Privacy Policy

Last updated: February 16th, 2024

This version is effective from 10^th June 2025

1 Introduction

1.1 This privacy notice (the “Privacy Notice”) explains our approach to our processing of your personal data which is any information relating to you (including by reference to identifiers associated with you or any device that you use to access our websites) in connection with the provision of our services (“Service”) that we make available via the following websites:  www.kope.ai, www.offsite.market, www.mmc.market, www.kope.market, app.kope.ai
and construct.kope.ai (“KOPE.AI Platform”).

1.2 Please take a moment to read this Privacy Notice as it provides you with important information about your personal data, including the rights you have in relation to it.

1.3 We will use reasonable endeavours to ensure that any changes we make to this Privacy Notice in the future will be posted on the KOPE.AI Platform and, where we have collected the relevant contact details, notified to you by email. Please check this page frequently to see any updates or changes to our Privacy Notice.

2 About us

2.1 The KOPE.AI Platform and our Service are made available by KOPE AI Ltd (“we”, “us”, “our”). We are an English company (No: 12180284) with its registered office at 86-90 Paul Street, London, United Kingdom, EC2A 4NE.  We are registered as a controller with the Information Commissioner’s Office (Registration No: ZB585256).

2.2 If you have any questions about this Privacy Notice, please email us at [e-mail].

3 How we collect and receive personal data

3.1 We collect and receive personal data using different methods:

(a) Personal data you provide to us. You may give us your personal data directly, for example, when you use our Service, contact us with enquiries, complete forms on our KOPE.AI Platform, subscribe to receive our marketing communications or provide feedback to us.

(b) Personal data your company provides to us. Your company may require you to use our Service and provide us with personal data, which may be used to register an account on our KOPE.AI Platform.

(c) Personal data we collect automatically, including through cookies and other similar technologies.            When you access and use our KOPE.AI Platform, we may collect personal data automatically, including through our use of cookies and other similar technologies.

(d) Personal data received from third parties. We may receive personal data from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide our KOPE.AI Platform and our Service or third parties that provide us personal data on your behalf.

(e) Publicly available personal data. From time to time, we may collect personal data that is available from public sources (including media publications) or that you or a third party may otherwise publish (for example on websites or posts on social media platforms).

4 Personal Data we hold about you

4.1 We may collect the following types of personal data about you:

(a) Identity Data: such as full name; username or password

(b) Contact Data: such as address and post code; telephone number; e-mail address; social media handle;

(c) Profile Data: such as information provided by you in your communications with us; information provided by you in our surveys, marketing and communications preferences; and

(d) Behavioural Data: such as data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about the referring URL (the webpage or other source that you were previously on before you reached our  KOPE.AI Platform); information about your use of our KOPE.AI Platform, such as pageviews and events; information about when your current or previous sessions started; details about any products you viewed or purchased through the KOPE.AI Platform;

(e) Usage Data:  such as information about your device when you access our KOPE.AI Platform including: IP address; browser type, browser version; operating system; MAC address; device manufacturer and model; device UDID/Android ID number; device IMEI number; and other diagnostic data.

4.2 We do not store or collect your payment card details.

That information is provided directly to our third-party payment processors whose use of your personal data is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

5 Our processing activities

We process your personal data for the following purposes:

(a) to provide our KOPE.AI Platform including improving the content on our KOPE.AI Platform to customise the content and/or layout of our KOPE.AI Platform pages to suit your needs and protect against misuse of our KOPE.AI Platform;

(b) to provide you with Service;

(c) to deal with customer services and enquiries, carry out surveys and obtain feedback and promotional material;

(d) to carry out our promotional and marketing activities (see further below);

(e) to carry out insight and analysis; and

(f) for business administration and legal compliance purposes.

For more information about these processing activities and our lawful basis for such processing, please see our Details of Processing Activities Section at the end of this Privacy Notice.

6 Marketing

6.1 We may from time to time use your personal data to send our marketing communications to you by email.  If you do not want to receive an email from us in the future, please let us know by sending us an email at the [e-mail].

6.2 If you supply us with your telephone number, we may, with your consent, contact you by telephone to give you information on our new products and on our new products and services or upcoming events. If having given your consent, you change your mind and do not want to receive such telephone calls from us in the future, please let us know by sending us an email at [e-mail].

6.3 From time to time and where you have given us permission to do so, we make your email address available to other reputable organisations whose products or services we think you might be interested in. If having given your consent, you change your mind and do not want to us to share your email address with other reputable organisations in the future, please let us know by sending us an email at [e-mail].

6.4 When contacting us to opt out of any marketing communication, please ensure that you provide us with accurate details of your name, address, e-mail and/or telephone number (as applicable) so that we can make an accurate record of your request and cease the applicable marketing communications.

7 Social Media Targeting

7.1 We may from time to time wish to display advertising on social media platforms.  It is in our legitimate interest to do so to promote our Service.

