Privacy Policy

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3. Our legal basis for processing personal information

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We only ever use your information in line with applicable data protection laws and guidance based on your location – this includes the EU General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 (DPA 2018), the Act on the Protection of Personal Information (the APPI) of Japan, and the Hong Kong Data Protection Principles (the DPP) (collectively the Data Protection Legislation). 

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Under the Data Protection Legislation, these are the general legal bases for which we process your personal information, as detailed in the table above:

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Consent – you have given us consent to process your personal information for a specific purpose that we have told you about.

Performance of our contract – processing your personal information is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

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Legitimate interests – processing your personal information is necessary for our legitimate interests or those of a third party, provided those interests are not outweighed by your rights and interests (including where processing is required to comply with or enforce a legal obligation, or to exercise or defend our legal rights).

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Kaiku may collect personal information indirectly. When applicable, you are informed about the data collection and processing practices through this Privacy Policy and may withdraw consent to data use at any time. 

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4. When do we share your personal information?

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We may disclose your information for certain purposes and to third parties, as described below:

Provision of service: we may share your personal information for the provision of Advisory services (Advisory Users). We do not authorise Advisory Users to use or disclose your personal information, and Advisory Users agree to the same or higher level of data protection and security as Kaiku.

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Kaiku staff and our group of companies:

we share your information with our staff (including employees, consultants, agents and advisors) and within the Kaiku group of companies as required for: providing you with access to our services according to our agreement, data storage and processing, providing customer support, making internal choices around business improvements, content development, and for the other purposes set out in this Privacy Policy.

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Third Party Providers:

We use certain companies, agents or contractors (Third Party Providers) to perform services on our behalf or to help deliver our services to you. We contract with Third Party Providers, for example to track our contacts and communications, advertising, marketing communications, infrastructure and IT services, to personalise and enhance our services, to provide customer service, to collect debts, to analyse and action data (including data about interactions with our services), and to process and administer consumer surveys. In the course of providing such services, these Third Party Providers may have access to your personal information. We do not authorise Third Party Providers to use or disclose your personal information except in connection with providing their services to us. Upon your request, we may provide a list of active sub-processors. 

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Promotions with our partners:

We may offer joint promotions, schemes or incentives with our selected partners that, in order for you to participate, will require us to share your information with the relevant partner. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the relevant incentive. Please note that our partners are responsible for their own privacy and data protection methods and if applicable you should refer to their relevant Privacy Policy.

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To protect legitimate interests:

There are certain circumstances where Kaiku and our Third Party Providers may disclose and/or make use of your information where a disclosure would be necessary to: (a) satisfy any applicable law, regulation, legal process, or other legal or governmental request or requirement, (b) enforce applicable terms of use, including investigation of any actual or alleged breaches, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Kaiku, its users or the public, as required or permitted by law.

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Transfers of our business:

In connection with any corporate reorganisation, restructuring, investment, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to comply with our requirements as set out in this Privacy Policy relating to your personal information.

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5. Communications

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This section is to explain how we will ensure that you only receive communications that you wish to receive.

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Marketing communications:

We want to ensure that you are informed and aware of the best services and promotions that we can offer you. By consenting to receive additional communications (by mail, telephone, text/picture/video message or email) from us and any named third parties that feature at the point of obtaining consent in respect of such information, we will process your personal information in accordance with this Privacy Policy.

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You can change your marketing preferences and unsubscribe at any time by emailing us or clicking the ‘unsubscribe’ in applicable communications. If you choose not to receive this information we will be unable to keep you informed of new services and promotions of ours, or the Kaiku group of companies, that may interest you.

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Whatever you choose, you’ll still receive other important information, for example service updates, as described below.

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Service communications:

As detailed in the table in Section 2, we may send you communications such as those which relate to any service updates (e.g. new product features, service availability) or provide customer satisfaction surveys. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.

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6. How long do we store your personal information?

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Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the personal information be deleted. Even if we delete your personal information, it may persist on backup or archival media for legal, tax or regulatory purposes.

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In accordance with this Privacy Policy, you have the right to request that we delete your personal information, except where we are legally permitted or required to maintain certain personal information. For example:

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We are legally required to retain financial and transaction data for a minimum period of 7 years for tax, audit and accounting purposes. This includes keeping a record of the amount of each transaction, what it related to, and who we transacted with.  

There may be other situations where we have legitimate business interests to retain personal information, such as to prevent fraud or protect the security of other people interacting with us.

