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1. INFORMATION WE COLLECT

Identity and contact details

Name, address, email address and phone number

Purchase related information

• Transaction details from the receipts you upload to our mobile application (App), including the store details, order date and time and item description
• Details of your physical K-card when you scan your K-card for a retail purchase

App related information

• Transaction details from your use of our App or enquiries about our App
• Performance details from your completion of any quests under our App
• Your preferences for our App and your marketing preferences and where relevant information related to loyalty programmes
• Feedback, complaints and compliments and survey responses

Financial and payment information

Payment details for redeeming any Koins from us and where relevant banking information

Digital information

• IP address and general location information derived from your IP address
• Device identification
• Search and browsing behaviour and user journeys
• Website usage patterns
• Cookie preferences and tracking

Information about your right to work in the UK

Sometimes we remove identifying details from your data to make it anonymous. Anonymous data cannot identify you personally, so it's not covered by this privacy policy. We also use pseudonymised data, which has identifying details removed but could still identify you if it is combined with other information. Pseudonymised data remains your personal data and is protected under this policy. We use pseudonymisation to enhance security when sharing data with partners or conducting analysis.

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2. HOW WE COLLECT PERSONAL DATA

Directly from you when you: upload receipts on the App, complete quests on the App, or otherwise when you interact with us, contact us, fill out forms.

Automatically when you: visit our App or website, use our technologies, including the K-card at participating retail stores, or interact with our App.

From third parties: service providers, business partners, government organisations and organisations or people authorised by you.

From publicly available sources: such as Companies House and professional networking sites such as LinkedIn.

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3. HOW WE USE YOUR INFORMATION

Data protection law requires us to have proper legal reasons for using your personal data. We can only use your information when we have one or more of these legal bases.

• Consent - You have clearly agreed to us using your personal data for a specific purpose.
• Performance of a contract - We need to use your information to fulfil a contract with you, or because you've asked us to do something before entering into a contract.
• Legal duty - We must use your information to comply with the law.
• Vital interests - We need to use your information to protect someone's life.
• Public interest - We need to use your information to perform a task in the public interest or carry out official functions that have a clear legal basis.
• Legitimate interests - We have a genuine business reason to use your information, or a third party does, but only if this doesn't unfairly override your rights and interests. Where we rely on legitimate interests as our legal basis, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms.

These assessments consider:

• The nature of our legitimate interest
• The impact on you
• Any safeguards we can implement
• Your reasonable expectations
• The broader context of our relationship

Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. We have listed the reasons we process your data and the legal basis below. Please reach out to us if you need further details about the specific legal basis we are relying on to process your personal data.

Managing your account and providing our services

What we use your information for:

• To enable you to access and use our App, including providing login credentials
• To provide our services to you, including allowing you to earn Koins, allowing you to scan your K-card at participating retail stores, providing you the opportunity to redeem your Koins through the provision of a reward
• To contact and communicate with you about our services, including responding to support requests and enquiries and for dealing with complaints or claims
• Internal record keeping, administrative, invoicing and billing purposes

Legal basis: Performance of a Contract, Legal Duty (for billing and record-keeping requirements), Legitimate interests

Types of information we use: Identity and contact details, Purchase related information, App related information, Financial Information, Digital information

Client onboarding and verification

What we use your information for:

• To assess whether to take you on as a new client, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks

Legal basis: Performance of a Contract, Legal Duty, Public Interest, Legitimate interests

Types of information we use: Identity and contact details, Financial information

Website enquiries and customer service

What we use your information for:

• To contact and communicate with you about any enquiries you make with us via our website

Legal basis: Legitimate interests

Types of information we use: Identity and Contact Data, Digital Information

Business improvement and development

What we use your information for:

• Analytics including profiling on our website and App
• Market research and business development
• To operate and improve our services, associated applications and associated social media platforms

Legal basis: Legitimate interests

Types of information we use: Identity and contact details, Purchase related information, App related information, Digital Information

Marketing and communications

What we use your information for:

• To send you promotional information about our business and services and information that we consider may be of interest to you
• To run promotions, competitions and offer additional benefits to you
• With your consent, we or our retail partners may also send you targeted personalised marketing and advertising via social media or general digital advertising on websites and apps

Legal basis: Consent, Legitimate interests

Types of information we use: Identity and contact details, Purchase related information, App related information, Digital Information

Data modelling

What we use your information for:

• Understanding shopping trends and patterns
• Creating data models that identify common shopping behaviours
• Helping retail partners understand shopping trends and data models, which they may use for advertising or marketing purposes

Legal basis: Consent, Legitimate interests

Types of information we use: Identity and contact details, Purchase related information, App related information, Digital Information

Legal compliance

What we use your information for:

• Comply with our legal obligations or if otherwise required or authorised by law

Legal basis: Legal Duty

Types of information we use: All relevant Personal Data

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4. OUR DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES

We may disclose personal data to:

Service providers

• IT service providers including IONOS
• Data storage providers including Cloudflare
• Web hosting and server providers
• Payment processors including Tide bank
• Marketing and advertising providers
• Analytics providers

Partners

We share personal data to participating partners. Our list of current participating partners can be found here [insert link].

