Background

Kads Cloud Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our website, www.kadscloud.com and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site, and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

Account	Means an account required to access and/or use certain areas and features of Our Site.
Cookie	Means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in below.
Cookie Law	Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003
Personal Data	means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).
We/Us/Our	Means Kads Cloud Ltd, a limited company registered in England under company number 11870054.

Information about Us

Our Site is owned and operated by Kads Cloud, a limited company registered in England under company number 11870054

What does this policy cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

Your Rights

• As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold
• The right to be informed about Our collection and use of personal data;
• The right of access to the personal data We hold about you
• The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us)
• The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, but if you would like Us to delete it sooner, please contact Us)
• The right to restrict (i.e. prevent) the processing of your personal data
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
• The right to object to Us using your personal data for particular purposes; and
• Rights with respect to automated decision making and profiling.
• If you have any cause for complaint about Our use of your personal data, please contact Us and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
• For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

What Data do We collect?

Information you choose to give us.

• When you sign up to our services we collect and store your email address. This is also true if you login via Facebook or your Google account
• After you sign up, you may choose to add more information about yourself and your organisation, such as your first and last name, contact information, property details (including photographs, property expenses and lease details, including rent payments).
• If you contact us, we may keep a record of our correspondence with you. When you contact us for support, our customer representative may attach our support account to view your data if we need to get more information. You can tell us you don’t want us to do this in your support email to support@kadscloud.com.

Personal information that other people give us.

• Where reasonably practical we aim to collect information directly from the person who is the subject of the personal information. However, users may enter personal information about someone else, such as a tenant, landlord or builder. This may include their name, contact information, payments and lease details.
• If you provide Kads Cloud Ltd with personal information about someone else, you must ensure that you are authorised to disclose that information to Kads Cloud Ltd in accordance with applicable data protection or privacy laws. When you make a payment with our payment provider (PayPal or Stripe), we may also collect your registered address and email.
• Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data.
• Name
• Date of birth
• Gender
• Business/company name
• Job title
• Profession
• Contact information such as email addresses and telephone numbers
• Demographic information such as post code, preferences, and interests
• Financial information such as credit / debit card numbers
• IP address
• Web browser type and version and
• Operating system.

Information we observe

Similar to other services, we also automatically collect information through cookies (or similar technologies) and other applications within our services.

• We may record your IP address, the device you use, the date and time, your interactions with our services, and the location of your device
• When you make a payment to us through our services, we may record the details of that transaction and your registered address and email.
• When you send emails via our platform to tenant’s or any other third party, these are also recorded
• Access your information so we can provide you with customised content and experiences, or remember the last page you visited on the Services
• Identify returning users, registrants and subscribers
• Eliminating the need for returning users to re-enter their login details
• Maintain your settings and authenticate your identity while you are logged in to the Services
• To support security measures and to assist in identifying possible fraudulent or abusive activities

Analytical information

We may combine and analyse the information that we have collected (including via Google Analytics). Where possible we will use de-identified information. This means the information is collated in such a way so that it no longer reflects or represents any individual user. However, it is possible that data analytics will create new personal information. For example, insights from data analytics may be applied to a user to understand their preferences and behaviour.

We limit our collection of information via data analytics to ensure that we are only creating personal information that is reasonably necessary for the purposes described below. If personal information is created via data analytics which is not necessary for these purposes, then such information will be either de-identified or destroyed as described below

Why do we collect and what do we do with this information?

We use the information collected so that we may pursue our legitimate business functions and activities. These interests include:

• Carrying out our obligations under any contract between us and our users, including the Terms of Service.
• Personalising the services for you, so that our services are presented in the most effective manner
• Personalising our marketing to you so that you are provided with information about services you may be interested in.
• Understanding our users, and how our product is being used
• Identifying where to make improvements in our products, and to help us deliver new services or products
• To help us develop stronger, evidence-based strategies
• Access your information so we can provide you with customised content and experiences, or remember the last page you visited on the Services
• Identify returning users, registrants and subscribers
• Eliminating the need for returning users to re-enter their login details
• Maintain your settings and authenticate your identity while you are logged in to the Services
• To support security measures and to assist in identifying possible fraudulent or abusive activities.
• Complying with laws and regulations applicable to us
• Complying with our obligations to our third-party service providers
• To protect and enforce our rights, property and interests

We may also use the information collected for such other purposes that are compatible with the original purpose described above, or that you otherwise consented to from time to time.

