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1. Introduction
Commitment to Privacy:Kuuka Technologies Limited (“Kuuka”) is committed to protecting your personal data in accordance with applicable data protection laws, including GDPR. This policy explains how we collect, use, and safeguard your information when you use our Digital Products.
2. Information We Collect
Personal Identification Data:
- Name, email, phone number, and address.
Business Data:
- Business name, company number, VAT number, bank details, and supplier/product information.
Financial Data:
- Payment details (tokenized, not raw card data) via PCI-compliant third-party processors.
Risk & Credit Data:
- Credit scores and risk assessments (from internal AI models and third-party bureaus).
Usage Data:
- Data collected automatically (IP address, transaction history, app usage).
Voice & AI Interaction Data:
- Voice recordings and chat logs used for AI processing, which can be deleted upon request.
3. Legal Bases for Processing
Consent:
- For marketing communications and optional data collection.
Performance of a Contract:
- Necessary for service delivery, payment processing, and compliance.
Legitimate Interests:
- For risk assessments, AI model training, system security, and improving our services.
Compliance:
- To meet legal obligations, such as GDPR, PCI, and FCA regulations.
4. How We Use Your Information
Service Provision:
- To facilitate transactions, manage orders, and provide customer support.
AI & Analytics:
- To generate risk scores, dynamic pricing models, and predictive inventory management.
Marketing:
- To inform you about promotions and updates, with options to opt out.
Legal Compliance:
- To retain data as required for financial, tax, and audit purposes (e.g., 7 years for transaction data).
5. Data Sharing and Transfers
Internal Sharing:
- Within Kuuka and its group companies for operational purposes.
Third-Party Providers:
- With trusted partners for payment processing, data analytics, and IT services.
International Transfers:
- Data may be transferred outside the EEA/UK with appropriate safeguards (SCCs or UK Addendum).
Legal Requirements:
- We may disclose data to comply with legal obligations or to protect our rights and the safety of our users.
6. User Rights
Access and Portability:
- You have the right to access and export your personal data.
Rectification and Deletion:
- Request corrections or deletion of your personal data, subject to legal retention obligations.
Objection and Restriction:
- You may object to certain processing activities, including automated decision-making.
AI Opt-Out:
- Request human intervention in AI-driven decisions.
Contact:
- For data requests, contact our DPO at [INSERT EMAIL ADDRESS].
7. Security Measures
Data Protection:
- We employ encryption, access controls, and regular audits to safeguard your data.
Data Breach Procedures:
- In the event of a breach, we will notify affected users within 72 hours as required by law.
8. Data Retention
Objection and Restriction:
- Personal and financial data is retained as long as necessary to fulfil contractual and legal obligations (e.g., 7 years for financial records).
Anonymisation:
- Data used for statistical purposes is anonymised.
9. Changes to this Policy
Policy Updates:
- We may update this policy periodically. Significant changes will be communicated through our website and your account notifications.
Effective Date:
- The current policy is effective as of [INSERT DATE].
10. Contact Information
Questions or Concerns:
- Please contact our Data Protection Officer at [INSERT EMAIL ADDRESS] for any inquiries related to your personal data