Privacy & Cookies Policy
1 General principles
Blukudu is committed to safeguarding the privacy of your information. This privacy notice provides you with the details of how we collect and process your personal data, including through your use of this site. By providing us with your data, you warrant to us that you are over 13 years of age.
Blukudu Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, please contact us using the details set out below:
85 Great Portland Street
Email address: firstname.lastname@example.org
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing or writing to us using the details provided above.
2 The data we collect about you, for what purpose and on what ground we process it
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to the supply of our services to you, or the procurement of services from third parties to us such as your name, title, billing address, delivery address, email address, phone number, other contact details and account details. We process this data to supply the services to you or to pay for services provided to us and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. We may use Customer Data to deliver relevant website content and advertisements to you (including LinkedIn or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in new services we may offer you, our promotions such as competitions and surveys, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may process your personal data without your knowledge or consent where this is required or permitted by law. Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to provide our services to you). If you don’t provide us with the requested data, we may have to cancel a service but if we do, we will notify you at the time. We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We do not process the following categories of personal data about you:
- User Data. We do not collect any User Data. User data includes data about how you use our website and any online services together with any data that you post for publication on or through online channels.
- Technical Data. We do not collect any Technical Data. Technical data includes data about your use of our website and online services such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website.
- Sensitive Data. We do not collect any Sensitive Data about you. Sensitive data refers to data that 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 also do not collect any information about criminal convictions and offences.
- We do not carry out automated decision making or any type of automated profiling.
3 How we collect your personal data
We may collect data about you by you providing the data directly to us (for example by filling in a form on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
We may receive data from third parties such as analytics providers based outside the EU, advertising networks such as LinkedIn based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4 Marketing communications
Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). You may receive marketing communications for a number of reasons: you have previously expressed an interest in the topic of one of our communications or our services; from our research we have identified you to have an interest in the content of our communications; we have had some previous connection, correspondence or relationship.
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if (i) you are a recipient of our services or asked for information from us about our services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications. Under these regulations, if you are a limited company, we may send you marketing emails without your consent, however you can still opt out of receiving marketing communications from us at any time.
Before we share your personal data with any third party we will get your express consent.
You can ask us (by emailing firstname.lastname@example.org) to stop sending you marketing messages at any time or by following the opt-out links on any marketing message sent to you.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as paying for our services.
5 Disclosure of your personal data
We may have to share your personal data with the parties set out below:
- A client, partner or sponsor of a Blukudu service that you may be interested in or have asked us to supply to you, such as a trade mission or Fintech programme we run on behalf of a government or public sector body;
- Service providers who provide IT and system administration services;
- Professional advisers including lawyers, accountants, auditors and insurers;
- Government bodies that require us to report processing activities;
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6 International transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Some of our third parties service providers (for instance secure cloud based data storage services) are based outside the European Economic Area (EEA) so the processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7 Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what is the correct time to keep the data we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8.1 What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. The cookie can be read by the website that created it when you visit that website again. Cookies are either session cookies that are only stored on your computer during your web session and are automatically deleted when you close your browser (they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer) or Persistent cookies that are stored as a file on your computer and it remains there when you close your web browser. Types of cookies can be classified into one of three categories, namely Strictly necessary, Performance and Functionality cookies. Cookies are useful because they allow a website to recognise a user’s device. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests based on information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes. Cookies are used by nearly all websites and do not harm your system.
8.2 What types of cookies do we use?
This website only uses Strictly necessary and Performance cookies. We do not capture, use or store any information from these cookies.Strictly necessary cookies
These cookies are essential in order to enable you to navigate our website effectively and access content, and therefore cannot be turned off. Without these cookies, services available to you on our site cannot be provided. These cookies do not gather information about you that can be used for marketing or remembering where you have been on the internet.Performance cookies
These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify which pages visitors go to most often, and if they get error messages from web pages. The information collected is anonymous and is only used to improve the performance of our websites.Functionality cookies
Although we do not use this type of cookie we have described them here for information purposes. This type of cookie allows a website to remember the choices you make and provide enhanced features. For instance, to provide you with news or updates to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. These cookies can also be used to remember customisation changes that you may make (for example text size or fonts). The information these cookies collect is usually anonymised and cannot be used to track your browsing activity on other websites. Without these cookies the website will not be able to remember choices that you have previously made or personalise your website browsing experience.
8.3 How to control and delete cookies through your browser
You have the ability to enable, disable or delete cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. In order to do this follow instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility). Please note that if you set your browser to disable all cookies (including Strictly necessary cookies), you may not be able to access certain areas of the website. Further information on how to amend your cookie preferences through your browser is available at the external website www.allaboutcookies.org
8.4 What happens to cookies that have been set in the past?
If you have disabled one or more cookie categories, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information.
8.5 Use of web beacons
We do not use web beacons. For information purposes, web beacons are usually a small image that makes up the webpage you want to view and the request to view that image is then logged by the server/computer we store that image on. The request for the image from your browser allows us to know simple information such as the IP address of the computer wanting to view the image, the time the image was viewed, and the type of browser viewing the image.
9 Your legal rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. You can read more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
11 Contact us
If you have any questions about our Privacy & Cookies Policy please email us at firstname.lastname@example.org. Please do not include any confidential personal information within your email.