Privacy Policy

Thank you for choosing to be part of our community at Kudo Property Ltd ("Company", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regards to your personal information, please contact us on legal@kudoproperty.com. When you visit our website https://www.kudoproperty.com (the "Website"), and more generally, use any of our services (the "Services", which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have concerning it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing, or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

1. WHAT INFORMATION DO WE COLLECT?

The personal information you disclose to us
We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services when you participate in activities on the Website or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Personal Information Provided by you
  We collect names, email addresses, phone numbers, mailing addresses, usernames, passwords, contact preferences, billing addresses, contact or authentication data, debit/credit card numbers, and other similar personal information.


• Payment Data
  We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Payment Sense. You may find their privacy notice link(s) on the following link:
  
  https://www.paymentsense.com/uk/legal/privacy
  
  All personal information that you provide to us must be true, complete, and accurate. You must notify us of any changes to such personal information.


• Information automatically collected
  We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:
  
  
  
  • Log and Usage Data
    Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings, and information about your activity on the Website (such as the date/time stamps associated with your usage, pages, and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
  
  
  • Device Data
    We collect device data such as information about your computer, phone, tablet, or other devices you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system, and system configuration information.
  
  
  • Location of Data
    We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note, however, if you choose to opt-out, you may not be able to use certain aspects of the Services.


• Information collected from other sources
  To enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below. We use the information we collect or receive:

• To facilitate account creation and login process
  If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.


• To post testimonials
  We post testimonials on our Website that may contain personal information. Before posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update or delete your testimonial, please contact us on legal@kudoproperty.com and be sure to include your name, testimonial location, and contact information.


• Request feedback
  We may use your information to request feedback and to contact you about your use of our Website.


• To enable user-to-user communications
  We may use your information to enable user-to-user communications with each user's consent.


• To manage user accounts
  We may use your information to manage our account and keep it in working order.


• To send administrative information to you
  We may use your personal information to send you the product, service, and new feature information and/or information about changes to our terms, conditions, and policies.


• To protect our services
  We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).


• To enforce our terms, conditions, and policies
  For business purposes, to comply with legal and regulatory requirements, or in connection with our contract.


• To respond to legal requests and prevent harm
  If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.


• Fulfil and manage your orders
  We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the site.


• To deliver and facilitate the delivery of services to the user
  We may use your information to provide you with the requested service.


• To respond to user inquiries/offer support to users
  We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our services.


• To send you marketing and promotional communications
  We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our site, subscribing to marketing, or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see "WHAT ARE YOUR PRIVACY RIGHTS" below).


• Deliver targeted advertising to you.
  We may use your information to develop and display personalised content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We may process or share your data that we hold based on the following legal basis:

• Consent
  We may process your data if you have given us specific consent to use your personal information for a specific purpose.


• Legitimate Interests
  We may process your data when it is reasonably necessary to achieve our legitimate business interests.


• Performance of a Contract
  Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.


• Legal Obligations
  We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).


• Vital Interests
  We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  

• Business Transfers
  We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  


• Vendors, Consultants, and Other Third-Party Service Providers
  We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time.
  This information may be used to, among other things, analyse and track data, determine the popularity of certain content, pages, or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
  


• Affiliates
  We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  


• Business Partners
  We may share your information with our business partners to offer you certain products, services, or promotions.
  

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

We only share and disclose your information with the following third parties. We have categorised each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".

• The Financial Conduct Authority (FCA), and other regulators and authorities


• US tax residence info is shared with the Internal Revenue Service (IRS)


• CRS applicable tax residence info (countries as per OECD Guidance ) is shared with the Organization for Economic Co-operation and Development (OECD)


• SumSub AML screening service


• Data Backup and Security
  Amazon Web Services (AWS)


• Functionality and Infrastructure Optimization
  Amazon Web Services (AWS)


• Web and Mobile Analytics
  Google Analytics

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. DO WE USE GOOGLE MAPS PLATFORM APIS?

This Website uses Google Maps Platform APIs which are subject to Google’s Terms of Service. You may find the Google Maps Platform Terms of Service here. To find out more about Google’s Privacy Policy, visit their website.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the Dublin, Ireland. If you are accessing our Website from outside Ireland, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in Dublin, and other countries. If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than seventy-two (72) months past the termination of the user's account. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us on legal@kudoproperty.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right:

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practise in a revised version of this privacy notice.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

1. Every individual who is in the State of California for other than a temporary or transitory purpose
2. every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

1. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
2. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information.
3. Protected classification characteristics under California or federal law Gender and date of birth.
4. Commercial information Transaction information, purchase history, financial details, and payment information.
5. Internet or other similar network activity.
6. Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements
7. Geo-location data Device location.
8. Professional or employment-related information.
9. Inferences are drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

1. Receiving help through our customer support channels.
2. Participation in customer surveys or contests.
3. Facilitation in the delivery of our Services and to respond to your inquiries.

14. GDPR DATA PROTECTION RIGHTS

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access
You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification
You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erase
You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing
You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing
You have the right to object to our processing of your data, under certain conditions.

The right to data portability
You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us on legal@kudoproperty.com.

15. CALOPPA (CALIFORNIA ONLINE PRIVACY PROTECTION ACT)

Although it does apply to California-based businesses as well, CalOPPA pertains to any company that collects personal information from California residents regardless of where that company is located. Because of the global nature of the internet, this law not only applies to almost any business in the United States, but it can also be (and has been) enforced in other countries as well. In our case, as we have traffic from all over the world so our privacy policy complies with the CalOPPA as well. Note: CalOPPA requires that all information you collect about Visitors be listed within the Privacy Policy. This includes both the information collected directly from users, data that is collected automatically such as IP address, and data collected from visitors such as email, etc. We provide all such information in our privacy policy so we fulfil the criteria of CalOPPA requirement

16. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email on legal@kudoproperty.com.

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please send an email to legal@kudoproperty.com.