Introduction

This Privacy Policy explains how we use personal information we collect about you when you use our website, our software and our apps. This Privacy Policy covers:

• what personal information we collect about you
• how we use that information
• who we may share that information with
• the choices that you have about how we can make use of that information
• how to access and update your information

We are Kudos Software Ltd, and we are the controller responsible for your personal data. We own and operate the following content and services, and this Privacy Policy applies to them:

• the website at www.kudos-software.co.uk; and
• the following mobile and desktop applications (“apps”):
  • Kudos Desktop Software version 10.3.24 (which was last updated on 20/01/2025)
  • Kudos Web Head Office Software version 10.3.24(which was last updated on 20/01/2025)
  • Kudos Apps:
    • Drive version 1.41 (which was last updated on 18/09/2024);
    • SignUp version 1.56 (which was last updated on 06/03/2025);
    • Stock version 1.9 (which was last updated on 26/09/2024);
    • POS app version 1.24 (which was last updated on 17/03/2025); and
    • Charity Card version 1.14 (which was last updated on 20/02/2025)
  • SignUp Web version 10.3.24 (which was last updated on 20/01/2025);
  • EBooker version 10.3.24 (which was last updated on 20/01/2025);
  • Api Access version 10.3.24 (which was last updated on 20/01/2025)

 

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

We updated our Privacy Policy on 25/03/2025.

Contact details

Our full details are:

• Full name of legal entity: Kudos Software Ltd
• Title of data privacy manager: Data Security Officer
• Email address: admin@kudos-software.co.uk
• Postal address: First Floor Office Suite, Higher Mill, Higher Mill Lane, Buckfastleigh, TQ11 0EN
• Telephone number: 01364 701450

Our Legal Basis for Using your Information

The law only allows us to use your personal information in certain limited circumstances.  Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:

1. Where you have consented to us using your personal information

Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

2. Where we need to perform the contract we have entered into with you

Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract. Examples of how we may use your information in order to comply with a contract that we have entered into with you:

• To provide the information or products you have requested
• To provide the services you have requested

3. Where it is necessary for our legitimate interests

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. 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. 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. We may provide you with marketing information about our own products and services similar to those that you have purchased or enquired about (unless you tell us to stop). We may also record telephone calls for quality and training purposes.

4. Where we need to comply with a legal obligation

Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order. An example of how we may use your information to fulfil a legal obligations:

• Keeping records for tax purposes

 

Information we collect about you

Information you provide

We may collect personal information about you when you fill in one of our forms in our software, apps or on our website or when you place an order for our products or services. We also collect information in order to provide training on our products or services and to provide you with support when using our products and services.

To make it easier for you to use this privacy notice, we group these into the following categories. Each of these categories is described in more detail.

Description of categories of personal data

• Identity Data: first name, last name, title, date of birth and Profile Data.
• Contact Data: first name, last name, contact address, email address and telephone numbers, your communication preferences and copies of the communications between you and us.
• Profile Data: your email address, username and password.
• Transaction Data: billing and delivery addresses, payment card details, bank details, history of your payments, purchases, deliveries, returns and refunds and the applicable terms and conditions of your purchases.
• Device Data: the type of device you use, your unique device identifier, the type of mobile browser you use, IP address, time zone setting, and device location.
• Content Data: information that you store or generate in our website, or software and our apps, being [photos, videos and associated metadata, check-ins, posts and messages.
• Usage Data: logs and detail of your use of our website, or software, our apps and services, being the dates and times on which you download, access and update the website, software, apps and services, any error or debugging information, and the resources that you access and the actions we and you take in relation to them and Cookies Data.
• Security Data: information we collect about your use of the website, software, apps, our services and our sites in order to ensure your and our other users’ safety and security, being Usage Data, the Cookies Data generated by website functions, third party functions, anonymous visitor statistics, advertising cookies, remarketing cookies, authentication, anti-forgery protection and cookie consent and the information provided to us by our payment processing provider.
• Cookies Data: the information collected through the cookies and similar technologies listed in our Cookies Notice available here https://www.kudos-software.co.uk/cookie-policy/.
• Direct Marketing Data: your direct marketing preferences, consents for receiving direct marketing from us and the history of the direct marketing communications we have sent to you.
• Location Data: your current location as disclosed by GPS technology Wi-Fi connections, your IP address for the time period where you have permitted us to collect it.
• Feedback Data: your feedback and survey responses.
• Personalisation Data: Cookies Data (in respect of advertising cookies and remarketing cookies), Device Data, Content Data, Transaction Data, Connected Data, Social Media Data, Usage Data, Location Data, and the preferences we have inferred you have and use to personalise the website, software, apps and services, enabling us to tailor our solution offering to you.
• Competition Data: information about the competitions you enter with us, being your competition history, the applicable terms and conditions, associated third parties and any additional privacy notices.

