A note from our founding team...
Kado is a small business run part-time by it's creators. If you have any concerns about your data as it relates to the European General Data Protection Regulation (“GDPR”) or otherwise, please don't hesitate to contact us via support@getkado.com and we will work with you to resolve the issue.
Many Thanks,
The Kado Team
Privacy Policy
Thanks for visiting Kado! Kado (“Kado”, “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.
By using any of Kado’s Services, you confirm you have agreed to the Terms of Service and read and understood this Privacy Policy and our Cookie Policy.
1. Some key terms
In our Privacy Policy, when we refer to “Users”, we mean our customers who use our Services, including visitors to our sites. We explain who we are in the “Who is Kado?” section below. The users, visitors and customers of, our Users’ sites are “End Users”. Any other capitalized terms not defined in this Privacy Policy have the meanings in our Terms of Service.
2. How does this Privacy Policy apply?
This Privacy Policy describes what we do with personal information that we collect and use for our own purposes (i.e., where we are a controller), such as your account information and information about how you use and interact with our Services, including information you submit to our customer support as well as certain information relating to your End Users.
We use cookies and similar technologies. Our Cookie Policy describes what we do in that regard.
We also host and process User Content for our Users. Our Users tell us what to do with User Content, and we follow their instructions. This Privacy Policy does not describe what we do with User Content on our Users’ instructions (i.e., as their processor). If you are an End User of one of our User’s sites and want to know how a User handles your information, you should check its privacy policy. If you want to know about what we do for our own purposes, read on.
If you are a User, see our Data Processing Addendum to learn more about how we process User Content on your instructions or with your permission.
3. Personal information we collect
We collect various personal information regarding you or your device. This includes the following:
Information you provide to create an Account, specifically email address, first name and last name. If you sign up for Paid Services, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.
Your marketing preferences.
The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others.
Information you share with us in connection with surveys, contests or promotions.
Information from your use of the Services or Users’ sites. This includes: IP addresses, preferences, web pages you visited prior to coming to our or our Users’ sites, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sites (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).
Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
Other information you submit to us directly or through Third Party Services if you use a Third Party Service to create an Account (based on your privacy settings with such Third Party Service).
4. How we collect personal information
We obtain personal information from various sources. We do this in three main ways:
You provide some of it directly (such as by registering for an Account).
We record some of it automatically when you use our Services or Users’ sites (including with technologies like cookies).
We receive some of it from third parties (like when you register for an account using a Third Party Service or when you make payments to us using our payment processor).
We’ve described this in more detail below.
a. Personal information you provide
When you use our Services, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address to register and manage your Account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.
Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for Paid Services to determine if, and how much, tax we need to collect from you. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
b. Personal information obtained from your use of our Services
When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our mobile apps.
If you are an End User of our Users’ sites, we also get information about your interactions with their sites, though we use this in anonymous, aggregated or pseudonymized form which does not focus on you individually. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services).
Some of this information is collected automatically using cookies and similar technologies when you use our Services and our Users’ sites. We let our Users control what cookies and similar technologies are used through their sites (except those we need to use to provide the Services properly, such as for performance or security related reasons). You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.
c. Personal information obtained from other sources
If you use a Third Party Service (such as Google) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.
If you sign up for Paid Services, we obtain limited information about your payment card from our payment processor, such as the last four digits, the country of issuance and the expiration date. Currently, our payment processor is Stripe. Stripe uses and processes your complete payment information in accordance with Stripe’s privacy policy.
5. How we use your personal information
We use the personal information we obtain about you to:
Provision of the Services. Create and manage your Account, provide and personalize our Services, process payments and respond to your inquiries.
Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.
Surveys and contests. Administer surveys, contests and other promotions.
Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Kado and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your subscription plan or what we think may interest you based on other information we hold about you.
Advertising. Analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for Paid Services or we may choose to serve you a particular advertisement based on your subscription plan or what we think may interest you based on other information we hold about you.
Customizing the Services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose, such as remembering which of Your Sites you most recently edited.
Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature.
Security. Ensure the security and integrity of our Services.
