Effective from October 6, 2021
1. Please read carefully
2. What ‘Personal Information’ do we collect?
2.1. User information:
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:
Information you provide us. When you register for our Services, purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., Kakaw’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
To provide our Services, we collect Personal Information about our Users.
The Personal Information comes from you when you visit or use our services, Personal Information we collect automatically, and Personal Information we collect from other sources.
2.2. Users of users ‘Personal Information’
We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
3. Why do we collect such ‘Personal Information’
We use your Personal Information for the following purposes:
To provide and operate the Services;
.To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);
To help us to update, expand and analyze our records to identify new customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
To analyze our performance and marketing activities;
To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
To provide you with professional assistance , only upon your request;
To enhance our data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.
We use your Personal Information for the purposes set out in Section 3 where:
Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);
Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of Kakaw by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.#ItsThatEasy
We use the Personal Information we collect about you to provide our services and make them better and safer.
We also collect and use Personal Information in order to contact Users and to comply with the laws applicable to us.
4. How we share your ‘Personal Information’
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
Third Party Service Providers: Kakaw has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
Kakaw may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
commercial Personal Information, for example Personal Information regarding products or services purchased, obtained, or considered.
We may share the Personal Information of our Users and Users-of-Users with various third parties, including certain service providers and law enforcement officials.
The Personal Information may be shared solely in accordance with this policy.
Sharing Personal Information by Kakaw subsidiaries and affiliated companies in the European Union, the United Kingdom and Switzerland with Kakaw’s subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses.
In connection with a change in corporate control: In addition, should Kakaw or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
Upon Your Further Direction: The Kakaw Services enable you, through different techniques, to engage and procure various third party services, products and tools for enhancing your web or mobile sites, including, without limitation, applications and widgets offered to you by third parties through the Kakaw Website (including the Kakaw App Market), eCommerce payment providers, third party designers who may assist you with your website, etc. (collectively, “Third Party Services”). If you choose to engage with such Third Party Services, they may have access to and process Personal Information of your Users-of-Users collected through your web or mobile sites. For example:
a) Framed Pages: our Services may enable you to integrate Third Party Services directly into your web or mobile sites, such as via page framing techniques to serve content to or from Third Party Services or other parties (“Frames”). In these circumstances, the Third Party Services may collect Personal Information from your Users-of-Users.
b) App Market Developers: We allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the Kakaw App Market (“Third Party App(s)”) to Users, which you may integrate into your web or mobile sites. Each Third Party Developer is bound by the Kakaw App Market Partner Agreement, which among other things, restricts the ways in which such developers may access, store, share, and use the Personal Information you and/or your Users-of-Users provide to them.
c) Social Media Features: Our Services may enable you to integrate certain Social Media features, widgets, and single sign on features, such as “Facebook Connect,” or “Google Sign-in” (“Social Media Features”) into your web or mobile sites. These Social Media Features may collect certain Personal Information from your Users-of-Users such as identifiers, including name, alias, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers. Social Media Features are hosted either by a third party or directly on our Services.
Please note that in the examples listed above in this Section 4.6, Kakaw merely acts as an intermediary platform allowing you to procure the services of such Third Party Services (including, but not limited to, Third Party Developers, Third Party Apps and Social Media Features) with which you are interacting directly, and at your discretion. In this respect, Kakaw acts as a service provider to you, disclosing information to the Third Party Services on your behalf. Kakaw will share your Users-of-Users’ Personal Information with Third Parties Services only upon your direction or with your permission and is not, and shall not be, in any way responsible for such Third Party Services processing of such Personal Information, or liable with respect thereto.
5. Where do we store your ‘Personal Information’?
Users’ and Users-of-Users’ Personal Information may be stored in data centers located in the United States of America, Ireland and United Kingdom. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.
Kakaw Ltd. is based in United Kingdom which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.