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). We do not collect data relating to criminal offences.

 

How is your personal data collected?

Information we collect automatically

When you visit our website or use our software or apps or services, we may collect certain information automatically. We collect your personal data in the following way:

• We collect your Identity Data and Contact Data when you register your account with us.
• When you communicate with us via email, telephone, one of our online forms or chat we collect your Contact Data. If the communication relates to an error or problem you are having with the website, software, apps or one of our Services, we will also collect Usage Data for diagnosis and improvement.
• Information you generate when using our website, software, apps and services. Each time you access and use our website, software, apps and services we collect Content, Device, Cookies, Personalisation and Usage Data. We collect Content Data where you upload it to the website, software or apps or interact with the content available on the website, software or apps. We collect Device, Cookies, Personalisation and Usage Data by using cookies and other similar technologies. Please see our cookie notice https://www.kudos-software.co.uk/cookie-policy/ for further details.
• Information we collect through monitoring the use of our website, software, apps, sites and services. Each time you access and use our website, software, apps and services we collect information about that access and use, being Device, Content, Cookies, and Usage Data.
• Additional information we otherwise collect through our website, software, apps, sites and services where we have your consent to do so. Where you provide your consent and where configured for your use, we collect your Location Data on an ongoing basis while you have the apps installed on your device.
• Direct Marketing. We collect and record Direct Marketing Data when we add you to our marketing database, you request to change your direct marketing preferences, or you interact with our direct marketing communications, or we receive prospect information from our data broker partners.
• Information we receive from third parties and publicly available sources. We will receive personal data about you from the third parties and public sources set out below:
• Device and Cookies Data from the following parties:
• analytics providers being the Google Play Store and the IOS App Store based in the USA; and
• industry bodies and event organisers such as the CRA, the Reuse Network, Hospice UK and Circular Communities Scotland, all based in the UK;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Opayo based inside the UK;
• Identity and Contact Data from publicly available sources such as your website, Companies House and the electoral register based inside the UK.
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Website usage information is collected using cookies and other tracking technologies. Further information on our use of cookies can be found at https://www.kudos-software.co.uk/cookie-policy/.

Information we collect from other sources

We work closely with third parties (e.g.: business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.  The organisations we work with include:

• Azure – cloud data storage services (www.azure.microsoft.com/en-gb)
• Sage – accounting software (www.sage.com)
• Access Dimensions – accounting software (theaccessgroup.com)
• Royal Mail
• Elavon / Opayo

There may be other organisations we work with, please contact us at admin@kudos-software.co.uk for the current list.

We may also collect information publicly available about you on your website.

How we use your information

Providing our services, software, apps and website

Delivery and improvement of our website, software, apps or services

Purpose or activity	Type of personal data	Lawful basis for processing
To permit you to install the software or apps and register you as a new website, software or app user	Identity Contact Financial Device	Both for Performance of a contract, and Legitimate interests (delivering our website, software, apps or services to you)
To take steps towards providing you with services at your request, to process and fulfil in-website, software or app orders/purchases and deliver services to you, including managing payments and sending you service communications	Identity Contact Transaction Device Location	Performance of a contract
Enforce our terms and conditions, including to collect money owed to us	Identity	Legitimate interests (to recover debts due to us)
To enable you to communicate, collaborate and share files with other users when you chose to do so	Identity Contact	Both for Performance of a contract, and Legitimate interests (delivering our website, software, apps or services to you)

