Privacy and Cookie Policy

Last Updated: July 15, 2019

Koodoo Global Ltd, a company registered in England no 11320191 ("We", “Our”, "Us” and “Koodoo”) is committed to protecting and respecting your privacy. Koodoo is registered with the UK Information Commissioner's Office (ICO) in the Register of Data Controllers as required by the UK's 1998 Data Protection Act.

This policy (and together with any other documents referred to in it, hereinafter the “Privacy 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. It also describes the choices available to you regarding Our use of your personal data and how you can access and update this information (see "Your rights" section for more details).

By visiting www.koodoo.global and Our mobile application (“Our Site”) you are accepting and consenting to the practices described in this Privacy Policy.

Koodoo may change this Privacy Policy from time to time. Any changes We may make to Our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

How we handle data

We comply with all statutory requirements of the Data Protection Act 1998 by registering all personal data held on Our servers and/or related electronic equipment and by taking all reasonable steps to ensure the accuracy and confidentiality of such information.

The data that We collect from you may be transferred to, and stored at, a destination inside or outside the European Economic Area ("EEA"). It may also be processed by staff operating inside or outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. Access to your information is limited to those who have a need to manage it. Where your information is transferred from the EEA to a country that is not subject to an adequacy decision by the EU Commission, we will seek to ensure that it is adequately protected by (i) ensuring that EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules are in place or (ii) relying on derogations (e.g. contractual necessity). A copy of the relevant mechanism can be provided for your review on request, using the contact details provided below.

Internal Access Policy statement:

“All personal data or sensitive information that is accessed or processed on an external network or stored locally must be encrypted.”

You may request details of personal information that we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please contact us. If you believe that any information we are holding on you is incorrect or incomplete, please email campaigns@koodoo.global. We will correct any information found to be incorrect. For further information please refer to additional instructions in the “Your rights” portion of this policy.

Information we may collect from you

We will collect and process the following data about you:

Information you give us:

This is information about you that you give Us by filling in forms on Our Site or by corresponding with Us by phone, e-mail, responding surveys, or otherwise. It includes information you provide when you register to use Our Site, subscribe to any of Our services and when you report a problem with Our Site.

This information includes contact information such as name, email address, mailing address, phone number, financial information such as bank or brokerage account numbers, unique identifiers such as username, account number, password, date of birth and preferences information such as favorites lists, transaction history, marketing preferences.

Information we collect about you:

With regard to each of your visits to Our Site we will automatically collect the following information: technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting; information about your visit, including the URL, page response times, download errors, length of visits to certain pages, page interaction information.

Information obtained by Us from third parties in accordance with this Privacy Policy:

For example, if you chose to list your business with us, we may obtain additional information from credit reference agencies as a supplementary source.

If you do not want Us to use your data in one or more of the ways mentioned above, please let us know by contacting us at campaigns@koodoo.global or refer to additional instructions in the “Your rights” portion of this policy.

Cookies and Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used or may be used by Koodoo and our partners, including marketing partners affiliates, or analytics service providers and business process service providers. These technologies are used in analyzing trends, administering Our Site, tracking users’ movements around Our Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use or may use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of Our Site. They include, for example, cookies that enable you to log into secure areas of Our Site.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it.

We may also use cookies to estimate our audience size and usage pattern; to store information about your preferences, and to allow Us to customize Our Site according to your individual interests; to speed up your searches; and to recognize you when you return to Our Site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use Our Site, but your ability to use some features or areas of Our Site may be limited.

We may also partner with third party ad networks to either display advertising on Our Site or to manage our advertising on other sites. Our ad network partner may use cookies and Web beacons to collect non-personal data about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by sending us an e-mail to campaigns@koodoo.global and for further information please refer to additional instructions in the “Your rights” portion of this policy. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Additionally, We may use an ad-publishing service to display third party ads on Our Site. When you view or click on an ad a cookie will be set to help better provide advertisements that may be of interest to you on this and other Web sites. You may opt-out of the use of this cookie by visiting the preference managers.

Local Storage Objects (Flash/HTML5): Third parties with whom we may partner to provide certain features on Our Site or to display advertising based upon your web browsing activity may use LSOs such as HTML 5 or Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Security

Koodoo employs a range of security features:

- All data sent in and out of Our servers is encrypted,

- Passwords are securely encrypted,

- Databases are backed-up daily.

You are required and responsible for keeping your password secure and your browser and antivirus up to date.

Disclosure of your information

Koodoo protects your personal information. We will not sell, distribute or lease any of your information to third parties without your permission, unless we are bound by law to do so or permitted by law in order to enforce or apply our Terms and Conditions of Website Use and other agreements; or to protect the rights, property, or safety of Us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

You may remove your personal information and history on any of Our databases at any time, but we retain the right to charge for this work at a nominal rate.

We may also disclose your information to third parties:

- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. You will be notified via email and/or prominent notice on Our Site of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.

- If Koodoo or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

- If you have made an investment or applied to invest in a company via Our Site, your personal data may be disclosed to the company (or the company's professional representatives) that you have invested or applied to invest in. If you request a business plan, follow a campaign or contact a business or entrepreneur via a campaign page your contact details may also be shared with that business or entrepreneur.

Uses of your information

Carrying out Our obligations:

We may use the information you provide to deliver to you the information, products and services that you request from us.

Improving Our products and services:

We may use the information you provide to understand your needs and provide you with improved products and services.