Third party relationships. Manage our vendor and partner relationships.
Enforcement. Enforce our Terms of Service and other legal terms and policies.
Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.
We process your personal information for the above purposes when:
Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to your Kado account.
Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
To operate the Kado business and provide you with tailored advertising and communications to develop and promote our business.
To analyze and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring Kado is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
To provide and improve the Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.
To share your personal information with other Kado group companies that help us provide and improve the Services.
To anonymize and subsequently use anonymized information.
Protecting you and others. To protect your vital interests, or those of others.
Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness or our Users who have a legitimate interest in having their sites function properly and securely and analyzing the usage of their sites so they can understand trends and improve their services.
6. How we share your personal information
We share personal information in the following ways:
Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
Users. We share with our Users data regarding usage by End Users of their sites. For example, we provide a User with information about what web page the End User visited before coming to their site and how their End Users interacted with their site. This is so Users can analyze the usage of their sites and improve their services.
Business partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.
Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.
Process payments. We transmit your personal information via an encrypted connection to our payment processor.
Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of Kado or our Users or End Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third party social media platform on which we advertise to avoid serving Kado ads to people who already use Kado.
Business transfers. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.
7. Your rights and choices
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information (or that of your End Users) either directly in your Account or by contacting us at support@getkado.com to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.
You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instruction in such communications.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:
Irish Data Protection Commissioner
Office of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone +353 57 868 4757
Fax: +353 57 868 4757
Email: info@dataprotection.ie
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
Our Cookie Policy explains how you can manage cookies and similar technologies.
If you are an End User of one of our User’s sites, you should contact them to exercise your rights with respect to any information they hold about you.
8. How we protect your personal information
While no service is completely secure, we have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.
9. How we retain your personal information
We retain personal information regarding you or your use of the Services for as long as your Account is active or for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.
As Users may have a seasonal site or come back to us after an Account becomes inactive, we don’t immediately delete your personal information when your trial expires or you cancel all Paid Services. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back.
You may delete your Account by contacting us at support@getkado.com and Kado will delete the personal information it holds about you (unless we need to retain it for the purposes set out in this Privacy Policy).
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.
10. Data transfers
Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in the U.S. We also store personal information locally on the devices you use to access the Services.
Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:
Privacy Shield. We transfer, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (each individually and jointly, the “Privacy Shield”), including Kado, Inc.
Standard data protection clauses. We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.
Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.
You can find out more information about these transfer mechanisms here.
11. End Users’ personal information
Our customers who have created a site using Kado are responsible for what they do with the personal information they collect, directly or through Kado, about their End Users. This section is directed to such customers.
a. Your relationship with End Users
If you’re one of our Users, you will collect personal information about your End Users. For example, during checkout you may ask your End Users to provide their name, address, email address and payment information so that you can complete their orders. You may also use cookies and similar technologies to analyze usage and other trends.
You're solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including personal information you collect about them from us or using Kado functionality or cookies or similar technologies.
You must publish your own privacy and cookie policy and comply with them.
We’re not liable for your relationship with your End Users or how you collect and use personal information about them (even if you collect it from us or using Kado functionality or cookies or similar technologies) and we won’t provide you with any legal advice regarding such matters.
b. End User payment information
Your End Users’ payment information may be processed via third party eCommerce Payment Processors with which you integrate your Account, in accordance with such eCommerce Payment Processors’ terms and policies. We transmit your End Users’ complete payment information when they initially provide or update it only so that we can pass it along to the eCommerce Payment Processors you agree to use. We don’t collect or store your End Users’ payment information.
12. Updates to this Privacy Policy
We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).
We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your personal information.
13. Who is Kado?
When we say “Kado” (or “we”, “us” or “our”), we mean: (a) Kado, LLC. if you are a resident of or have your principal place of business in the United States of America or any of its territories or possessions (the “US”); or (b) Kado Ireland Limited, in any other case.
If your place of residence or principal place of business changes, the Kado entity that controls your personal information will be determined by your new residence or principal place of business from the date it changes.