Account management and profiling

Purpose or activity	Type of personal data	Lawful basis for processing
Combining the information we collect about you into a single customer account profile	Contact Direct marketing	Legitimate Interests (to publicise and grow our business)

Direct marketing

Purpose or activity	Type of personal data	Lawful basis for processing
To send you direct marketing communications via email, text and/or push notification	Contact Device Direct Marketing	Consent Unless we can rely on the soft opt-in and you have not opted out, in which case we rely on Legitimate Interest (to publicise and grow our business)
To send you direct marketing communications by telephone or post	Contact Device Direct Marketing	Legitimate interests (to publicise and grow our business) Unless you have opted out, in which case we rely on Consent

Troubleshooting, improvement and security

Purpose or activity	Type of personal data	Lawful basis for processing
To administer, monitor and improve our business, website, software and apps including troubleshooting, data analysis and system testing, To gain your feedback about your experience of our software, apps, website and services;	Identity Contact Device	Legitimate interests (for running our business, provision of administration and IT services, network security, maintaining the security of our website, software apps and services, providing a secure service to users and preventing fraudulent and other misuse of our website, software, apps and services)
Applying security measures to our processing of your personal data, including processing in connection with the website, software and apps	All personal data under this privacy notice	Legal obligation (applying appropriate technical and organisational measures under Article 32 of the UK GDPR and the EU GDPR)
Otherwise monitoring use of the website, software and apps and deploying appropriate security measures	Contact Security Transaction	Legitimate interests (running our business, provision of administration and IT services, network security, maintaining the security of our website, software and apps and services, providing a secure service to users and preventing fraudulent and other misuse of our website, software and apps)

Rights and obligations

Purpose or activity	Type of personal data	Lawful basis for processing
To comply with our other legal obligations, including contractual obligations, compliance with tax legislation, judicial, law enforcement and government authorities’ requests	All personal data under this privacy notice	Legal obligations under UK and EU law

Cookies and personalisation

Purpose or activity	Type of personal data	Lawful basis for processing
To deploy and process personal data collected via Cookies, as set out in the cookies policy at https://www.kudos-software.co.uk/cookie-policy/	Cookies	Legitimate interests (delivering and securing the website, software, apps and our services)
To deploy and process personal data collected via Cookies that are not strictly necessary, as set out in the cookies note https://www.kudos-software.co.uk/cookie-policy/	Cookies	Consent
To deliver (personalised) advertisements to you	Personalisation	Consent

Other communications

Purpose or activity	Type of personal data	Lawful basis for processing
To notify you of changes to the website, software, apps, services, your purchases and our terms and conditions for ongoing contracts	Contact	For ongoing or prospective contracts, Performance of a contract Otherwise, Legitimate interests (in servicing our users and prospective users)
To notify you of updates to this privacy notice	Contact Transaction	Legal obligation (to inform you of our processing under Articles 13 and 14 of the UK GDPR and the EU GDPR)
To respond to your requests to exercise your rights under this notice	As relevant to your request	Legal obligation (complying with data subject requests under Chapter 3 of the UK GDPR and the EU GDPR)
To enable you to participate in a prize draw or competition (where applicable, please also see the separate prize or competition privacy notice)	Contact Direct Marketing Competition	Legitimate interests (in growing and publicising our business) Unless you have previously opted out, where we will rely on Consent Performance of a contract (once you have entered)
To ask you to complete a survey and process your response (where applicable, please also see the separate privacy notice)	Contact	Legitimate interests (to analyse how users use our products or Services and to develop them and grow our business) Unless you have previously opted out, where we will rely on Consent
To otherwise respond to your enquiries, fulfil your requests and to contact you where necessary	As relevant to your enquiry or request	Legitimate interests (service our users and prospective users)

Personal data sharing

Purpose or activity	Type of personal data	Lawful basis for processing
Share personal data with our third-party providers for purposes not otherwise set out above (see Disclosures of your personal data)	Contact	Legitimate interests for the purpose relevant to the recipient, as set out at “Disclosures of your personal data”

Business contacts

Purpose or activity	Type of personal data	Lawful basis for processing
Process personal data relating to staff members of our business contacts, including suppliers, customers and prospects	Contact	Legitimate interests (servicing and receiving products or services, to or from our business contacts and carry out our B2B business)

 

Legal Requirements and Law Enforcement

We may also disclose your personal information to third parties:

• If we sell our business in which case the personal information that we hold will be part of the transferred assets
• If we are required by law, or in order to enforce or apply our terms of use. This includes exchanging information with other organisations for the purposes of fraud protection and credit risk reduction

Our Marketing

We may provide you with information about products, services, special offers, and other news where we feel these may interest you.

