Keeping your personal data safe

Our Privacy Policy is designed to keep you and your data safe, while providing the best service possible.

Privacy Policy - Table of Contents

1. Introduction

2. Contact details

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

4. Third party links

5. The categories of data we collect about you

6. How is your personal data collected?

7. Cookies

8. Purposes for which we will use your personal data

9. Disclosures of your personal data

10. International transfers

11. Data security

12. Data retention

13. Your legal rights

14. Glossary

Appendix 1: Cookie policy

Essential Cookies

Performance & functionality cookies

Analytical cookies

Targeting cookies

Privacy Policy

1. Introduction

This policy (together with the Cookie Policy set out at Appendix 1, our Service Terms and Conditions and Merchant Terms and Conditions which can be found by tapping on the tab entitled “Legal” in the settings area of the App or via the link entitled “Terms” 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 collected from you, or that you provide to us, will be processed by us.

We partner with various organisations and merchants (our “Partners”) to improve your payments with them. While the App may display third party branding, the App is owned and operated by KodyPay Ltd. It is important that you understand that KodyPay Ltd exercises overall control over how your personal data is processed in order to provide you with the KodyPay Offering and under applicable data protection law, KodyPay Ltd is the Controller of your personal data.

With the exception of Processors acting on our instructions; this policy does not apply to any third-party websites, applications or software that integrates with the KodyPay Offering or any other third party products, services or businesses, including those of our Partners. KodyPay is not responsible for the privacy or security practices of any third party, which may be different than the practices described in this privacy policy.

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 personal data shall be processed. We recommend that you save and print a copy of this policy for future reference.

While this policy is primarily aimed at those who use the KodyPay Offering as a customer, we will also explain in this policy the extent to which we will collect or otherwise process your personal data if you work for or with one of our Partners to deliver the KodyPay Offering.

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: info@kodypay.com

If, after contacting KodyPay Ltd, you have unresolved concerns, you have the right to complain to an information protection authority where you live, work or where you believe a breach may have occurred. The contact details for the UK Data Protection Authority are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

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 November 2021. 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 acknowledge 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.

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 categories of data we collect about you

We may collect, use, store and transfer the following categories and types of personal data about you as follows:

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.

Know You Customer (KYC) Data: first name, last name, home address, date of birth, passport or identity card details, signature, email address and telephone numbers.


We also collect, use and share anonymised 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 also work with third parties (such as suppliers who provide us with IT, payment and delivery services and our banking and financial services partners and payments networks) who may also use and share aggregated data derived from your personal data for similar purposes, subject to their own compliance with data protection laws.

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 work for one of our Partners, they may provide your personal data to us to enable us to create staff credentials and manage your access to the App and our web portal.

If you work with one of our Partners, e.g. as a merchant which incorporates the KodyPay Offering into its services, we may need to collect and otherwise process your personal data, including by sharing such data with the relevant Partner to perform mandated Know Your Counterparty verification checks (“KYC checks”). This enables us to comply with our legal and regulatory obligations.

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) we collect from you when you fill 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 our Partners, Processors and publicly available sources. We will receive personal data about you from our Processors 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. Purposes for which we will use your personal data

We process your personal data for the following purposes:

Purpose/activity
Type of data
Lawful basis for processing
Use of the App
To install the App and register you as a new App user
Identity
Contact
Financial
Device
Performance of a contract with you.
To check your identity when you apply for a new product or Service
Identity
Contact
Financial
Transaction
Device
Marketing and Communication
Performance of a contract with you.
To enable us to process transactions, including in relation to:
• Managing payments into and out of your KodyPay account;
• Remedying transactions made in error or which have passed through Our Sites incorrectly or which otherwise require action to be taken by us or our Partners; or
• Processing returns in conjunction with our Partners
Identity
Contact
Financial
Transaction
Performance of a contract with you.
To enable us to create staff credentials for the App and our web portal
Identity
Contact
Performance of a contract with you.
To personalise services provided by merchants
Identity
Necessary for our Legitimate Interests
Management of Services
To enable us to detect misuse of the App, to close or to merge duplicate accounts and to prevent any other misconduct, including interference with our App or any operating system
Identity
Contact
Financial
Transaction
Device
Necessary for our legitimate interests (we need to ensure that our Services are not abused and function well)

To carry out Know Your Customer (KYC) checks on appropriate organisations and individuals, e.g. merchants which incorporate the KodyPay Offering into their services
KYC