15. How to contact us
If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at support@getkado.com, or write to us at the addresses below:
If you are a resident of or have your principal place of business in the US:
Kado, LLC
Attention: Legal - Privacy
151 Alice B. Toklas Pl. #502,
San Francisco,
California,
94109
If you are a resident of or have your principal place of business anywhere other than the US:
Kado, LLC
Attention: Legal - Privacy
151 Alice B. Toklas Pl. #502,
San Francisco,
California,
94109
Data Processing Addendum
This Kado Data Processing Addendum forms part of, and is subject to the provisions of, the Kado Terms of Service. Capitalized terms that are not defined in this Data Processing Addendum have the meanings set forth in the Terms of Service.
1. Additional Definitions.
The following definitions apply solely to this Data Processing Addendum:
a. the terms “controller”, “data subject”, “personal data”, “process,” “processing” and “processor” have the meanings given to these terms in EU Data Protection Law.
b. “Breach” means a breach of the Security Measures resulting in access to Kado’s equipment or facilities storing Your Controlled Data and the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Your Controlled Data transmitted, stored or processed by Kado on your behalf and instructions through the Services.
c. “Content” means your User Content and any content provided to us from your End Users, including without limitation text, photos, images, audio, video, code, and any other materials.
d. “EU Data Protection Law” means any data protection or data privacy law or regulation of Switzerland or any European Economic Area (“EEA”) country applicable to Your Controlled Data, including, as applicable, the GDPR and the e-Privacy Directive 2002/58/EC.
e. “GDPR” means the EU General Data Protection Regulation 2016/679.
f. “Security Measures” means the technical and organizational security measures set out here.
g. “Sub-Processor” means an entity engaged by Kado to process Your Controlled Data.
h. “Your Controlled Data” means the personal data in the Content Kado processes on your behalf and instructions as part of the Services, but only to the extent that you are subject to EU Data Protection Law in respect of such personal data. Your Controlled Data does not include personal data when controlled by us, including without limitation data we collect (including IP address, device/browser details and web pages visited prior to coming to Your Site) with respect to your End Users’ interactions with Your Site through their browser and technologies like cookies.
2. Applicability.
This Data Processing Addendum only applies to you if you or your End Users are data subjects located within the EEA or Switzerland and only applies in respect of Your Controlled Data. You agree that Kado is not responsible for personal data that you have elected to process through Third Party Services or outside of the Services, including the systems of any other third-party cloud services, offline or on-premises storage.
3. Details of Data Processing.
3.1 Subject Matter. The subject matter of the data processing under this Data Processing Addendum is Your Controlled Data.
3.2 Duration. As between you and us, the duration of the data processing under this Data Processing Addendum is determined by you.
3.3 Purpose. The purpose of the data processing under this Data Processing Addendum is the provision of the Services initiated by you from time to time.
3.4 Nature of the Processing. The Services as described in the Agreement and initiated by you from time to time.
3.5 Type of Personal Data. Your Controlled Data relating to you, your End Users or other individuals whose personal data is included in Content which is processed as part of the Services in accordance with instructions given through your Account.
3.6 Categories of Data Subjects. You, Your End Users and any other individuals whose personal data is included in Content.
4. Processing Roles and Activities.
4.1 Kado as Processor and You as Controller. You are the controller and Kado is the processor of Your Controlled Data.
4.2 Kado as Controller. Kado may also be an independent controller for some personal data relating to you or your End Users. Please see our Privacy Policy and Terms of Service for details about this personal data which we control. We decide how to use and process that personal data independently and use it for our own purposes. When we process personal data as a controller, you acknowledge and confirm that the Agreement does not create a joint-controller relationship between you and us. If we provide you with personal data controlled by us, such as in any access to data regarding your End Users’ interactions with Your Site, you receive that as an independent data controller and are responsible for compliance with EU Data Protection Law in that regard.
4.3 Description of Processing Activities. We will process Your Controlled Data for the purpose of providing you with the Services, as may be used, configured or modified from within your Account (the “Purpose”). For example, depending on how you use the Services, we may process Your Controlled Data in order to: (a) enable you to integrate content or features from a social media platform on Your Site; or (b) email your End Users on your behalf.
