Privacy Policy

1. Who we are

Kinshipway is a trading name of Aquila Altivora LLC, a limited liability company registered in the State of Wyoming, United States of America ("Kinshipway", "we", "us", "our"). We operate the website www.kinshipway.com and all associated services.

For the purposes of UK GDPR and the Data Protection Act 2018, Aquila Altivora LLC is the data controller of personal data collected through our services from UK and EU residents. As a non-UK entity that processes the personal data of UK residents, we have appointed a UK GDPR representative as required by Article 27 UK GDPR:

UK and EU residents may contact our representative directly in relation to all matters concerning the processing of their personal data and the exercise of their rights under UK GDPR and EU GDPR.

For US operations, Aquila Altivora LLC is the business entity responsible for the collection and processing of your personal information under applicable US privacy law.

2. Data we collect

Information you provide directly

• Name, email address, telephone number, and postal address
• Account registration details and login credentials
• Communications you send to us (including support enquiries)
• Payment and billing information (processed via secure third-party processors)
• Survey responses, feedback, or competition entries

Information collected automatically

• IP address and approximate geographic location
• Browser type, device identifiers, and operating system
• Pages visited, time spent, click patterns, and referring URLs
• Cookie and tracking data (see Section 9)

Information from third parties

• Social media profile data (where you connect an account)
• Data from analytics and advertising partners
• Publicly available information where relevant and lawful

3. How we use your information

4. Legal basis for processing (UK & EU)

Under UK GDPR and EU GDPR, we rely on the following lawful bases:

• Contract — processing necessary to fulfil a contract with you or to take steps at your request before entering into a contract.
• Legitimate interests — where we have a legitimate business interest that is not overridden by your rights (e.g. fraud prevention, service improvement, direct marketing to existing customers).
• Consent — where you have given clear consent for a specific purpose (e.g. marketing emails, non-essential cookies). You may withdraw consent at any time.
• Legal obligation — where processing is necessary to comply with a legal obligation to which we are subject.

5. Sharing your data

We do not sell your personal data. We may share it with:

• Service providers — trusted third parties who process data on our behalf (hosting, email delivery, analytics, payment processing). They are bound by data processing agreements and may only process data on our instructions.
• Group companies — affiliated entities within the Kinshipway group, subject to equivalent protections.
• Professional advisers — solicitors, accountants, insurers, where necessary.
• Regulators and law enforcement — where required by law, court order, or to protect our legal rights.
• Business transfers — in the event of a merger, acquisition, or sale of assets, your data may be transferred to the relevant third party.

6. Retention of data

We retain personal data only for as long as necessary for the purposes set out in this policy, or as required by applicable law. Typical retention periods:

7. Your rights (UK & EU)

Under UK GDPR and EU GDPR you have the following rights:

• Access — Obtain a copy of the personal data we hold about you.
• Rectification — Have inaccurate or incomplete data corrected.
• Erasure — Request deletion of your data in certain circumstances.
• Restriction — Ask us to limit how we use your data in certain circumstances.
• Portability — Receive your data in a structured, machine-readable format.
• Objection — Object to processing based on legitimate interests, including direct marketing.
• Withdraw consent — Where processing is based on consent, withdraw it at any time.
• Complaint — Lodge a complaint with the ICO (UK) or your local supervisory authority.

To exercise any of these rights, email privacy@kinshipway.com. We will respond within 30 days. You may also complain to the Information Commissioner's Office (ICO) at ico.org.uk or call 0303 123 1113.

8. US residents

California (CCPA / CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to know — what personal information we collect, use, disclose, and sell.
• Right to delete — request deletion of personal information we hold about you, subject to certain exceptions.
• Right to correct — request correction of inaccurate personal information.
• Right to opt out — opt out of the sale or sharing of your personal information.
• Right to limit use — limit our use and disclosure of your sensitive personal information.
• Right to non-discrimination — we will not discriminate against you for exercising your rights.

Kinshipway does not sell personal information as defined under CCPA/CPRA. To submit a rights request, email privacy@kinshipway.com or visit our preference centre.

Other US states

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other states with privacy laws may have similar rights. We honour such requests wherever applicable. Contact us at privacy@kinshipway.com.

9. Cookies

We use cookies and similar tracking technologies. Essential cookies are required for the site to function. All other cookies (analytics, marketing) are placed only with your consent. Please see our Cookie Policy for full details and to manage your preferences.

10. International transfers

Your data may be transferred to and processed in countries outside the UK and EU. Where this occurs, we ensure appropriate safeguards are in place, such as:

• UK International Data Transfer Agreements (IDTAs) or EU Standard Contractual Clauses (SCCs)
• Adequacy decisions by the UK Government or European Commission
• Other legally recognised transfer mechanisms

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These include encryption in transit and at rest, access controls, and regular security assessments. No method of transmission over the internet is completely secure; if you have reason to believe your interaction with us is no longer secure, please contact us immediately.

12. Children's privacy

Our services are not directed at children under the age of 13 (or 16 where required by applicable law). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.

13. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be notified to you by email or by a prominent notice on our website prior to the change becoming effective. The "last updated" date at the top of this page reflects the most recent revision. We encourage you to review this policy periodically.

14. Contact us

For unsubscribe requests: kinshipway.com/unsubscribe