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Mobile App Privacy Policy

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided at www.kubu- home.com/appterms and it is important that you read that information.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy www.kubu-home.com/appterms.
YES I consent to the installation of the App.
NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us on www.kubu-home/support but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Kubu Smart Ltd (“we”) are committed to protecting your personal data and respecting your privacy.

Introduction

This privacy policy (“Policy”) (together with our mobile application terms and conditions as set out at www.kubu-home.com (“Mobile Application Terms”) and any additional terms of use incorporated by reference into the Mobile Application Terms applies to your use of the Kubu mobile application software (“App”), once you have downloaded or streamed a copy of the App from our website onto your mobile telephone or handheld device (“Device”).
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.
This App 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.

Important information and who we are

Kubu Smart Ltd is the controller and is responsible for your personal data (collectively referred to as “Company“, “we“, “us” or “our” in this Policy).
We have appointed a data privacy manager. If you have any questions about this Policy, please contact them using the details set out below:
Contact name: Ryan Bromley

Contact email address: support@kubu-home.com

Contact telephone number: 0330 555 9545

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this Policy and your duty to inform us of changes

We keep this Policy under regular review.
This version was last updated in May 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email. 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.
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.

Third party links

Our website 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.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. 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 Policy.

We do not intentionally collect or seek out 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.

How is your personal data collected?

We will collect and process the following data about you:

Cookies

We use cookies to distinguish you from other users of the App, our website and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our website and also allows us to improve the App and our website.

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:

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.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity Contact Financial Device

Your consent

To manage payments and collect money owed to us

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Location

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App

Identity Contact Financial Profile

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)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity Contact Device Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

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 the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Consent

Necessary for our legitimate interests (to develop our products and grow our business)

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;

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

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

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data.
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.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:

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

If you wish to exercise any of the rights , please contact us at support@kubu-home.com

Glossary

1.1 Lawful Basis
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 to enable us to give you the best service/product and the best and most secure experience. 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.

1.2 Third Parties

1.3 Internal Third Parties
Other companies [acting as joint controllers or processors] and who are based in India and Malaysia and provide [IT and system administration services and undertake leadership reporting].

1.4 External Third Parties
Service providers [acting as processors] based in India who provide [IT and system administration services].

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances].

1.5 Your Legal Rights

You have the right to:

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.

Want to learn more?

Get in touch with us today




Give us a call on

0330 555 9545

E-mail us at

support@kubu-home.com

Our Head office

4th Floor Towers Business Park
Wheelhouse Road
Rugeley
WS15 1UZ