4.4 Compliance with Laws. You will ensure that your instructions comply with all laws, regulations and rules applicable in relation to Your Controlled Data and that Your Controlled Data is collected lawfully by you or on your behalf and provided to us by you in accordance with such laws, rules and regulations. You will also ensure that the processing of Your Controlled Data in accordance with your instructions will not cause or result in us or you breaching any laws, rules or regulations (including EU Data Protection Law). You are responsible for reviewing the information available from us relating to data security pursuant to the Agreement and making an independent determination as to whether the Services meet your requirements and legal obligations as well as your obligations under this Data Processing Addendum. Kado will not access or use Your Controlled Data except as provided in the Agreement, as necessary to maintain or provide the Services or as necessary to comply with the law or binding order of a governmental, law enforcement or regulatory body.
5. Our Processing Responsibilities.
5.1 How We Process. We will process Your Controlled Data for the Purpose and in accordance with the Agreement or instructions you give us through your Account. You agree that the Agreement and the instructions given through your Account are your complete and final documented instructions to us in relation to your Controlled Data. Additional instructions outside the scope of this Data Processing Addendum require prior written agreement between you and us, including agreement on any additional fees payable by you to us for carrying out such instructions. We will promptly inform you if, in our opinion, your instructions infringe applicable EU Data Protection Law, or if we are unable to comply with your instructions. We will notify you when applicable laws prevent us from complying with your instructions, except if such disclosure is prohibited by applicable law on important grounds of public interest, such as a prohibition under law to preserve the confidentiality of a law enforcement investigation or request.
5.2 Notification of Breach. We will provide you notice without undue delay after becoming aware of and confirming the occurrence of a Breach for which notification to you is required under applicable EU Data Protection Laws. We will, to assist you in complying with your notification obligations under Articles 33 and 34 of the GDPR, provide you with such information about the Breach as we are reasonably able to disclose to you, taking into account the nature of the Services, the information available to us and any restrictions on disclosing the information such as for confidentiality. Our obligation to report or respond to a Breach under this Section is not and will not be construed as an acknowledgement by Kado of any fault or liability of Kado with respect to the Breach. Despite the foregoing, Kado’s obligations under this Section do not apply to incidents that are caused by you, any activity on your Account and/or Third-Party Services.
5.3 Notification of Inquiry or Complaint. We will provide you notice, if permitted by applicable law, upon receiving an inquiry or complaint from an End User, or other individual whose personal data is included in your Content, or a binding demand (such as a court order or subpoena) from a government, law enforcement, regulatory or other body in respect of Your Controlled Data that we process on your behalf and instructions.
5.4 Reasonable Assistance with Compliance. We will, to the extent that you cannot reasonably do so through the Services, your Account or otherwise, provide reasonable assistance to you in respect of your fulfillment of your obligation as controller to respond to requests by data subjects under Chapter 3 of the GDPR, taking into account the nature of the Services and information available to us. You will be responsible for our reasonable costs arising from our provision of such assistance.
5.5 Security Measures. We will maintain the Security Measures. We may change these Security Measures but will not do so in a way that adversely affects the security of Your Controlled Data. We will take steps to ensure that any natural person acting under our authority who has access to Your Controlled Data does not process it except on our instructions, unless such person is required to do so under applicable law, and that personnel authorized by us to process Your Controlled Data have committed themselves to relevant confidentiality obligations or are under an appropriate statutory obligation of confidentiality.