Kads Cloud may also use and disclose de-identified information (non-personal information) as set out in this Privacy Policy and as we otherwise determine, provided that there is only a low risk that any person could be re-identified from the data. For example, we may disclose information about the average rent or average rental yield in a particular area

How do We use your data?

• All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
• Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
• Providing and managing your Account
• Providing and managing your access to Our Site
• Personalising and tailoring your experience on Our Site
• Supplying Our services to you of facilitating the tenancy process (please note that We require your personal data in order to enter into a contract with you)
• Personalising and tailoring Our services for you
• Replying to emails from you
• Supplying you with emails that you have opted into (you may unsubscribe or optout at any time by clicking on unsubscribe at the footer of the email)
• Market research
• Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
• With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email and/or telephone with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
• Third parties (including Xero, Advance Rent, Zoopla, Rightmove, Experian, Signable) whose content appears on Our Site may use third party Cookies, as detailed below. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
• You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
• We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases): the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below
• When establishing and/or reviewing retention periods, the following shall be taken into account:
• The objectives and requirements of the Company;
• The type of personal data in question;
• The purpose(s) for which the data in question is collected, held, and processed;
• The Company’s legal basis for collecting, holding, and processing that data; and
• The category or categories of data subject to whom the data relates
• If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
• Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).
• In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.

Who might we share your information with?

We will keep all information we hold confidential but may provide information to

• Our professional advisors;
• Our third-party service providers in connection with the provision of our services; and
• Provide information to regulators or other person under applicable laws. We limit the disclosure of information to only that information which is reasonably necessary in connection with the reason for engaging a third parties, and will ensure that such third parties have such security measures in place that, as a minimum, is equal to the protections outlined in this privacy policy.

Information shared with Partners.

De-identified information may be made available to our Partners (see our Terms and Conditions). In general, the purpose of this information sharing is to enable our Partners to analyse whether a user may be interested in a product or service that they offer.

The de-identified information that we share with Partners will be limited to only that information which is reasonably necessary for the Partner to pursue their legitimate functions and activities. We will consider any risks that the Partner will be able to re-identify any person from the information that we share with them (including via the Partner’s legitimate access to other data sets), and the most appropriate data access environment to facilitate the sharing.

Only if you explicitly confirm you wish to be contacted by us or one of our Partners in relation to that offer, will we share your personal information. Arrangements with our Partners will set out our respective roles and responsibilities regarding compliance with applicable privacy laws, in particular how we will comply with the privacy rights of individuals.

Data transfers

We may hold your personal information in the United Kingdom (where our main data centres are located), and India and any other territories as we see fit from time to time. Regardless of where we process your information, we will take appropriate steps to ensure an adequate level of protection for your information.

Links and affiliated websites

Kads Cloud contains hypertext links to other sites, advertisers and other third parties. By clicking on any of these links, you are leaving our services. Kads Cloud has no control over the information collected by any third party after you have left our services, and Kads Cloud encourage you to read their privacy policies.

The data collection and usage practices of any third party linked to Kads Cloud are not covered by this Privacy Policy. Kads Cloud assumes no liability and is not responsible for any practices of such third-party web sites, including their privacy practices or content.

How long do we keep hold of your information?

We keep user’s information as long as you have a subscription with us and have accessed your information within the last 12 months. After 12 months, we reserve the right to delete or de-identify your data. At any time you can request us to delete all data you have entered and all data we hold about you by emailing support@kadscloud.com We will action this request, by either deleting or de-identifying the data, within 7 days’ time from our main database. It will also be removed or de-identified from our backup databases within 30 days.

How do we safeguard your information?

