Privacy Policy

1. What this Privacy Policy covers

This Privacy Policy sets out how Kuai Commerce Limited trading as YASO (company number: 13952850) (“YASO”, “we”, “our”, “us”), uses and protects your personal data.

We respect your privacy and are determined to protect your personal data. The purpose of this Privacy Policy is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

2. Important information and who we are

For the purposes of UK data protection law, YASO is the “data controller” of personal data we collect through our website. This means we determine what we collect, how it’s used and how it’s protected, as set out in this Privacy Policy (the “Privacy Policy”).

If you have any questions about this policy or how we handle your data, you can contact us at privacy@goyaso.com or 304 Edinburgh House, 170 Kennington Lane, London, SE11 5DP.

This website is not intended for children and we do not knowingly collect data relating to children.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

3. What personal data we collect

“Personal data” means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioner’s Office’s website.

When you visit our website, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name and company name
• Contact Data includes company address, email address(es), telephone number(s)
• Technical data includes IP address, browser type, device information, pages visited, general usage data, mobile device data and operating systems (if our website is visited through your mobile), referral source and session information

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do not collect any special category data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.

4. How we collect your personal data

We use different methods to collect data from and about you including through:

• Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Subscribe to our mailing list;
  • Book a consultation through our website;
  • Create an account on our website;
  • Request marketing to be sent to you.
• Automated technologies or interactions: as you interact with our website we will automatically collect technical data about your browsing actions, equipment and patterns through using cookies, website analytics providers and other similar technologies.

5. How and why we collect your data

Legal Basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose for which we will use your personal data

We collect your personal data for the following purposes and relying on the following legal basis:

Opting out of marketing

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting privacy@goyaso.com at any time.

Where you opt out of receiving these marketing messages, you may still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact privacy@goyaso.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Who we share your personal data with

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above:

• External Third Parties: service providers, analytics or performance tools, including:
  • HubSpot
  • MailChimp
  • Apollo
  • Zapier
  • Notion
  • Microsoft 365
  • Vercel
  • Google Analytics and Google Tag Manager
  • LinkedIn Insight Tag, Meta Pixel, Apollo Pixel and Microsoft Clarity
  • Ahrefs
  These third parties may process personal data on our behalf in accordance with our instructions and applicable data protection laws.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance, and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

Some of our third-party providers may process personal data outside of the UK, including to the United States. Where this occurs, we ensure appropriate safeguards are in place, including the UK International Data Transfer Agreements or adequacy regulations.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention: how long we keep your data for

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including contact, identity, financial, and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ‘your legal rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

You have the following rights under data protection laws with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact privacy@goyaso.com.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us at privacy@goyaso.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk).

12. Changes to our Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our activities, legal requirements, or how we handle personal data. When we make changes, we will update the ‘Last Updated’ date at the top of this page.