5.6 Sub-Processors. You agree that we can share Your Controlled Data with Sub-Processors in order to provide you the Services. We will impose contractual obligations on our Sub-Processors, and contractually obligate our Sub-Processors to impose contractual obligations on any further sub-contractors which they engage to process Your Controlled Data, which provide the same level of data protection for Your Controlled Data in all material respects as the contractual obligations imposed in this Data Processing Addendum, to the extent applicable to the nature of the Services provided by such Sub-Processor. A list of our current Sub-Processors is available upon request by sending an email to privacy@getkado.com. Provided that your objection is reasonable and related to data protection concerns, you may object to any Sub-Processor by sending an email to privacy@getkado.com. If you object to any Sub-Processor and your objection is reasonable and related to data protection concerns, we will use commercially reasonable efforts to make available to you a means of avoiding the processing of Your Controlled Data by the objected-to Sub-Processor. If we are unable to make available such suggested change within a reasonable period of time, we will notify you and if you still object to our use of such Sub-Processor, you may cancel or terminate your Account or, if possible, the portions of the Services that involve use of such Sub-Processor. Except as set forth in this Section 5.6, if you object to any Sub-Processors, you may not use or access the Services. You consent to our use of Sub-Processors as described in this Section 5.6. Except as set forth in this Section 5.6 or as you may otherwise authorize, we will not permit any Sub-Processor to access Your Controlled Data. Kado will remain responsible for its compliance with the obligations of this Data Processing Addendum and for any acts or omissions of any Sub-Processor or their further sub-contractors that process Your Controlled Data and cause Kado to breach any of Kado’s obligations under this Data Processing Addendum, solely to the extent that Kado would be liable under the Agreement if the act or omission was Kado’s own.
5.7 Kado Audits. Kado may (but is not obliged to) use external or internal auditors to verify the adequacy of our Security Measures.
5.8 Customer Audits and Information Requests. You agree to exercise any right you may have to
conduct an audit or inspection by instructing Kado to carry out the audit described in Section 5.7.
You agree that you may be required to agree to a non-disclosure agreement with Kado before we
share any such report or outcome from such audit with you and that we may redact any such reports as
we consider appropriate. If Kado does not follow such instruction or if it is legally mandatory for
you to demonstrate compliance with EU Data Protection Law by means other than reviewing a report
from such an audit, you may only request a change in the following way:
a. First, submit a request for additional information in writing to Kado, specifying all details required to enable Kado to review this request effectively, including without limitation the information being requested, what form you need to obtain it in and the underlying legal requirement for the request (the “Request”). You agree that the Request will be limited to information regarding our Security Measures.
b. Within a reasonable time after we have received and reviewed the Request, you and we will discuss and work in good faith towards agreeing on a plan to determine the details of how the Request can be addressed. You and we agree to use the least intrusive means for Kado to verify Kado’s compliance with the Security Measures in order to address the Request, taking into account applicable legal requirements, information available to or that may be provided to you, the urgency of the matter and the need for Kado to maintain uninterrupted business operations and the security of its facilities and protect itself and its customers from risk and to prevent disclosure of information that could jeopardize the confidentiality of Kado or our users’ information.
You will pay our costs in considering and addressing any Request. Any information and documentation
provided by Kado or its auditors pursuant to this Section 5.8 will be provided at your cost. If we
decline to follow any instruction requested by you regarding audits or inspections, you may cancel any affected Paid Services.
5.9 Questions. Upon your reasonable requests to us for information regarding our compliance with the obligations set forth in this Data Processing Addendum, we shall, where such information is not otherwise available to you, provide you with written responses, provided that you agree not to exercise this right more than one (1) time per calendar year (unless it is necessary for you to do so to comply with EU Data Protection Law). The information to be made available by Kado under this Section 5.9 is limited to solely that information necessary, taking into account the nature of the Services and the information available to Kado, to assist you in complying with your obligations under the GDPR in respect of data protection impact assessments and prior consultation. You agree that you may be required to agree to a non-disclosure agreement with Kado before we share any such information with you.
5.10 Requests. You can delete or access a copy of some of Your Controlled Data through your Account. For any of Your Controlled Data which may not be deleted or accessed through your Account, upon your written request, we will, with respect to any of Your Controlled Data in our or our Sub-Processor’s possession that we can associate with a data subject, subject to the limitations described in the Agreement and unless prohibited by applicable law or the order of a governmental, law enforcement or regulatory body: (a) return such data and copies of such data to you provided that you make such request within no more than ninety (90) days after the cancellation of the applicable Paid Services; or (b) delete, and request that our Sub-Processors delete, such data (excluding in the case of (a) or (b) any of such data which is archived on back-up systems, which we shall securely isolate and protect from any further processing, except to the extent required by applicable law). Otherwise, we will delete Your Controlled Data in accordance with our data retention policy. This Section 5.10 does not apply to personal data held by Third Party Services.
