Website Privacy Notice
About this notice
This Privacy Notice is intended to inform you (“you”, “your”, “yours” or “yourself”) how Kudo Energy Limited (registered number SC267933) whose registered office is at The Green House Forrest Estate, St John's Town Of Dalry, Castle Douglas, Dumfries & Galloway DG7 3XS, Scotland ("we”, “us” or “our”) will collect and use your personal data when you do any of the following:
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Visit and browse our website www.kudosoftware.com.
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Supply your personal data to us including through our website, in writing, and verbally.
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Communicate with us in any way, either directly or in response to a communication from us, including by email, direct message, video chat, phone, and text.
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Submit your personal data to us with the intention that we may use it to contact in future in connection with our services, when you order or buy any of our services, including any modification, cancellation or similar activity.
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Register and sign up for our newsletter or sign up for a promotion or special offer.
Please read this Notice carefully as it contains important information on your rights in relation to your personal data, and how to contact us or supervisory authorities, in the event you have a complaint.
Personal data we collect about you
The personal data we collect about you depends on whether you are, or may be, a customer or a supplier, personnel of a customer or a supplier, a private individual, or you are browsing our website (in whichever capacity). In each case, we will collect and use some or all of the following personal data about you:
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect most of this personal data directly from you, but we may also collect information:
• from publicly accessible sources, e.g. Companies House
• from your company website(s) and other online sources
• from cookies on our website. See our Cookie Policy for more information.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of another.
We have a legitimate interest when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and why
Marketing
We have a legitimate interest in using the personal data of personnel who work for a customer or supplier for marketing purposes. This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
We give such personnel the right to opt out of receiving marketing communications at any time by sending an email to support@kudosoftware.com.
We may ask commercial personnel to confirm or update marketing preferences if they ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat personal data with the utmost respect and never sell or share it with other organisations.
Who we share your personal data with
Where necessary we routinely share personal data with:
• External hosting providers for the administration of our website, for example our video chat host and our newsletter distributor.
• Mailing houses: we transfer your name and address to mailing houses to send out brochures.
• Our affiliates and companies in the Natural Power family of companies, who may use your information in the same way as we can under this notice.
• Our professional advisers, our insurers, bank(s) and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.
• Members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency (anonymised where possible).
We only allow those organisations to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data.
TWIPLA
TWIPLA is a website analytics service that measures traffic on our website and collects general information from our website visitors. We create statistics to improve the experience of our website visitors. We never use cookies for this purpose. As a website operator using TWIPLA to conduct reach measurement, depending on the level of data protection we have activated, we may process information about the device you are using and its characteristics, information about technical characteristics of the website visit, the number of page visits and statistically relevant behavior of our website visitors. The technology does not use the collected data to identify individual visitors or to match the data with additional information about an individual user. Depending on the location from which you access our website, TWIPLA may not collect any information about the device you are using due to our technical settings.
Artificial Intelligence (AI) Tools
We use AI tools which utilise large language models (LLMs), a type of artificial intelligence algorithm that uses deep learning techniques to understand, summarise, predict, and generate content.
The personal data used in AI tools is limited to the categories of personal data shown in the table above. We restrict how much personal data is processed by AI tools and avoid using any sensitive personal data, such as health or disability information, where we can. If we need to process special category (sensitive) information about you, we will seek your consent before doing so unless an exemption applies. We may, for example, process your sensitive information in an emergency if you are unable to give consent yourself. An exemption also applies if we need to establish, exercise, or defend a legal claim or for judicial proceedings.
AI Tools help us to improve the efficiency, quality, and speed of our business processes. We carry out a number of these processes already but using AI to automate these activities allows us to optimise our resources. For example, AI can help us by summarising information (such as in emails, Teams chat messages and meeting transcripts, documents) and prepare for meetings, create and format documents, analyse data such as public consultation responses, and generate draft emails or presentations. AI also assists with notetaking and idea generation to support efficient communication and decision-making.
Any data, used in AI is stored and stays within our secure UK Microsoft 365 and Azure tenants, and is not used for training foundation models.
Where we use your personal data, it is processed under the lawful basis of legitimate interest to enhance and improve response times and efficiency, for example in relation to service delivery, complaint handling, providing you with guidance, or investigating a breach. Alternatively, we may use your information in order to enter into and/or perform a contract with you.
We use AI tools to assist our staff do their job and we do not solely use AI to make automated decisions. Our policy requires that there is always a human intervention to review and approve outputs from the AI tools.
We will continue to monitor our use of AI tools to review the risks and benefits of this deployment. Any extension of our use will be considered under our risk assessment processes and this privacy notice will be updated accordingly.
We or the third parties mentioned above occasionally also share personal data with:
• Our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations.
• Our and their professional advisers (such as lawyers and other advisers), in which case the recipient of the information will be bound by confidentiality obligations.
• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.
• Other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency - usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above.
Some of these third parties may be based outside the UK[/EEA]. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK[ and EEA]’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you no longer have an account with us, you no longer provide goods and/or services to us or we are no longer providing goods and/or services to you, we will delete or anonymise your data after 2 years.
Transferring your personal data out of the UK and EEA
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Your rights
You have the following rights, which you can exercise free of charge:
For more information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
• Email, call or write to us; see ‘How to contact us’ below
• Provide enough information to identify yourself and any additional identity information we may reasonably request from you;
• Let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
If you are unhappy with how we handle your personal data, you have the right to lodge a complaint. We will acknowledge your complaint within 30 days and aim to resolve it without undue delay. Please contact us using the details in the ‘How to contact us’ section below.
If you are dissatisfied with our response, you also have the right to lodge a complaint with:
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the Information Commissioner in the UK; and
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a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
How to contact us
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details
The Green House Forrest Estate, St John's Town Of Dalry, Castle Douglas, Dumfries & Galloway, DG7 3XS
+44 (0) 1644 430 008
Our Data Protection Officer's contact details
Fred. Olsen House, White House Road, Ipswich, IP1 5LL
dataprotection@fredolsen.co.uk
07826 924470
We have appointed Natural Power Consultants (Ireland) Limited to be our data protection representative within the EEA. They can be contacted at Suite 6, The Mall, Beacon Court, Sandyford, Dublin 18, D18 A3W8, Ireland.
Changes to this Notice
We may change this privacy notice from time to time. You are encouraged to revisit our website from time to time to ensure you are reading the current version of this notice.