CUDO Ventures Limited

Privacy policy

Version dated: 09 Febuary 2024

Introduction

Welcome to the CUDO Ventures’ privacy notice.

CUDO Ventures Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please be advised that CUDO Donate, CUDO Compute and CUDO Miner are trading names of CUDO Ventures Ltd.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at the end of this notice to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how CUDO Ventures collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, utilise our services or take part in a competition.

This website is not intended for children (under 18s) and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data Controller

CUDO Ventures Ltd (registered company number 11065412) whose registered office address is at Kemp House, 160 City Road, London, EC1V 2NX is the data controller and responsible for your personal data (collectively referred to as “CUDO Ventures”, “we”, “us” or “our” in this privacy notice). CUDO Ventures are registered with the Information Commissioner’s Office in the UK (ICO Registration Number: ZA494591)

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact CUDO Ventures using the details set out below.

Contact details

Our full details are:

Data Protection Lead: Vicki Ivory

Postal Address: CUDO Ventures Ltd, Kemp House, 160 City Road, London, EC1V 2NX

Email Address: [email protected]

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details above.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated 29th January 2024 and historic versions archived can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this directly with your contact in our organisation, or by using the contact details above marked for the attention of the Data Protection Lead.

Third-party links

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.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. Certain features of our services may require KYC (Know Your Customer)/AML (Anti-Money Laundering) checks and therefore we may require additional data including Passport or ID information from our customers.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account, payment card details and any external wallet addresses which you are using to store your cryptocurrency.
• Transaction Data includes details about payments to and from you, and your external wallet.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal 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 and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

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

Direct interactions. 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:

• create an account on our website;
• subscribe to our service;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
• analytics providers such as Google based outside the EU;
• advertising networks such as Facebook, LinkedIn, Twitter, Instagram, Reddit, Youtube and Google; and
• search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

Third party tracking services. We may send website and platform usage data to platforms such as Facebook, LinkedIn, Twitter, Reddit, Instagram and Google, to utilise their conversion tracking and audience targeting services.

• This enables us to gauge the effectiveness of our advertising initiatives and refine our marketing strategy.
• The data collected through conversion tracking may encompass details about your interactions with our website, such as viewed pages, completed purchases, or other actions taken.
• To learn more about the privacy practices of the specified social media platforms and the tracking services they offer, please refer to the privacy policies and settings of the social media platforms and networks you utilise.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

(b) Collect and recover money owed to us | (a) Identity (b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) | | To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey | (a) Identity (b) Contact

(c) Profile

(d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) | | To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) | | To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact

(c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation | | To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) | | To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) | | To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact

(c) Technical

(d) Usage

(e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) | | We may wish to publish anonymous data on our sites and services for the purpose of marketing for example user statistics and figures. | (a) Technical (b) Usage | Necessary for our legitimate interests (to keep our website updated and relevant and to develop our business and to support our marketing strategy) |

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We operate an email mailing list which is used to inform you about products and services we supply and / news that we publish. You will be invited to subscribe to receive marketing and advertising. At the time of subscription you will be given the option to opt in to receive communications from us which may contain third party content or information.

Email marketing messages may contain tracking beacons or tracked clickable links or similar technologies in order to track subscriber activity.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have subscribed as a user of our service or have requested information from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We use a third party providers (Get Response, Plunk, Nowmarketing, SendGrid & Beehiiv) to assist us with preparing and distributing marketing communications. The third-party providers are placed under strict contractual obligations to only use your data in accordance with our instructions and to keep your data secure. We will get your express opt-in consent before we share your personal data with Hubspot or any other company outside the CUDO group of companies for marketing purposes.

Who has access to your information?

We limit access to your personal data to our employees who have a legitimate need to know and to third-party service providers (see below), who provide a service to us within the scope of our business operations. We ensure that they are aware of their duty of confidentiality.

We do not sell or rent your personal data or information to any third party or share your information with third parties for their marketing purposes.

We may pass information about you to other parties as required to provide requested services to you. For example, if you choose to donate to charity through our services, we will give you the option as to whether or not you share your details with your chosen charity. If you prefer to remain anonymous, we will not pass your details to the charity.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may pass your information on to third party service providers for the purposes of completing a task or providing services to you on our behalf. However, we disclose only the personal information necessary to deliver that service and have a contract in place that requires them to keep your information secure and not to use it for other purposes. The purposes for which they can access your data are limited in scope and they cannot use your data for their own purposes.