Improving Our website:

We may use the information you provide to customise the service and website per your preferences.

Direct Marketing:

We may periodically send promotional messages about new products, special offers and updates that you may find interesting.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisements to that target audience.

Third Parties that provide service to us:

We may provide your personal data to companies that provide services to help us with the activities described above helping our business activities such as offering customer services or to improve our business operations. These companies are authorized to use your personal data only as necessary to provide these services to us.

Other:

In certain other circumstances we may seek your consent to use your information. In this case we will ask you to confirm your agreement to your information being processed for a specific purpose, either through Our Site of by another means.

How long we retain your information

We will retain your information for as long as your account is active or as needed to provide you services and as required by this Privacy Policy. We will retain and use your information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements, which in some cases involving the collection and processing of financial data may require a retention period of 7 years (or longer if required by law).

Your rights

You have the right to access information that is held about you. A small fee may be payable.

To protect your privacy and security, we’ll take reasonable steps to verify your identity before providing copies of any relevant materials.

You may be entitled to ask Us:

- for a copy of your information;

- to correct or erase your information;

- to restrict or stop the processing information;

- to transfer some of this information to other organisations; and

- where we have asked for your consent to process your data, to withdraw this consent.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

Where we require information to comply with legal or contractual obligations, then provision of such data is mandatory: if such information is not provided, then we will not be able to meet obligations placed on us or manage your transactions on Our Site. In all other cases, provision of requested information is optional.

We hope that we can satisfy queries you may have about the way we process your information and resolve any complaints you may have. We encourage you to come to Us in the first instance, but you are entitled to complain directly to the relevant data protection authority.

How to exercise your rights

You can correct, change or delete your information in your member account setting page. You can stop receiving our newsletters or marketing emails by following the unsubscribe instructions included in these emails or accessing the email preferences in your account settings page. Alternatively, or to access any of the other above rights, you can email by contacting us at campaigns@koodoo.global or by contacting us by telephone or postal mail at the contact information listed below.

Additional Privacy Information

Blog / Discussions

Our Site offers a publicly accessible blog and community discussions. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blog or community discussions, contact us at campaigns@koodoo.global. In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why.

Referrals

If you choose to use our referral service to tell a contact about Our Site, we will ask you for your contact’s name and email address. You must have consent from your contact to provide this information to us. We will automatically send your contact a one-time email inviting him or her to visit the site. Koodoo store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Your contact may contact us at campaigns@koodoo.global to request that we remove this information from our database.

Links to Third Party Sites

Our Site may, from time to time, contain links to and from the websites of our suppliers, partner networks, advertisers, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites should have their own privacy policies and we do not accept any responsibility or liability for these policies or the content or operation of these websites. Please check these policies and the terms of the websites before you submit any personal data to these websites.

Member Directory

Koodoo will build a member directory and We may add you to this. If you wish to request removal of your information or the deletion of an unauthorized profile from our directory, you can contact us at campaigns@koodoo.global.

Profiles

The profile you create on Our Site will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile through your account portal.

Social Media Widgets

Our Site includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on Our Site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on Our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Single Sign-On

You can log in to Our Site using the sign-in service such as LinkedIn, Facebook and Google. These services will authenticate your identity and provide you the option to share certain personal data with us such as your name and email address to pre-populate our sign-up form. Services like LinkedIn, Facebook and Google may give you the option to post information about your activities on Our Site to your profile page to share with others within your network.

Communicating with Us

If you wish to make a notification to Us, or have any questions about this Privacy Policy,

you can reach us by sending a letter to:

Data Protection Team

Koodoo

14 David Mews

London, England, W1U 6EQ

United Kingdom

or by sending an email to campaigns@koodoo.global

Unsubscribing from Koodoo e-newsletters:

Every Koodoo newsletter contains an unsubscribe link. Alternatively, if you no longer wish to receive our marketing updates, you can unsubscribe here.

Have a question?

We’ve created a support centre that has guides and FAQs to help answer any questions you might have about Koodoo.

Risk Warning

Investing in start-ups and early stage businesses involves risks, including illiquidity, lack of dividends, loss of investment and dilution, and it should be done only as part of a diversified portfolio. Cryptocurrency investments carry substantial risk of loss and are not suitable for all investors. Anyone investing using cryptocurrencies can be impacted by volatility in the price of the crypto asset that are typically larger than price swings of fiat currency and investments made using cryptocurrencies are more open to cyberattacks and theft, with no way to retrieve lost or stolen funds. Koodoo is targeted at investors that meet categorisation and appropriateness requirements and investors should make investments at their own risk and ensure that appropriate financial advice is sought if necessary. Investors should only invest a proportion of their available investment funds through Koodoo as these investments are high risk.

Please click here to read the full risk warning. Koodoo Global Ltd is an Appointed Representative of Sapia Partners LLP, which is authorised and regulated by the Financial Conduct Authority (FRN 550103). Campaigns are not offers to the public and investments can only be made by members of Koodoo on the basis of information provided in the campaigns. Sapia Partners LLP and Koodoo Global Ltd take no responsibility for the accuracy of this information or for any opinions made by the campaign companies.

The availability of any tax relief, including EIS and SEIS, depends on the individual circumstances of each investor and of the company concerned. This is only available for UK investors in qualifying companies and may be subject to change in the future. If you are in any doubt about the availability of any tax reliefs, or the tax treatment of your investment, you should obtain independent tax advice before proceeding with your investment.

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