Privacy Notice

Your information will be held by KUSHIM France and by KUSHIM USA, which is part of KUSHIM Group (Edda® Trademark). This privacy notice is to let you know how companies within the Group promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice also tells you about your privacy rights and how the law protects you.

Kushim promise

• To keep your personal information safe and private.
• Not to sell your personal information.
• To give you ways to manage and review your marketing choices at any time.

Data Protection law

As well as our Privacy Promise, your privacy is protected by law. Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside KUSHIM Group. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When you consent to it

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This information is called ‘special categories of personal data’. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

• For reasons of substantial public interest, or
• To establish, exercise or defend legal claims.

The ways that we may use your personal information

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

Where we collect personal information from

This section lists all the places where we get data that counts as part of your personal information.

We may collect personal information about you (or your business) from Kushim Group companies and any of these sources:

Data you give to us

This covers data given by you as well as data provided by people linked with you or your business’s product or service, or people working on your behalf.

• When you apply for our products and services
• When you talk to us on the phone or in branch, including recorded calls and notes we make
• When you use our websites, mobile device apps or web chat
• In emails and letters
• In customer surveys

If you take part in our promotions

Data we collect when you use our services

This covers two things: details about how and where you access our services, and account activity that is shown on your statement.

• Profile and usage data
  This includes the security details you create and use to connect to our services. It also includes your settings and marketing choices. We also gather data from the devices you use (such as computers and mobile phones) to connect to the internet, mobile and related services. We also use cookies and similar tracking technologies to collect data while you are using our websites or mobile apps and when you receive, open or respond to emails we send you. You can find out more about this in our cookies policy.

Data from outside organisations

• Companies that introduce you to us
• Social networks and other technology providers
• Firms providing data

We will keep your personal information for as long as you are a customer of Kushim Group.

We may keep your data for up to 5 years after you stop being a customer. The reasons we may do this are:

• To respond to a question or complaint, or to show whether we gave you fair treatment
• To study customer data as part of our own internal research
• To obey rules that apply to us about keeping records.

We will only use your personal information for those purposes and will make sure that your privacy is protected.

The control you have and your rights

You :

• have the right to contact us if you are unhappy with how we have used your personal information. You can contact us:
  
  USA / World:
  Kushim, Inc - 2711 Centerville Road Suite 400 Delaware 19808 County of New Castle USA
  nicolas@kushim.vc
  
  Europe:
  KUSHIM FRANCE a French registered company situated 10 rue de Penthièvre 75008 Paris FRANCE
  nicolas@kushim.vc
• have the right to complain to the regulator if you are not happy with the outcome of a complaint. For French customers this is the CNIL 3 Pl. de Fontenoy, 75007 Paris
• can also withdraw your consent at any time. Please contact us if you want to do so. This will only affect the way we use information when our reason for doing so is that we have your consent ;
• have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it;
• can get a copy of all the personal information we hold about you by filling by writing to us at this address:
  
  USA / World:
  Kushim, Inc - 2711 Centerville Road Suite 400 Delaware 19808 County of New Castle USA
  nicolas@edda.co
  
  Europe:
  KUSHIM FRANCE a French registered company situated 10 rue de Penthièvre 75008 Paris FRANCE
  nicolas@edda.co
  
• can object to us keeping or using your personal information. This is known as the ‘right to object’;
• can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’ ;

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

How personal information is used

We may share your personal information with outside organisations. This is so that we can provide you with products and services, run our business, and obey rules that apply to us. Here we list all the types of organisation that we may share your personal information with.

We may share your personal information with other companies in Kushim Group.

Outside companies we work with to provide services to you and to run our business:

Google Analytics for analytics
Calendly for meeting scheduling
Pipedrive for sales and marketing
Intercom for support
Heap for improving the platform

Sharing data that does not say who you are:

We may share data to other companies outside Kushim Group, but only when it is grouped so that no-one’s identity can be known or found out.

We combine data in this way so we can look for general patterns and trends. When we combine data this way, we use all of the information – including historical data – that we hold about you and our other customers. We do this to learn about the types of customers we have, how they use our products, and how our products perform for them. The law says this is not considered to be personal information after it has been grouped in this way.

How we work out what marketing you receive

We may use your personal information to make decisions about what products, services and offers we think you may be interested in. This is what we mean when we talk about ‘marketing’.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not conflict unfairly with your own interests.

We do not sell the personal information we have about you to outside organisations. We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

Sending data outside France and European Union and European Economic Area

Given the international dimension of the KUSHIM Group, processings mentioned previously may involve the transfer of personal data outside the EEA, whose legislation on the protection of personal data is different from that of the European Union. In this case, these transfers are processed in a manner that guarantees and ensures appropriate security and confidentiality of the personal data.

As such, KUSHIM takes all physical, technical and organisational measures needed to ensure the security and confidentiality of personal data which may be communicated to the official organs and administrative or judicial authorities of a country, particularly in the context of the fight against money laundering and terrorist financing, the fight against the fraud and for the determination of the tax status.

This section tells you about the safeguards that keep your personal information safe and private, if it is sent outside France, European Union and EEA.

We will only send your data outside France, European Union and of the European Economic Area (‘EEA’) to:

• Follow your instructions
• Comply with a legal duty (For example, we share information about US citizens with the US tax authority.)
• Work with our suppliers who help us to run your accounts and services.

If we do transfer your personal information outside the France, European Union and EEA to our suppliers, we will make sure that it is protected to the same extent as in France, European Union and EEA. We’ll use one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as France, UK and EEA.
• Put in place a contract with the recipient that means they must protect it to the same standards as France, UK, European Union and EEA.

How can you keep up with changes to this data protection notice?

In a world of constant technological changes, we may need to regularly update this Data Protection Notice.

We invite you to review the latest version of this notice online and we will inform you of any material changes through our website or through our other usual communication channels.