Depending on what contact information you have given to us, we may contact you by email or post, phone. We will only do this where you have consented to receiving such information from us.

You can opt out of such marketing at any time and if you wish to opt out, please email us at sales@kudos-software.co.uk or follow unsubscribe preferences.

Information Sharing

We may share your personal data with the following third parties:

• Your Appstore Provider and mobile network operator to allow you to install the Apps.
• Service providers based in the UK who provide IT and system administration services, hosting services for our website, software, apps, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
• Our professional advisors based in the UK including lawyers, auditors, insurers and consultants who provide legal, accounting, and insurance services.
• Your service providers that you have appointed, and we need to contact to fulfil your requests, such as your banking or payment card provider to process your transactions.
• Marketing and promotional partners and co-operatives based in either the UK or EEA with whom we share data to enhance our offerings and identify prospective customers.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties acting as controllers based in the UK where necessary to exercise our rights or comply with a legal obligation.
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, including IT Protocol and Elavon
• Analytics and search engine providers that assist us in improving and optimising your use of our apps and our website
• With other users you chose to share files, documents, photos and other materials

 

Third Party Privacy Policies

Our software, apps and website may contain links to and from the websites owned by third parties.  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 information to these websites.

 

International transfers

Where we transfer your personal data between the UK and the EEA those transfers are made pursuant to the UK government’s adequacy decision in favour of countries in the EEA and the European Commission’s adequacy decision in favour of the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers located outside the UK, we use specific contracts approved by the UK which give personal data the same protection it has in the UK.

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

Data storage and security

All information you provide to us is stored on our secure servers and located in the UK (Southern England). Any payment transactions carried out by us, or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, apps or services, 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 protect your personal data from loss, unauthorised use or access.

We will collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technology.

We have put in place procedures to detect and respond to personal data breaches and notify you and any applicable regulator when we are legally required to do so.

 

Retention of Information

We only hold your personal information for as long as necessary for the purposes for which we collected your information.  We have a retention policy which lays down timescales for the retention of information.

The relevant data retention periods can be found below:

Type of documents	Description of document	Retention period
Marketing database	Name and contact details of people expressing interest in our goods and services.	Up to one year from last contact
Order database	Name and contact details of all customers including emails, addresses and payment information	One year after last order
Telephone records	Date times and contents of incoming and outgoing telephone calls	30 Days

 

Emails

If you chose to send us information via email, we cannot guarantee the security of this information until it is delivered to us.

Your Rights

You have the following rights under data protection laws in relation to your personal data.

• Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
• Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us).
• Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. (In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.) You can request the erasure of your personal data by email to admin@kudos-software.co.uk or by contacting us by phone and asking to speak to our Data Security Officer.
• Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
• Restriction. Request that we restrict or suspend our processing of your personal data:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Data portability. Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
• Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, 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.
• Complain to the UK data protection regulator. If you are unhappy with how we process your personal data, we ask that you contact us first so that we have the chance to put it right. Our internal complaints procedure allows your request to be reviewed by our Managing Director who will do their best to try and resolve the issue. However, you also have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time.  They can be contacted as follows:

 

Website:           www.ico.org.uk

Telephone:        0303 123 1113

Address:           Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

 

You can exercise any of these rights at any time by contacting us at admin@kudos-software.co.uk.

 

 

Automated decision making and profiling

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

 

Changes to our Privacy Policy

We review our Privacy Policy on a frequent basis to check that it accurately reflects how we deal with your information and may amend it if necessary.  You should check this page regularly to see the most up to date information.

How to Contact us

We welcome questions, comments and requests regarding this Privacy Policy which can be sent to admin@kudos-software.co.uk.