Kakaw affiliates and Third-Party Service Providers that store or process your Personal Information on Kakaw’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
Transfer of EU Personal data : If you are located in Europe, when we will transfer your Personal Information to the United States or anywhere outside Europe, we will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Standard Contractual Clauses are in place.
We may store and process Personal Information in the USA, Europe, or other jurisdictions, whether by ourselves or with the help of our affiliates and service providers.
Kakaw’s data storage providers are contractually committed to protect and secure your data.
Among other things, Kakaw will ensure that there is the adequate level of protection or that relevant Standard Contractual Clauses are in place for the international transfer of our EU users’ data.
Privacy Shield Certification: Kakaw and its affiliates, including DeviantArt Inc., participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List, here.
In compliance with the Privacy Shield Principles, Kakaw.uk commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: hello@Kakaw.uk. For the avoidance of doubt, Kakaw does not rely on the Privacy Shield as a mechanism for transferring GDPR protected personal data.
Kakaw.uk has further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider at https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services are provided at no cost to you.
6. Users-of-users’ ‘Personal Information’
Kakaw may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with Kakaw, on the User’s behalf.
For such purposes, Kakaw serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.
The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
The Processing of the Users-of-users’ Personal Information shall take place within the territory of the European Union or a third country, territory or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection and such processing and transfer will be in accordance to the Data Processing Addendum – Users (“DPA"). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission, shall be conducted under an approved transfer mechanism, as detailed in the DPA.
You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.
Kakaw cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.
For more information on how Users-of-Users Personal Information may be handled by Kakaw (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12 and 13.
If you are a visitor, user or customer of any of our Users, please read the following: Kakaw has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by Kakaw on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If Kakaw is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
8. Communications from Kakaw
8.1. Promotional messages
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from Kakaw or our partners (acting on Kakaw’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify Kakaw at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
8.2. Service and billing messages
Kakaw may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a Kakaw User (which can be done by deactivating your account).
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
9. Your rights in relation to your ‘Personal Information’
Kakaw believes that it is imperative that all Kakaw users have control over their Personal Information. Therefore, depending on the way you use the Kakaw Services, you may have the right to request access to, receive a copy of, update, amend or delete, port certain Personal Information to another service, restrict, or object to certain uses of your Personal Information (for example, for direct marketing purposes). Further, when we rely on your consent for processing of your Personal Information (for instance, for direct marketing) you can withdraw your consent at any time, and such withdrawal will take affect from thereon.
Kakaw will not charge you more if you exercise any of these rights and will continue to provide you with the same level of service.
If you are a Kakaw user, you can access and correct a lot of your Personal Information directly through your account, or via online forms Kakaw makes available to you (as detailed below). You can also exercise your rights by sending your request to hello@Kakaw.uk, mailing it to Kakaw, 12 Library Road, Kendal, Cumbria LA9 4QB. When we receive your right request, we may take steps to verify your identity before complying with the request to protect your privacy and security.
Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a Kakaw User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please email us at Hello@kakaw.uk You can also mail your request to Kakaw, 12 Library Road, Kendal, Cumbria LA9 4QB. We will make reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.
Please note that permanently deleting your Kakaw account erases all of your Personal Information from Kakaw's databases. After completing this process, you can no longer use any of your Kakaw Services, your account and all its data will be removed permanently, and Kakaw will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.
When it comes to your Personal Information you stored with us, you have the right to: access, receive a copy of, update, amend or delete your Personal Information, enjoy data portability (in certain cases) restrict, or object to certain uses of your Personal Information, withdraw consent you’ve given us before to processing.
Just reach out to us by e-mail, mail or through our customer care team, or, when available, fill out our dedicated form.
You may also correct and/or update your Personal Information through your user account, if you have one.
You can also delete your Personal Information by deleting your entire account. We will respond to your requests within a reasonable timeframe.