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Any Third Party Providers that we engage, will keep your personal information stored on their systems for as long as is necessary to provide the relevant services to you or us. If we end our relationship with any third party providers, we will take reasonable steps to ensure that they securely delete or return your personal information to us.

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We may retain personal information about you for statistical purposes. Where information is retained for statistical purposes it will always be de-identified, meaning that you will not be identifiable from that information.

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7. Security of your personal information

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We are committed to securing and protecting your personal information, and we make sure to implement appropriate technical and organisational measures to help protect the security of your personal information. We may adopt various policies including anonymisation, pseudonymisation, encryption, password restricted access, and retention policies to guard against unauthorised access and unnecessary retention of personal information in our systems.

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The information that we collect from you may be transferred to, and stored at, a destination outside of the UK and/or the European Economic Area (EEA). When we transfer and store your personal information outside of the UK and/or EEA we will take steps to ensure that the information is transferred in accordance with this Privacy Policy and applicable data protection laws. In particular, we will ensure that appropriate contractual, technical, and organisational measures are in place with any parties outside the UK and/or EEA such as the Standard Contractual Clauses approved by the EU Commission.

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Unfortunately, the transmission of your personal information via the internet is not completely secure and although we do our best to protect your personal information, we cannot guarantee the security of your information transmitted to us over the internet and you acknowledge that any transmission is at your own risk.

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Use of data in Kaiku training models: 

Kaiku uses publicly available data to train our models used in Services, and to improve our Services. Personal information used for training purposes is not used to market to specific customers or profile individuals.

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8. Links

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Our website may, from time to time, contain links to websites operated by third parties, which will usually be those of our commercial partners. This Privacy Policy only applies to the personal information that we collect from you and we cannot be responsible for personal information collected and stored by third parties. If you click on a link, please understand that the relevant third party websites have their own terms and conditions and privacy policies, and we do not accept any responsibility for the content of those third party websites or third party terms and conditions or policies. Please check these policies before you submit any personal information to these websites.

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9. Age Restrictions

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You must be 18 years of age or older to use our Services generally. We do not knowingly collect personal information from individuals under 18 years of age. If you are under that age limit, then please do not use Kaiku or provide any personal information to us. 

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10. Sale of data 

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Kaiku has/has not “sold” personal information in the 12 months prior to the last updated data. 

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11. Notice for Japan residents 

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Kaiku may collect and process information indirectly as defined under the Act on the Protection of Personal Information (the APPI). Personal information is collected to fulfill the purposes of performing the service, as outlined in Section 2 and 3 of this Privacy Policy. 

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Individuals whose personal information is collected by Kaiku, may exercise their rights under Section 14.

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13. Notice for Hong Kong residents

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Kaiku may collect and process information indirectly as defined under the Hong Kong Data Protection Principle (the DPP). Kaiku collects personal information in compliance with DPP 1 and DPP 3. Personal information is collected to fulfill the purposes of performing the service, as outlined in Section 2 and 3 of this Privacy Policy. 

Individuals whose personal information is collected by Kaiku, may exercise their rights under Section 14. 

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14. Your rights and choices

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This section explains that you have a number of rights in relation to your personal information.

Under the Data Protection Legislation, you are entitled to certain rights. There are circumstances in which your rights may not apply. You have the right to request that we:

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• provide you with a copy of the information we hold about you;
• update any of your personal information if it is inaccurate or out of date;
• delete the personal information we hold about you - if we are providing services to you and you ask us to delete personal information we hold about you then we may be unable to continue providing those services to you;
• restrict the way in which we process your personal information;
• stop processing your data if you have valid objections to such processing; and
• transfer your personal information to a third party.

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For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us.

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

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As explained in section 4, even if you consented to the processing of your personal information for marketing purposes (by ticking the relevant box or by requesting information about services for example), you have the right to ask us to stop processing your personal information for such purposes. You can exercise this right at any time by contacting us.

Please note that we reserve the right to charge a fee for responding to requests where we reasonably determine that they are manifestly unfounded or onerous or being made in bad faith.

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15. Contacting us

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If you have any questions or concerns about how we handle your personal information, please contact us. We have appointed a DPO that you can contact at:

hello@kaiku.co
Assenteo Ltd
71-75 Shelton Street, Covent Garden,
London, United Kingdom,
WC2H 9JQ‍

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If you are not satisfied with the way a complaint you make in relation to your personal information is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/. ‍

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‍16. Cookies

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We may use cookies on our website which help us monitor use of it, and in turn improve it based on how we interact with it. You can choose to accept or turn off cookies within your browser settings. We use the following types of cookies: