KUDO Energy Privacy Notice
This Privacy Notice is intended to inform you (“you”, “your”, “yours” or “yourself”) how Kudo Energy Limited (registered number SC267933) whose registered office is at The Green House Forrest Estate, St John's Town Of Dalry, Castle Douglas, Dumfries & Galloway DG7 3XS, Scotland ("we”, “us” or “our”) will collect and use your personal data when you do any of the following:
- Visit and browse our website www.kudosofware.com
- Supply your personal data to us including through our website, in writing, and verbally
- Communicate with us in any way, either directly or in response to a communication from us, including by email, direct message, video chat, phone, and text
- Submit your personal data to us with the intention that we may use it to contact in future in connection with our services, when you order or buy any of our services, including any modification, cancellation or similar activity
- Register and sign up for our newsletter or sign up for a promotion or special offer.
Please read this Notice carefully as it contains important information on your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
Personal data we collect about you
The personal data we collect about you depends on the whether you are, or may be, a customer or a supplier, personnel of a customer or a supplier, a private individual, or you are browsing our website (in whichever capacity). In each case we will collect and use some or all of the following personal data about you:
Information Type |
Details |
| Personal information | Name, title, address, phone number(s), email address, gender, job title, work address, details of company you work for, professional experience, qualifications |
| Payment method information | Billing information, transactional history and purchases, amount paid for services, bank information |
| Newsletter information | Email address provided to sign up for our newsletter |
| Website use & communications | In addition to the personal information described above, we may collect your username, account ID and password, IP address, website use information, browser information, device type, location, image and video and audio recording |
| Other information | Any information that is relevant to your interaction with us, your visit to our website, and making an enquiry. |
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect most of this personal data directly from you, but we may also collect information:
• from publicly accessible sources, e.g. Companies House
• from your company website(s) and other online sources
• from cookies on our website. See our Cookie Policy for more information.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of another.
We have a legitimate interest when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and why
|
What we use your personal data for |
Our reasons |
|
Processing your enquiry, contact with you and communications |
Legitimate interests |
|
To set you up as a customer or supplier |
Legitimate interests |
|
Providing products and/or services to you |
To comply with the contract with you |
|
Communicating with you about information that directly relates to you in the course of providing services to you and/or in connection with your communication with us |
Legitimate interests To comply with the contract with you |
|
Preventing and detecting fraud against you or us |
Legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us |
|
Conducting checks to identify our customers and/or suppliers and verify their identity
|
Depending on the circumstances:
|
|
Other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator |
To comply with our legal and regulatory obligations
|
|
To enforce legal rights or defend or undertake legal proceedings |
Depending on the circumstances:
|
|
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
|
Ensuring business policies are adhered to, e.g. policies covering procurement, ethical trading and security |
Legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
|
Operational reasons, such as improving efficiency, training and quality control |
Legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
|
Ensuring the confidentiality of commercially sensitive information |
Depending on the circumstances:
|
|
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer and supplier base, product range or other efficiency measures |
Legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price, or to ensure cost-effectiveness and efficiency in the supply chain |
|
Preventing unauthorised access and modifications to systems |
Depending on the circumstances:
|
|
Protecting the security of systems and data used to provide the goods and/or services |
To comply with our legal and regulatory obligations
|
|
Updating customer and/or supplier records |
Depending on the circumstances:
|
|
Statutory returns |
To comply with our legal and regulatory obligations |
|
Ensuring safe working practices, staff administration and assessments |
Depending on the circumstances:
|
|
Marketing our products and/or services to:
|
Legitimate interests, i.e. to promote our business |
|
Credit reference checks via external credit reference agencies |
Legitimate interests, i.e. to ensure our customers are likely to be able to pay for our products and services |
|
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our |
Depending on the circumstances:
|
|
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances:
|
Marketing
We have a legitimate interest in using the personal data of personnel who work for a customer or supplier for marketing purposes. This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
We give such personnel the right to opt out of receiving marketing communications at any time by:
• sending an email to [email protected]
We may ask commercial personnel to confirm or update marketing preferences if they ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat personal data with the utmost respect and never sell or share it with other organisations.
Who we share your personal data with
Where necessary we routinely share personal data with:
• External hosting providers for the administration of our website, for example our video chat host and our newsletter distributor
• Mailing houses; we transfer your name and address to mailing houses to send out brochures
• Our affiliates and companies in the Natural Power family of companies, who may use your information in the same way as we can under this notice
• Our professional advisors, our insurers and bank(s) and auditors for the purpose of seeking professional advice or to meet our audit responsibilities
We only allow those organisations to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency - usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above.
Some of these third parties may be based outside the UK[/EEA]. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK[ and EEA]’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you no longer have an account with us, you no longer provide goods and/or services to us or we are no longer providing goods and/or services to you, we will delete or anonymise your data after 2 years.
Transferring your personal data out of the UK and EEA
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Your rights
You have the following rights, which you can exercise free of charge:
|
Access |
The right to be provided with a copy of your personal data |
|
Rectification |
The right to require us to correct any mistakes in your personal data |
|
Erasure (also known as the right to be forgotten) |
The right to require us to delete your personal data (subject to exemptions) |
|
Restriction of processing |
The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
|
Data portability |
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations) |
|
To object |
The right to object:
|
|
Not to be subject to automated individual decision making |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For more information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
• email, call or write to us - see below: ‘How to contact us’; and
• provide enough information to identify yourself and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We will aim to resolve any issues you may have.
You also have the right to lodge a complaint with:
• the Information Commissioner in the UK; and
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
How to contact us
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
We have appointed Natural Power Consultants (Ireland) Limited] to be our data protection representative within the EEA. They can be contacted at Suite 6, The Mall, Beacon Court, Sandyford, Dublin 18, D18 A3W8, Ireland.
Changes to this Notice
We may change this privacy notice from time to time. You are encouraged to revisit our website from time to time to ensure you are reading the current version of this notice.