6. Data Transfers.
You authorize us to transfer Your Controlled Data away from the country in which such data was originally collected. In particular, you authorize us to transfer Your Controlled Data to the US. We will transfer Your Controlled Data to outside the EEA using the Swiss-U.S. and EU-U.S. Privacy Shield Frameworks or another lawful data transfer mechanism that is recognized under EU Data Protection Law as providing an adequate level of protection for such data transfers.
7. Liability.
The liability of each party under this Data Processing Addendum is subject to the exclusions and limitations of liability set out in the Agreement. You agree that any regulatory penalties or claims by data subjects or others incurred by Kado in relation to Your Controlled Data that arise as a result of, or in connection with, your failure to comply with your obligations under this Data Processing Addendum or EU Data Protection Law shall reduce Kado’s maximum aggregate liability to you under the Agreement in the same amount as the fine and/or liability incurred by us as a result.
8. Conflict.
In the event of a conflict between this Data Processing Addendum and the Terms of Service, this Data Processing Addendum will control.
9. Miscellaneous.
You are responsible for any costs and expenses arising from Kado’s compliance with your instructions or requests pursuant to the Agreement (including this Data Processing Addendum) which fall outside the standard functionality made available by Kado generally through the Services.
Effective Date: May 14, 2018
This Cookie Policy describes how Kado uses cookies and similar technologies to provide, customize, evaluate, improve, promote and protect our Services. Note that any capitalized terms not defined in this Cookie Policy have the meanings set forth in our Terms of Service. If you have any comments or questions about this Cookie Policy, feel free to contact us at privacy@getKado.com.
Cookies. Cookies are small pieces of text sent to your browser when you visit a site. They serve a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Services. We use cookies on the website and associated domains of www.Kado.com and on Kado web and mobile applications for the following purposes:
Authentication, Customization, Security and Other Functional Cookies. Cookies help us verify your Account and device and determine when you’re logged in, so we can make it easier for you to access the Services and provide the appropriate experiences and features. We also use cookies to help prevent fraudulent use of login credentials and to remember choices you’ve made on the Services, such as your language preference.
Performance And Analytics. Cookies help us analyze how the Services are being accessed and used, and enable us to track performance of the Services. For example, we use cookies to determine if you viewed a page or opened an email. This helps us provide you with information that you find interesting.
Third Parties. Third Party Services may use cookies to help you sign into their services from our Services. Any such third party cookie usage is governed by the policy of the third party placing the cookie.
Kado Ads. We partner with third party publishers, advertising networks and service providers to manage our ads on other sites. Our third party partners may set cookies on your device or browser to gather information about your activities on the Services and other sites you visit, in order to provide you with Kado ads. For example, if you visit Kado and also use a social media platform, you may see a Kado ad in your social media newsfeed or timeline.
Opting Out. You can set your browser to not accept cookies, but this may limit your ability to use the Services. We currently don’t respond to DNT:1 signals from browsers visiting our Services. You can also opt out of receiving interest-based ads from certain ad networks here (or if located in the European Union, here).
Device Identifiers. We use device identifiers on Kado web and mobile applications to track, analyze and improve the performance of the Services and our ads.
Third Party Tags. We use and manage third party tags on the website and associated domains of www.getkado.com and on Kado desktop applications. Third party tags may take the form of pixels or tracking snippets. We use pixels to learn how you interact with our site pages and emails, and this information helps us and our ad partners provide you with a more tailored experience.
We may update this Cookie Policy from time to time. When we make changes, we’ll update the “Effective Date” at the top of the Cookie Policy and post it on our sites. We encourage you to check back periodically to review this Cookie Policy for any changes since your last visit.