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Privacy Policy

1. Introduction

This policy (together with the Cookie Policy set out at Appendix 1 and our Customer Agreement which can be found by clicking on the tab entitled Customer Agreement on the App or on the link entitled App Customer Agreement on our website www.kodypay.com, together our "Terms of Use") applies to your use of:

(a) our website at www.kodypay.com;

(b) the KodyPay app ("App"); or

(c) any of the services you can get access to through the App or website (our "Services"),

together, the ("KodyPay Offering").

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  

The KodyPay Offering is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. 

Under data protection law, KodyPay Ltd is what is known as the 'data controller' of your personal data. 

2. Contact details

Our full details are:

KodyPay Ltd, company number 11532575

Registered office address: Unit 42, 24-48 St Leonard Road, Windsor, Berkshire, England SL3 3BB Email address: [email protected]

You have the right to make a complaint at any time to the Information Commissioner’s Office ("ICO"), the UK supervisory authority for data protection issues.

3. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated in September 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by push notification to your device, SMS, email or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services. 

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

4. Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

5. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.

• Contact Data.

• Financial Data.

• Transaction Data.

• Device Data.

• Content Data.

• Profile Data.

• Usage Data.

• Marketing and Communications Data.

We explain what each of these categories of data are in clause 15 below. 

We also collect, use and share Aggregated Data (information about our users that we combine together so that it no longer identifies or references an individual) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising and other business purposes. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature or the number of users purchasing particular products in particular locations. 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 policy.  

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.

6. How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App and the website (together "Our Sites"), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our Services, search for the App or Service, and when you report a problem with the App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

• Information we collect about you and your device. Each time you visit one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our Cookie Policy at Appendix 1 of this Privacy Policy for further details.

• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties such as credit reference agencies, fraud-prevention agencies and partners who help us to provide our services. This includes your credit record, information to help us check your identity, and information relating to your transactions.

7. Cookies

We use cookies to distinguish you from other users of the App, website or the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy in Appendix 1.

8. How we use your personal data

We collect your information so we can provide the best service, tell you about products and services you may be interested in, and meet our legal obligations. We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.

• Where we need to perform a contract we are about to enter or have entered with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

See the Glossary at clause 14 to find out more about the types of lawful basis that we will rely on to process your personal data. 

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Type of data
Lawful basis for processing
To install the App and register you as a new App user
Your consent
To deliver Services including checking your identity when you apply for a new product or Service, managing payments, to meet our obligations relating to transactions you made (for example, payments into and out of your KodyPay account), to give you details of our products and Services and to contact you with customer support services
Marketing and Communication
Your consent
Performance of a contract with you
Necessary for our legitimate interests (we need to be efficient about how we meet our obligations and we want to provide you with a good service)
To protect against fraud
Your consent
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products / Services)
Necessary to comply with legal obligations (to develop and improve how we deal with financial crime and meet our legal responsibilities)
To manage our relationship with you including notifying you of changes to Our Sites or any Services
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products / Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and
To enable you to participate in a prize draw, competition or complete a survey
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products / Services and to develop them and grow our business)
To administer and protect our business and Our Sites including troubleshooting, data analysis, system testing, statistical and survey purposes and to make sure that content from Our Sites is presented in the most effective way for you and your device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To allow you to take part in interactive features of our services and to help keep Our Sites safe and
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To create, collate, derive or prepare aggregated and/or anonymised data to share with our trusted third-party recipients for commercial purposes
Necessary for our legitimate interests (to provide us with revenue so we can continue to grow and develop Our Sites, our business and associated service offerings)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve Our Sites
If you agree, allow our partners and other organisations to provide you with information about their goods or services
Marketing and Communication
Necessary for our legitimate interests (to develop our products/Services and grow our business)

9. Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table in clause 8 above:

Other companies in the KodyPay group
To help us provide our services to you
Suppliers who provide us with IT, payment and delivery services, including Amazon Web Services and Intercom
To help us provide our services to you
Our banking and financial services partners and payments networks, including banking and lending partners, banking intermediaries and international payment service providers
To help us provide our services to you
Customer service providers, survey providers and developers
To help us provide our services to you
Advertisers and advertising networks
To promote our services
Analytics providers and search information providers
To help us improve Our Sites
Communications services provider
To help us send you emails, push notifications and text messages
Credit reference agencies
To check whether you are likely to make repayments when due
Fraud-prevention agencies
To check your identity, protect against fraud, keep to anti-money-laundering laws and confirm that you are eligible to use our products and services
Our partners
In order to provide you with certain services you have asked us for or to offer you co-branded services or promotional offers (we will always get your consent before sharing your information for these purposes and you can withdraw your consent at any time by contacting us)
Third-party organisations
If we have to do so under any law or regulation; in connection with criminal or fraud investigations; to enforce our rights (and those of customers or others); or
in connection with legal claims

We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

10. International transfers

A number of our external third parties, including Amazon Web Services and Zendesk, are based outside the European Economic Area ("EEA") so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

11. Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of your information via the Internet can never be 100% secure. Although we will do our best to protect your information, we cannot guarantee the security of information about you transmitted to us and so any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. 