Necessary for our legitimate interests (we need to ensure that we meet our obligations to our Partners)
Necessary to comply with legal obligations (to limit potential exposure to risk and cooperate with our Partners in the verification process)
To protect against fraud
Identity
Contact
Financial
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products / Services)
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, including to allow you to take part in interactive features of our Services
Identity
Contact
Device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
Communicating with You
To manage our relationship with you including notifying you of changes to Our Sites or any Services
Identity
Contact
Financial
Profile
Marketing and Communications
Performance of a contract with you
To enable you to participate in a prize draw, competition or complete a survey
Identity
Contact
Device
Profile
Marketing and Communications
Your Consent
To deliver content and advertisements to you
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communication
Necessary for our legitimate interests (to develop our products/Services and grow our business)
To measure and analyse the effectiveness of the advertising we serve you
Identity
Contact
Device
Profile
Marketing and Communications
Necessary for our legitimate interests (to analyse how customers use our products / Services and to develop them and grow our business)
To monitor trends so we can improve Our Sites
Identity
Contact
Device
Profile
Marketing and Communications
Necessary for our legitimate interests (to analyse how customers use our products / Services and to develop them and grow our business)
For partners and other organisations to provide you with information about their goods or services
Identity
Contact
Device
Profile
Marketing and Communications
Your Consent
To make recommendations to you about goods or services which may interest you
Identity
Contact
Device
Profile
Marketing and Communications
Necessary for our legitimate interests (to develop our products/Services and grow our business)
To provide direct marketing via email, telephone, SMS, push notification or other messaging service.
Identity
Contact
Device
Profile
Marketing and Communications
Your Consent
Aggregated Data
To create, collate, derive or prepare aggregated data to share with our trusted third-party recipients for commercial purposes
Identity
Contact
Device
Content
Profile
Usage
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)

9. Disclosures of your personal data

We will share your personal information with third parties who support our business, who will process it on behalf of KodyPay for the purposes identified in Clause 8. Such third parties include merchants, financial institutions, credit reference agencies, fraud prevention service providers, providers of hosting services and technical infrastructure CRM services, customer support services, and marketing/advertising services.

We only provide personal data required to perform the specific service(s). Our Processors may only use personal data for the specific purpose(s) specified in our contract with them. We conduct initial and ongoing due diligence of their security and data protection regimes. If we cease our engagement, we shall ensure personal data held by a Processor will be deleted or rendered anonymous.

We will provide your personal data to our Partners to enable them to act against you where there is reason to believe that you are misusing our Services. To remedy transactions made in error or which have passed through Our Sites incorrectly or which otherwise require action to be taken by our Partners. To provide you with certain services you have asked us for or to offer you co-branded services or promotional offers. To enable us to comply with our legal and regulatory obligations.

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 IBM, Visa's Cybersource and Intercom, are based outside the United Kingdom ("UK") so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data outside the UK, we shall 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 UK Secretary of State for Digital, Culture, Media and Sport. For further details, please consult the ICO website.

• Where we use certain service providers, including in the US, we may use specific contracts approved by the Information Commissioner’s Office, which give personal data the same protection it has in the UK. For further details, see the ICO Model contracts for the transfer of personal data to third countries.

11. Data security

KodyPay, as a responsible company, has a layered approach to security in place to keep your personal data safe. We maintain compliance with the internationally recognised data security standard PCI-DSS. Some of the controls we have in place include, but are not limited to:

• We secure access to all our Sites and apps using TLS technology.

• Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.

• We perform periodic vulnerability scans and carry out penetration testing to identify ways to further strengthen security.

• We take regular backups.

12. Data retention

Where a legal minimum retention period exists, your data shall be held for that period. For all other purposes, data will be retained in line with our data retention schedule. If you would like any information on how long your data is retained, please contact us at support@kodypay.com or use the in-App chat function on our website at www.kodypay.com.

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

• Request access to the personal data we hold on you (commonly known as a “Data Subject Access Request”).

• Request correction of the personal data that we hold about you.

• Request erasure of your personal data.

• Object to processing of your personal data for one or more purposes.

• Request restriction of processing of your personal data for one or more purposes. You have the absolute right to restrict processing of your personal data for direct marketing purposes.

You can exercise any of these rights at any time by contacting us at support@kodypay.com 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.

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
Purpose
Default Duration
Description
kpbanner
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
Purpose
Default Duration
Description
intercom-id-[app_id]
Unique anonymous identifier
9 Months
Anonymous visitor identifier cookie.
intercom-session-[app_id]
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.
_gat_gtag_UA_178495853_1
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
Purpose
Default Duration
Description
_ga
Visitor identifier
Two Years
Anonymous visitor identifier cookie used to block malicious traffic.
_gid
Visitor identifier
24 Hours
Anonymous visitor identifier cookie.
_fbp
Visitor identifier
7 Days
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.