10. Additional Information for California residents
If you are a California resident using the Services, the California Consumer Privacy Act ("CCPA") grants you the right to request access to and deletion of the Personal Information Kakaw collects about you, as well as to request that we disclose how we collect, use, and share your Personal Information.
California residents also have a right to opt-out of the sale of their Personal Information by a business and a right not to be discriminated against for exercising any of their rights under the CCPA.
No Discrimination. Kakaw does not discriminate against any User for exercising their rights under the CCPA.
California consumers can exercise their CCPA rights directly or through an authorized agent by signing in to their registered Kakaw account at Kakaw.uk and following the instructions outlined below. Please note: in order to protect Users’ accounts and Personal Information and safeguard Users’ privacy rights, we verify Users’ deletion and access requests, and to that extent, we may ask you for additional information or documentation (depending on the case), such as account related information, and, in some cases, billing information used to purchase paid Services, and a copy of documents that can assist with verifying your identity.
Such identification documentation (if requested) will be used only for verification purposes and we will delete it after your request is processed.
Right to Deletion: If you want to exercise your right to request deletion of any of your Personal Information that you have stored with us, please follow the instructions provided in this Help Center article: <"Permanently Deleting Your Kakaw Account">, which explains how to delete your Personal Information that you can access directly through your User account. You can also choose to submit a request to delete all your Personal Information (including information accessible via your User account and any other Personal Information we hold about you) by submitting a request by email to hello@Kakaw.uk, or by mailing your request to Kakaw, 12 Library Road, Kendal, Cumbria LA9 4QB.
Once we receive and verify your consumer request, we will delete your personal information from our records unless an exception applies. We will make reasonable efforts to honor your request promptly and consistent with requirements under applicable law.
Please note that permanently deleting your Kakaw account erases all of your Personal Information from Kakaw's databases. After completing this process, you can no longer use any of your Kakaw Services, your account, and all its data will be removed permanently, and Kakaw will not be able to restore your account or retrieve your data in the future. Additionally, if you contact our support channels in the future, the system will not recognize your account, and support agents will not be able to locate the deleted account.
If you cannot access your Kakaw account or if you wish to exercise your CCPA rights through an authorized agent operating on your behalf, you, or your authorized agent (as applicable) may send a request to hello@Kakaw.uk , including by requesting a callback from a customer care expert. To process your request, in order to protect Users’ accounts and Personal Information, we may ask you or your authorized agent for the verifying information detailed above, which may vary according to the circumstances of your request. Authorized agents will also need to provide Kakaw with a copy of the consumer’s signed authorization designating them as their agent.
California residents have a few options to submit requests to exercise their rights. Please refer to this Section 10 for more detail on how you or your authorized agent may submit different types of requests.
Kakaw does NOT sell (as such term is defined in the CCPA) your Personal Information or your customers’ Personal Information (Users-of-Users) to third parties.
11. Questions and complaints
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.
You can file a complaint with your local supervisory authority for data protection at any time. Please contact us first so we can try to resolve your concerns.
12. Data retention
We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to Personal Information in our care.
Kakaw has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by Kakaw, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information or any other information you upload, publish or otherwise share with Kakaw or anyone else. We encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us here.
14. Third-party websites
16. Public forums and user content
Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us via email. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.
If you upload any user content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
17. Updates and interpretation
Any heading, caption or section title contained herein, and any explanation or summary under the right “#ItsThatEasy” column, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.
We may change this policy at any time. We will notify you of changes as required by applicable law.
Only the left column is legally binding (this column is just for clarity).
Translated (non-English) versions of these terms are provided for convenience only.
18. Contacting us
For the purposes of UK GDPR (Article 27), you may contact our UK representative at Kakaw.uk (UK) Limited, 12 Library Road, Kendal Cumbria LA9 4QB#ItsThatEasy
We may change this policy at any time. We will notify you of changes as required by applicable law.
Only the left column is legally binding (this column is just for clarity).
Translated (non-English) versions of these terms are provided for convenience only.
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