7.2 Please also note that the activities mentioned below are also subject to the privacy choices you have elected to make on such social media platforms.

7.3 You can opt-out of our sharing of your personal information with the third-party providers by exercising your rights as a data subject as set out below.

Advertising to you on social media and similar platforms

7.4 We may share your email address (usually in an encrypted or ‘hashed’ form) with the relevant social media platform to enable them to “match” your data with the data of their registered users of the respective platform. Where there is a successful match, we will display our advertising to you when you use the relevant platform. This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant service.

7.5 We will only share your personal data with the third-party providers of the social media platforms, so that we can advertise our Service to you when you use those Platforms, where you have provided your consent (where this is required) or where it is otherwise in our legitimate interests to do so to promote our Service.  

Advertising to others who share similar interests and characteristics to you (or if you are someone who sees such advertising)

7.6 In some circumstances, we may ask the social media platform to serve our advertising on users who “look like” our matched users (in other words users who share similar interests and characteristics to our existing customers).  This “matching” is based on information that the social media platforms has on its registered users. This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” you.

7.7 It is in our legitimate interests to share your personal data with the relevant social media platforms so that we can advertise our Service to other individuals that use those services and share similar interests and characteristics with you.

8 Disclosure of your Personal Data

8.1 We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

8.2 When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

(a) Third-party vendors who provide applications/ functionality, data processing or IT services: We share personal data with third parties who support us in providing our KOPE.AI Platform and help provide, run and manage our internal IT systems.

(b) Affiliates: we share personal data with our affiliates, which include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

(c) Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds.

(d) Delivery and courier companies: We share personal data with vendors who assist us in the delivery of our Service to our customers.

(e) Advertising service providers: We share personal data with third party advertising providers. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.

(f) Third-party post/email marketing and CRM specialists: We share personal data with specialist vendors who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.

(g) Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

(h) Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

(i) Other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

9 Transfers outside the UK and the European Economic Area (“EEA”)

9.1 Where necessary in order to provide our KOPE.AI Platform and our Service, we may transfer personal data to countries outside the UK and the EEA.

9.2 Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

9.3 When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.

(a) Adequacy decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK Government (as applicable).

(b) Standard contractual clauses: Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK Government which give personal data the same protection it has in Europe and/or the UK.

10 Cookies

10.1 We use cookies on our KOPE.AI Platform for identification, analysis and advertising purposes. By using the KOPE.AI Platform you consent to the storing and accessing of cookies on your device. To find out more about the cookies we use please see our Cookies Policy [https://www.kope.ai/policies/cookies].

11 Information security

11.1 The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we have appropriate security measures in place to protect your personal data, we cannot guarantee its absolute security.

12 How Long do we keep your Personal data?

12.1 We will only keep your personal data for as long as necessary for the purposes set out in this Privacy Notice.  We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

12.2 If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

12.3 If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

13 Third-party links

This Privacy Notice only applies to personal data processed by us through your use of our KOPE.AI Platform and/or in connection with our business operations. However, from time to time, our KOPE.AI Platform may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.

14 Personal data of minors

While our websites or Service are not intended for use by, or targeted at, minors (individuals under the age of 18), and we do not knowingly collect personal data of minors. However, this does not prevent minors from providing personal data to us. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.

If you are under the age of 13, you must not use our websites or purchase Service from us and you must not provide us with any personal data. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. Please contact us if you have reason to believe that a minor may have submitted personal data to us at [e-mail].

15 If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Service you have requested from us or to process an application to register an account. In these circumstances, we may have to cancel the provision of the relevant Service to you, in which case we will notify you.

16 Your rights as a data subject

16.1 You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please email us at [e-mail].

16.2 If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please email us at [e-mail].

16.3 You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

16.4 As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk. 

17 Detail of Processing Activities

Providing our KOPE.AI Platform

Activity	Description	Lawful Basis
Managing use of our KOPE.AI Platform	When you use our KOPE.AI Platform, we may process Usage Data to provide our KOPE.AI Platform to you. This includes keeping our KOPE.AI Platform secure and in working order, ensuring that we are showing you the correct notices and information. We use this information to manage and respond to your enquiry. For more information, please see our Cookie Notice [https://www.kope.ai/policies/cookies].	It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you in relation to your use of our KOPE.AI Platform, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our KOPE.AI Platform in a secure and effective way. We record preferences in relation to our use of cookies to comply with our legal obligations.
Set up user accounts	You may be required to register an account with us to use our Service. Account applicants will need to complete the registration form, providing all required Identity Data, Contact Data, Profile Data. We will use this data to open your account. Once the account is registered, we will process your Identity Data, Contact Data and Profile Data to identify you when you log in to your account and access secure areas of our KOPE.AI Platform. We will also process certain Usage Data and Contact Data so that we can administer your account and contact you about your account. We will also collect and process Usage Data when you use certain features and functionality on our KOPE.AI Platform. This data helps us understand how you use our KOPE.AI Platform so that we can improve it, and enables us to keep the accounts in working order.	It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the KOPE.AI Platform and our Service in a secure and effective way and so that we can make improvements to our KOPE.AI Platform.
Troubleshoot problems	We may use certain Usage Data (including crash reports and diagnostics data) collected through your use of our KOPE.AI Platform. This Usage Data may include information about errors affecting our KOPE.AI Platform, including which part of our KOPE.AI Platform is affected. This information helps us understand the cause of the error so that we can develop a fix to prevent that error from reoccurring and therefore improve our KOPE.AI Platform for all users.	It is in our legitimate interest to use personal data to detect and resolve errors.
Social media interaction	If you click on one of the social media links on our KOPE.AI Platform or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our KOPE.AI Platform or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Usage Data.	It is in our legitimate interest to ensure that we provide the KOPE.AI Platform in an effective way and to promote our KOPE.AI Platform via social media.

