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Privacy Policy

KEDOO PRIVACY POLICY

 

Last updated 22 June 2018

 

We operate the Kedoo platform called ‘MarketPlace’ located at www.kedoo.com (“Site”). The Site is an online community connecting content creators (“Creators”) with our brand partners (“Brands”). Brands can publish campaigns through our platform, giving Creators the opportunity to pitch to Brands, who may then engage Creators to create content (“Content”) in respect of a campaign in return for the payment of a fee.

 

We are committed to protecting and respecting your privacy (“you”, “your”, or “user”).

 

This Privacy Policy (“Policy”) together with our Terms of Use (see Creator Terms  and Brand Terms , together “Terms of Use) sets out the basis on which any Personal Data we collect on you, or that you provide to us, will be processed by us. Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us and you. 

 

The data controller of your Personal Data is Kedoo Ltd (company number 10019278) whose registered office is 3 High Street, Road, United Kingdom, NN7 2NW (“Kedoo”, “we”, “us” or “our”) (help@kedoo.com).

 

 

1.         PERSONAL DATA WE COLLECT FROM YOU  

 

Personal Data means any information about an individual from which that person can be identified, whether indirectly or directly (“Personal Data”). It does not include data where the identity has been removed or anonymised.

Personal Data you give us. This is information about you that you give us by creating an account with us on the Site, filling in the ‘Contact Us’ form on the Site or by corresponding with us by phone, email or otherwise.

If you are Creator, we will collect your name, email address, phone number, bank details, your image.

If you represent a Brand, we will collect your name, email address, phone number, bank details.

Information we collect about you. We may automatically collect the following information about all users of our Site, which may be Personal Data as it may (particularly when combined) enable you to be identified:

  • technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site.]

Information we receive from other sources. This is information we receive about you from any third party source, including, if you are a Creator, analytics data from your YouTube Channel, where you have provided us with access to such information.  We may combine this data with the other information we have collected about you via the Site. We will notify you when we receive information about you from any third parties which qualifies as Personal Data and the purposes for which we intend to use that data.

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).

 

2.         HOW WE USE YOUR PERSONAL DATA  

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 we need to, to perform and enforce the obligations contained within a contract we are about to enter into or have entered into with you, including the Terms of Use; or
  • 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; or
  • where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email. We will get your opt-in consent before we:

  • send you any marketing communications; or
  • share your Personal Data with any third party outside of the Kedoo group for the purposes of marketing.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at help@kedoo.com or adjusting your account settings on the Site or following one of the opt out links contained within marketing emails.

Specifically, we use Personal Data held about you in the following ways:

 

Personal Data you give to us. We will use this Personal Data:

 

  • to set up an account for you on the Site;
  • to provide you with Personal Data in respect of any enquiry you should make;
  • to notify you about changes to any services we provide through the Site.

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 your relationship with us.

Personal Data we collect about you. We will use this Personal Data:

  • to deliver the Site effectively and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve the Site to ensure that content is presented in the most effective manner for you and for your computer or other device;
  • as part of our efforts to keep the Site safe and secure;
  • to make suggestions and recommendations to you about services we offer that may interest you; and

Personal Data we receive from other sources.

 

  • We will combine this information with information  you give to us and that we collect about you. We will use the combined Personal Data for the purposes set out above (depending on the types of Personal Data we receive).

 

3.         DISCLOSURE OF YOUR PERSONAL DATA  

You agree that we have the right to share your Personal Data with:

 

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
  • Other users on the Site. Your Personal Data will only be shared with other users of the Site to the extent necessary for the Site to function.
  • We may forward your name, address and other contact information to any third party who, in our view, reasonably claims that you do not or may not have all necessary rights in and to the Content you upload, submit or share through the Site.

We will disclose your Personal Data to third parties:

 

  • If we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets.
  • If we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about Site users will be one of the transferred assets.
  • If we are under a duty to disclose or share your  Personal Data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our users, or others.