Professional advisers

• Bankers
• Auditors
• Insurers and insurance brokers
• Legal advisers

Business partners

• Our existing or potential agents
• Our business partners or contractors

Corporate transactions

If we merge with or are acquired by another company, or sell our business assets:

• Your information may be disclosed to our advisers
• Your information may be disclosed to the potential purchaser's advisers
• Your information may be included in the transferred assets

Legal and regulatory bodies

• Courts and tribunals
• Regulatory authorities including as required for reporting obligations
• Law enforcement officers

Other parties

• Third parties you have authorised
• Emergency services when necessary
• Any other parties as required or permitted by law

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5. OVERSEAS TRANSFERS

Where we store and access your information

We store your personal data in the United Kingdom. However, your information may be transferred to locations outside the United Kingdom in these circumstances:

• When our service providers are located overseas
• When we work with overseas business partners
• When using cloud-based services or data storage solutions
• When required by law or legal proceedings

Our approach to overseas transfers

When we transfer your personal data outside the United Kingdom, we ensure it receives appropriate protection by:

• Only transferring your information to countries that UK data protection law recognises as providing adequate protection for personal data, or
• Putting in place a contract with the third party that means they must protect personal data to the same standards as the UK.
• Transferring personal data to organisations that are part of specific agreements on cross-border data transfers with the UK.

What this means for you

We only transfer the minimum amount of personal data necessary and require all recipients to:

• Protect your information to the same standards required by UK law
• Use your information only for the purposes we've agreed
• Allow us to monitor how they handle your information
• Provide you with the same rights over your information that you have under UK law

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6. CHILDREN'S PERSONAL DATA

We do not knowingly collect or process personal data from children under 13 years of age without appropriate parental or guardian consent.

If you are under 13, please do not provide personal data to us without first asking your parent or guardian for permission.

If we become aware that we have collected personal data from a child under 13 without verified parental consent, we will take steps to delete that information as quickly as possible.

Parents and guardians have the right to:

• Review any personal data we hold about their child
• Request correction or deletion of their child's personal data
• Refuse or withdraw consent for further collection or use of their child's data
• Contact us with any concerns about their child's privacy

If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us immediately using the details provided in this policy.

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7. DATA RETENTION

How long we keep your information

We only keep your personal data for as long as we need it to:

• Provide our services to you
• Meet our legal, tax, accounting or regulatory obligations
• Handle any complaints or legal issues that may arise

We may keep your information for longer periods if:

• You make a complaint that we need to investigate or respond to
• We reasonably believe legal action involving our relationship with you might occur
• The law requires us to keep it for specific timeframes

How we decide retention periods

When determining how long to keep your information, we consider:

• How much information we have and how sensitive it is
• The risk of harm if the information was accessed without permission
• Whether we can achieve our purposes in other ways
• What legal, regulatory, tax or accounting rules require
• The nature of our relationship with you and the services we provide

What happens when we no longer need your information

Once we no longer need your personal data, we will securely delete or destroy it in accordance with our data retention policies and legal requirements.

Your Rights

You can request information about retention periods for your data and ask for early deletion where legally possible.

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8. YOUR PRIVACY RIGHTS AND CHOICES

Providing information

You can choose whether to provide personal data to us, however, if you don't provide certain information, we may not be able to provide some services. Let us know if you don't want to provide information and we will let you know when information is required versus optional.

Right of Access

You have the right to ask us for copies of your personal data. You can request other information such as details about where we get personal data from and who we share personal data with. There are some exemptions which means you may not receive all the information you ask for.

Right to Rectification

You have the right to ask us to correct or delete personal data you think is inaccurate or incomplete.

Right to Erasure ("Right to be forgotten")

You can request deletion of your personal data in certain limited circumstances as set out in data protection law, such as where the data is no longer necessary or has been unlawfully processed. This right is not absolute and we may be required or entitled to retain your data for legal, regulatory or legitimate business reasons.