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

12. Data retention

Under anti-money laundering laws we need to hold information about you and your transactions for five years.

Generally, we will not hold your personal information for more than six years after our business relationship with you has ended, unless we need to hold it for longer because of a potential or ongoing claim or another legal reason.

In some circumstances you can ask us to delete your data. See clause 13 below for further information. In some circumstances we will anonymise 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.

13. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data’s accuracy;

• where our use of the data is unlawful but you do not want us to erase it;

• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or Services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes. 

You can exercise any of these rights at any time by contacting us at [email protected] or use the in-App chat function on our website at www.kodypay.com.

14. Glossary

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business and generating revenue to enable us to give you the best Service / product and the best and most secure experience and to grow and develop Our Sites, our business and our service offerings. 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 us.

Performance of Contract 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. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

15. Description of categories of personal data

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.

• Contact Data: billing address, delivery address, email address and telephone numbers.

• Financial Data: bank account and payment card details.

• Transaction Data: includes details about payments to and from you.

• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use.

• Content Data: includes information stored on your Device, including friends’ lists, login information and photos, videos or other digital content.

• Profile Data: includes your username and password, in-App transaction history, your interests, preferences, feedback and survey responses.

• Usage Data: includes details of your use of our App or your visits to any of Our Sites including, but not limited to, traffic data and other communication data and the resources that you access.

• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Appendix 1: Cookie policy

Our Sites use cookies to distinguish you from other users of Our Sites. This helps us to provide you with a good experience when you browse Our Sites and also allows us to improve Our Sites. 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device if you agree. Cookies contain information that is transferred to your computer’s or mobile device's hard drive. By continuing to browse Our Sites, you’re agreeing to our use of cookies. 

We use the following cookies: 

Essential Cookies

These are cookies that are required for the operation of Our Sites. They include, for example, cookies that enable you to log into secure areas of Our Sites, use a shopping cart or make use of e-billing services.

Cookie Name
Default Duration
Anonymous visitor identifier
30 Days
Anonymous visitor identifier cookie used to block malicious traffic.
Keeping track of cookie preferences
7 Days
Keeps track of your cookie preferences so we know when to track/not track you.

Performance & functionality cookies

These are used to recognise you when you return to Our Sites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language). We also use these cookies for non-essential security measures and speed improvements.

Cookie Name
Default Duration
Unique anonymous identifier
9 Months
Anonymous visitor identifier cookie.
Keeping track of sessions
7 Days
Identifier for each unique browser session. This session cookie is refreshed on each successful logged-in ping, extending it to 1 week from that moment. You can access your conversations and have data communicated on logged out pages for 1 week, as long as the session isn't intentionally terminated with 'Intercom('shutdown')';, which usually happens on logout.
Rate limiting
1 Minute
Used to throttle request rate.

Analytical cookies

These allow us to recognise and count the number of visitors and to see how visitors move around Our Sites when they are using it. This helps us to improve the way Our Sites works, for example, by ensuring that users are finding what they are looking for easily.

Cookie Name
Default Duration
Visitor identifier
Two Years
Anonymous visitor identifier cookie used to block malicious traffic.
Visitor identifier
24 Hours
Anonymous visitor identifier cookie.

Targeting cookies

We may in addition to the above use targeting cookies. These cookies record your visit to Our Sites, the pages you have visited and the links you have followed. We will use this information to make Our Sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose in accordance with our Privacy Policy.

Third parties

Please note, other organisations, such as advertising networks, may also use cookies to track you across different websites. We have no control over these cookies. 

You can block cookies within your browser, by activating its setting that allows you to refuse all or some cookies. Do bear in mind that if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of Our Sites. 

Except for essential cookies, all cookies set by us will expire after 30 days. 

We may revise this cookies policy at any time by amending this page. Please check it from time to time to take notice of any changes we could make, as they’re binding on you. 

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