We currently use third-party service providers in the following areas of our business:

If any of your personal data are shared with a third party, as described above, we will take steps to ensure that your personal data are handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.

Transfers outside of the UK and European Economic Area

We may store or transfer some or all of your personal data in countries that are not part of the UK or European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data are treated just as safely and securely as they would be within the UK and under our Data Protection Legislation as follows:

• We share your data with external third parties, as detailed throughout and in the table above, that are based outside of the UK & EEA. The following safeguards are applied to such transfers:
• We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
• We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
• Where we transfer your data to a third party based in the US additional steps have been taken to ensure your personal data will be treated as securely and safely as it would be in the UK and under the GDPR. We have signed Data Processing Agreements with our data processors based on model contract clauses provided by the European Commission (also known as ‘standard contract clauses’), which impose suitable data protection standards on a contractual basis.

Please contact us using the contact details provided below for further information about the particular data protection mechanisms used when transferring your personal data to a third country.

CUDO Ventures uses Google Analytics Advertising Features; tools used to collect and evaluate usage information (anonymously), enabling CUDO to better understand how our Sites are used, enabling us to constantly improve our services. To collect this information, our Sites use cookies which are detailed in our Cookie Policy. You can opt-out of Google Analytics Advertising Features at any time through Google Ads Settings, Ad Settings for mobile apps, or any other available means. You can also use Google’s browser add-on, making it easier for you to opt-out. It is important for us to emphasise however is that by collecting this information, CUDO Ventures are able to improve our services and experience for you.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, we will still be able to contact you using the details you provided during the purchase / sign up process to give you essential information about the product or service we deliver to you and to manage your account with us. No marketing messages will be included as part of these communications.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 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 us.

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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties such as set out in the table above.
• You may choose to make donations to charity via our service, where you choose to do so we will share your personal data with the charity that you have nominated to receive such donations. If you do not want us to share your personal data with charities you may elect to keep your profile ‘anonymous’.
• 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.

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.

Contacting us via email

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with government standards. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 members for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure 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.

Your legal rights

Under Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the contact details provided at the end of this policy.
• The right to access the personal data we hold about you. The section “How Can I Access My Personal Data?” will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us are inaccurate or incomplete. Please contact us using the contact details provided at the end of this policy.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold, in certain circumstances. Please contact us using the contact details provided at the end of this policy to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data are processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the contact details provided at the beginning of this policy. Further explanations of your rights are available in the Glossary at the end of the policy.

How can I access my Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests can be made in writing, either via email or via the postal addresses shown below, or verbally, either in person or on the phone. 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.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. Alternatively, we may refuse to comply with your request in these circumstances.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required, up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

You also have the right to lodge a complaint about our processing of your personal data with the UK’s Information Commissioner’s Office.

Glossary

LAWFUL BASIS

There are six legal grounds on which we can rely to process personal data about individuals. We explain the relevant bases we rely on below:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Consent means that we ask you and give you a choice about whether or not you want us to process your personal data for a specific purpose. According to data protection law, consent must be specific, informed, freely given and unambiguous. For example, you can choose whether or not to sign up for a weekly newsletter, which we would clearly describe as a marketing communication and if you choose not to receive it then there is no detrimental impact on you in terms of the service or products you can receive from us. We will always ask for a positive action to opt-in where we rely on consent and always make it easy for you to withdraw your consent.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. For example, this will apply to any personal data we process to deliver products or services to you.

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Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, for example, Know Your Customer / Anti-Money Laundering regulations.

THIRD PARTIES

Internal Third Parties

Other companies in the CUDO Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.

External Third Parties

• Service providers acting as processors based in the UK, EEA and USA who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers 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 acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Charities acting as processors or joint controllers based in the United Kingdom to allow them to have visibility of the donations made to them.
• If your account is specifically being used to generate revenue for membership, subscription service or payment service your account ID and revenue/ cryptocurrency generated will be shared with the appropriate service provider so they can credit you accordingly.
• Please note that if you have made your profile ‘public’ then certain aspects of your profile will be visible to third parties.

YOUR LEGAL RIGHTS

Further definitions of your legal rights as explained in the policy above. You have the right to:

Be informed about the personal data that we hold about you. This means we won’t process your personal data without letting you know that we are doing so supported by the information provided to you via this privacy notice. Where we source personal data from a third-party rather than directly from you, we will let you know within a reasonable timeframe that we are processing your information – typically within one month.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Under the right to data portability you can request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.