 

4.         COOKIES  

We use cookies to distinguish you from other users of the Site. This helps us to provide you with a smooth experience when you visit the Site, and also allows us to improve the Site.  A cookie is a small text file that can be placed on your computer or other device when using the Site.

First and third party cookies

We set cookies (first party cookies) on web pages, however, where we require additional Personal Data or services, we also allow other companies to host cookies on our web pages (third party cookies). These partner companies have been carefully selected by us and are required to meet contractual obligations they have with us.

What do we use cookies for?

The cookies we use are categorised into four groups:

  • Strictly Necessary cookies - these cookies are used for technical reasons and are necessary to enable the Site to operate efficiently so that you can navigate the Site with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Site may not operate effectively.

 

  • Performance cookies - these cookies are used to obtain statistics about the number of users of the Site and how such users interact with the Site. These cookies collect Personal Data that is aggregated and therefore cannot be used to ascertain an individual's identity. Such Personal Data allows us to continuously improve the Site to provide users with a better online.

 

  • Functionality cookies - these cookies are used to improve the functionality of the Site and make it easier to use.  They help us to identify you as a repeat user of the Site and help us remember your preferences (for example, your choice of language or region), improving your user experience.

 

  • Analytical - These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this Personal Data to make our Site and the advertising displayed on it (if any) more relevant to your interests. We may also share this Personal Data with third parties for this purpose

 

We may share Personal Data that we collected through cookies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies as set out below.

 

How do I control my cookie settings on my computer or device?

Please be aware that if you decide to disable or block cookies, parts of the Site may not function correctly, or at all.

Should you choose however to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the 'Help' menu on your particular browser to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org  or www.youronlinechoices.eu for comprehensive Personal Data on how to manage cookies.

 

5.         WHERE WE STORE YOUR PERSONAL DATA  

The data that we collect from you will be transferred to, and stored at, a destination within the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. All Personal Data you provide to us is stored on our secure servers.

 

Unfortunately, the transmission of Personal Data via the internet is not completely secure. While we do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to us over the email or through the ‘Contact Us’ form on the Site; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.

 

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 may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe; or
  • 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 the Europe and the US; or
  • Where countries have been deemed to provide an adequate level of protection for Personal Data by the European Commission, we may transfer your Personal Data to third parties based in those countries.

If you would like further information on the specific mechanism used by us when transferring your Personal Data outside of the EEA, then please contact us using the details provided at the end of this Privacy Policy.

 

6.          YOUR RIGHTS  

Where you are located in the EEA, or where we are processing your Personal Data within the EEA, or in the context of our EEA business, you have a number of rights in relation to how we process your Personal Data.  These include:

  • the right access the Personal Data that we may hold about you;
  • the right to rectify any inaccurate Personal Data that we may hold about you;
  • the right to have your Personal Data erased in certain circumstances, for example, where it is no longer necessary for us to process your Personal Data to fulfil our processing purposes; where you object to your data being processed on certain grounds (for example, for marketing purposes)  or where your Personal Data is being unlawfully processed;
  • the right to object to our processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms;
  • the right to restrict the processing of your Personal Data under limited circumstances; and
  • the right to have your Personal Data ported to a new service provider if you no longer wish to use the Site or our services.

You can exercise any of these rights any time by contacting us at help@kedoo.com.

No fee usually required.

You will not have to pay a fee to access your Personal Data  (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you.

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

Time limit to respond.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these Sites.

 

7.         RETENTION

 

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

For further information on retention periods, please contact us using the details provided at the end of this Policy.

 

8.         CHANGES TO OUR POLICY

Any changes we make to our Policy in the future will be posted on this page and, where you continue to hold an account with us, notified to you by email. Please check back frequently to see any updates or changes to our Policy.

 

9.         CONTACT  

Questions, comments and requests regarding this Policy should be addressed help@kedoo.com.  

Should you have cause to complain about how we handle your Personal Data, please contact us in the first instance.  We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to your local data protection supervisory authority.