketing
Legal basis: (a) Performance of a contract with you, (b) Necessary to comply with legal obligations & (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products & services)

TO ADMINISTER AND PROTECT OUR BUSINESS, THIS WEBSITE & OUR SOFTWARE
(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Technical & (e) Usage
Legal basis: (b) Necessary to comply with legal obligations & (c) Necessary for our legitimate interests (for running our business, provision of our software, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

TO DELIVER RELEVANT WEBSITE CONTENT AND ADVERTISEMENTS TO YOU
(and/or measure or understand the effectiveness of the advertising we serve to you)
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Technical, (e) Usage & (f) Marketing
Legal basis: (c) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

TO USE DATA ANALYTICS
(to improve our website, services, marketing, customer relationships and experiences)
Type of data: (d) Technical & (e) Usage
Legal basis: (c) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

TO MAKE SUGGESTIONS AND RECOMMENDATIONS TO YOU
(such as about other goods or services that may be of interest to you)
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Technical & (e) Usage
Legal basis: (c) Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of Kreston PR, LLC for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or download, warranty registration, product or service experience or other transactions.

Cookies

If you prefer to do so, you can set your browser to refuse all non-necessary browser cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy (www.krestonpr.com/cookie-policy).

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our data representative.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Who we share your personal data with

We may share your personal data with the parties set out below for the purposes set out in section 4 above.

  • carefully selected third parties who provide a service to us to support our core operations, such as: processing our mail, communicating with clients on our behalf, providing IT systems and administrative services and the development and improvement of internal systems and processes;
  • competent authorities (statutory bodies, regulatory authorities, authorized bodies who have a role laid out by law);
  • other organizations where we are legally obligated to disclose your personal information (such as requests made in the prevention and detection of crime), where disclosure is necessary to protect the property, rights and safety of us and our staff or where disclosure is necessary in order to enforce or apply our contract with you (including non-payment of an invoice);
  • another business, if our business (or part) is purchased/taken over to ensure our services to you can be continually serviced or as part of discussions leading up to a sale/takeover;
  • another company from whom we are looking to purchase assets, where the personal information is relevant to us assessing if those assets will improve our offering to clients and/or our business processes;
  • other businesses where we are trialing products and services which we consider may improve our offering to clients and/or our business processes;
  • other third parties where you have given your express consent or where we reasonably believe a third party is acting on your behalf.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties are based outside the Puerto Rico and the United States (PRUS) so their processing of your personal data will involve a transfer of data outside the PRUS.

Whenever we transfer your personal data out of PRUS, we ensure a similar degree of protection is afforded to it by implementing safeguards.

Please contact our data representative if you want further information on the specific mechanism used by us when transferring your personal data out of PRUS.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We subject the information about our customers (including Contact, Identity, Financial and Transaction Data) to our Documents Retention Policy.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e., where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e., where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact our data representative.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Changes to this notice and your duty to inform us of changes

This version was updated on July 13th, 2021.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

11. Queries, requests, or concerns

To exercise all relevant rights, queries, or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data representative via our contact us page (www.krestonpr.com/contact-kreston-pr).

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Federal Trade Commission | Protecting America’s Consumers (ftc.gov).