Right to Restrict Processing

You can ask us to suspend processing where:

• You contest the accuracy of the data
• Processing is unlawful but you don't want erasure
• We no longer need the data but you need it for legal claims
• You've objected to processing pending verification of our legitimate grounds

Right to opt-out of marketing communications

You can opt-out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

Right to Data Portability

Where technically feasible, you can receive your personal data in a structured, commonly used format or have it transmitted to another controller where:

• Processing is based on consent or contract
• Processing is automated

Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds.

Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

How to Exercise Your Rights

To exercise any of these rights, contact us using the details below. We may ask for proof of identity and will respond within one month (extendable to three months for complex requests).

These rights are available under data protection law, though some may not apply in every situation. We'll let you know if any limitations apply when you make a request.

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9. MAKING A COMPLAINT

If you have concerns about how we handle your information

If you're unhappy with how we've used your personal data, please get in touch with us first using the contact details at the end of this policy. When you contact us:

• Give us full details about your complaint
• We'll investigate your concerns promptly
• We'll respond to you in writing explaining what we found and what we'll do to address your complaint

Your right to complain to the regulator

You can also make a complaint directly to the Information Commissioner's Office (ICO), the UK's data protection regulator, at any time. The ICO's address:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

You don't have to contact us first before going to the ICO, but we'd appreciate the opportunity to try to resolve your concerns directly with you.

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10. PROTECTING YOUR INFORMATION

We use multiple layers of security to protect your information.

Technical safeguards

• Enterprise-grade encryption for data storage and transmission
• Regular security testing and monitoring
• Automated threat detection systems

Operational security

• Staff training on security and privacy
• Strict access controls based on job requirements
• Regular security audits and incident response procedures testing

Physical security

• Secure premises with controlled access
• Secure disposal of physical documents
• Equipment security protocols

Public information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

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11. COOKIES AND ANALYTICS

Cookies and pixels

We use cookies and similar tracking technologies on our website to enhance your browsing experience and improve our services.

What are cookies?

Cookies are small text files that are stored on your device when you visit our website. They help us remember your preferences and understand how you use our site.

Types of cookies we use

• Essential cookies: Necessary for the website to function properly
• Performance cookies: Help us understand how visitors interact with our website
• Functionality cookies: Remember your preferences and settings
• Marketing cookies: Used to deliver relevant advertisements and track campaign effectiveness

Cookie consent

When you first visit our website, you will see a cookie notice explaining our use of cookies. You can choose which types of cookies to accept through our cookie preference centre. You'll find more information about the cookies we use in our cookie pop-up.

Managing your preferences

You can change your cookie preferences at any time by:

• Using our cookie preference centre on the website
• Adjusting your browser settings to refuse or delete cookies
• Visiting our cookie policy for detailed information about specific cookies

Please note that disabling certain cookies may affect the functionality of our website and your user experience.

Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity. You can opt out of Google's advertising features through your Google account settings, browser add-ons, or your device's privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google's privacy pages.

Meta advertising tools

We use Meta's advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

Use of location services data

We collect your precise or approximate location via our mobile application for the following purposes:

• To provide personalised targeted advertising

We collect this information when you enable our mobile application to use your device's location services. If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide geolocation data to us, it may affect our ability to work with you as a customer or supplier of our business.

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12. ARTIFICIAL INTELLIGENCE (AI) TECHNOLOGIES

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

• Conduct analysis and data processing
• Generate and modify content and coding
• Improve and optimise our services and operations
• Automate routine tasks and communications
• Personalise your experience with our services
• Support quality assurance processes
• Assist with customer support and queries

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal data in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal data, and you maintain all the rights outlined in this privacy policy. When using AI with your personal data, we commit to:

Transparency and control

• We'll inform you when AI is used to make decisions that may significantly affect you
• We maintain human oversight and review of significant AI-generated decisions
• Our staff are trained to understand AI limitations and verify outputs before relying on them
• We implement processes to verify the accuracy of AI-generated outputs

Security

• We use appropriate technical and organisational measures to maintain the security and integrity of your personal data
• We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

• We regularly assess and document risks associated with using AI to process personal data
• We implement appropriate measures to address these risks
• We continuously monitor AI performance and regularly review their impact

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13. AMENDMENTS

We may update this policy at any time by posting the revised version on our website. We recommend that you review our website regularly to stay current with any policy changes.

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14. OUR CONTACT DETAILS

Privacy contact email: [email protected]

Last update: 17 December 2025

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