Kads Cloud is committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your personal information is stored on secure servers that have SSL Certificates, and all Data transferred between You and the Service is encrypted. We will advise You at the first reasonable opportunity upon discovering or being advised of a security breach where your personal information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner. However, the internet is not in itself a secure environment and we cannot give an absolute assurance that your information will be secure at all times. Transmission of personal information over the Internet is at Your own risk and You should only enter or instruct the entering of personal information to the Service within a secure environment.

Data breaches

You can email us at support@kadscloud.com any time you wish to find out what information we hold about you. Any such requests will be replied to within 30 days

How and where do We store your data?

• We only keep your personal data for as long as We need to in order to use it as described above, and/or for as long as We have your permission to keep it.
• Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under GDPR including:
• Ensuring that appropriate technical and organisational measures are in place for treating the data safely and securely;
• Obtaining the explicit and informed consent of the data subject to any data transfer; and
• Ensuring that any data transfer is only necessary for the performance of a contract between us and the data subject i.e. for the services to be provided and no other reason; and
• Ensuring that any transfer is necessary for the performance of a contract made in the interests of the data subject between us and another party.
• Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
• Steps We take to secure and protect your data include:

Technical Data Security Measures:

• All emails containing Personal Data must be encrypted;
• All emails containing Personal Data must be marked ‘confidential’
• Personal Data may only be transmitted over secure networks;
• Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
• Personal Data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
• Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
• Where Personal Data is to be transferred in hardcopy form, it should be passed directly to the recipient in accordance with this Policy;
• All Personal Data transferred physically should be transferred in a suitable container marked “confidential”;
• All hardcopies of Personal Data, along with any electronic copies stored on physical media should be stored securely;
• No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
• Personal Data must be handled with care at all times and should not be left unattended or on view;
• Computers used to view Personal Data must always be locked before being left unattended;
• No Personal Data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the DPO and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
• No Personal Data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;
• All Personal Data stored electronically should be backed up regularly with backups stored onsite. All backups should be encrypted;
• All electronic copies of Personal Data should be stored securely using passwords and encryption;
• All passwords used to protect Personal Data should be changed regularly and should must be secure;
• Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
• All software should be kept up to date. Security-related updates should be installed as soon as reasonably possible after becoming available;
• No software may be installed on any Company-owned computer or device without approval; and

Organisational Data Security Measures

• The following organisational measures are in place within the Company to protect the security of personal data:
• All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s GDPR Policy;
• Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;
• All employees and other parties working on behalf of the Company handling Personal Data will be appropriately trained to do so;
• All employees and other parties working on behalf of the Company handling Personal Data will be appropriately supervised;
• All employees and other parties working on behalf of the Company handling Personal Data should exercise care and caution when discussing any work relating to Personal Data at all times;
• Methods of collecting, holding, and processing Personal Data shall be regularly evaluated and reviewed;
• The performance of those employees and other parties working on behalf of the Company handling Personal Data shall be regularly evaluated and reviewed;
• All employees and other parties working on behalf of the Company handling Personal Data will be bound by contract to comply with the GDPR and the Company’s GDPR Policy;
• All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s GDPR Policy;
• Where any agent, contractor or other party working on behalf of the Company handling Personal Data fails in their obligations under the GDPR and/ or the Company GDPR Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Do We share your data?

• In order to provide our integrated services to you, We may be required to share your data with the third parties listed in this Policy.
• In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
• We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
• We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
• We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
• We have the same measures in place as that listed under this policy to ensure that data is kept and held securely if stored or transferred for any reason.
• In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority

What happens if Our business changes hands?

• We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
• In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.

How can you control your data?

In addition to your rights under the GDPR, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing

your details and by managing your Account).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Your right to withhold information

You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

How can you access your data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at support@kadscloud.com or using the contact details below.

Cookies

Our websites and apps use ‘cookies’ and other similar technologies. A cookie is a piece of information placed on your device so we can remember something about you or your device.

Cookies help us monitor and improve our services, and to personalise your experience (including the ads you see on our websites, our apps and elsewhere). You can find out more in our cookie policy.

Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at support@kadscloud.com or by telephone on (0800 002 5850) Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as mentioned above).

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.