Providing our Service

Activity	Description	Lawful Basis
Supplying Service	We collect and maintain personal data that you submit to us for the purpose of supplying our Service that you have requested from us via our KOPE.AI Platform. We may collect and process your personal data where you are interacting with us or third parties on your own behalf or on behalf of any organisation you represent as part of the Service supplied. The personal data we process may include your Identity Data, Contact Data, Profile Data. We process this information so that we can fulfil the supply of Service, process any returns, maintain our user databases and to keep a record of how our Service are being used.	It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Service, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide our Service in an effective, safe and efficient way.

Customer service, enquiries and product returns

Activity	Description	Lawful Basis
Addressing general questions or issues concerning our KOPE.AI Platform or our Service	When you make an enquiry or request, we will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data, as well as any other personal data you volunteer that is relevant to your enquiry or request.	It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services.
Facilitating cancellation of our Service	If you wish to cancel our Service you have purchased from us, we will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data, as well as any other personal data you volunteer that is relevant to your return. We use this information to assist you with your return or cancellation.	It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Service, or it is in our legitimate interest to use personal data in such a way to ensure that we are able to help you with your cancellation, provide a good standard of service and improve our customer services.

Surveys and feedback and featuring in promotional material

Activity	Description	Lawful Basis
Collecting feedback on your experience of our KOPE.AI Platform and/or our Service	From time to time, we will invite you to provide feedback about us, our KOPE.AI Platform and our Service in the form of online surveys. We will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data, as well as any other personal data you choose to volunteer in your survey response or other feedback. We use this information to help us to monitor and improve our KOPE.AI Platform and our Service, to assist with the selection of future product and service lines and to train our personnel.	It is in our legitimate interest to use the personal data provided by you so that we can improve our KOPE.AI Platform and our Service and provide them in an effective way.
Featuring in promotional material	If you attend one of our events, we may use any photographs taken or testimonials provided or other content you may have published in our promotional materials.	If we wish to use your photographs, quotes, testimonials, or other content that you make available or publish in respect of a course you have attended, such processing of your such personal data will be based on consent.

Hosting events

Activity	Description	Lawful Basis
Organising and managing events	From time to time, we may organise and host events for the purpose of promoting our business or for charitable causes or other reasons. We may process your Identity Data and Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you. If you attend one of our events, we may use your Identity Data, Contact Data and certain Profile Data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications published on our KOPE.AI Platform, in print or other media. We may also send you SMS for operational purposes and the smooth running of an event, e.g. to inform you of a travel update.	It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way. If we use your photographs, quotes, testimonials, or other content that you make available or publish at the event, our lawful basis to process this personal data will be legitimate interest or in some circumstances your consent.

Promotions

Activity	Description	Lawful Basis
Administering our promotions	From time to time, we may run promotions on our KOPE.AI Platform and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data, Profile Data, Behavioural Data and/or Usage Data and any other personal data volunteered by you in relation to your promotion entry. Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.	It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.
Supporting your promotion of our Service on social media	If you agree to display our Service on social media, we may process your Identity Data and Contact Data and any other personal data volunteered by you to communicate with you and to administer the promotion of our Service.	We may specifically ask your permission to use your photographs, quotes, videos, or other content that you make available or publish on your social media platform. Where this is the case, our processing of your such personal data will be based on consent. It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to promote our products on your social media platform, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to enable us to promote your public enjoyment of our products.

Insight and analysis

Activity	Description	Lawful Basis
Understand you and your use of our KOPE.AI Platform and our Service	We and our third-party partners use cookies to collect Behavioural, Usage Data and certain Profile Data from the devices that you use to access our KOPE.AI Platform, our Service and any emails that you receive from us. Please see our Cookie Notice [https://www.kope.ai/policies/cookies] for further information, including details of our third-party partners. In particular we and our third-party partners use this data to analyse how you use our KOPE.AI Platform and our Service and the effectiveness of our KOPE.AI Platform and our Service, including: a) for social media retargeting; b) to provide you with a personalised experience when you use our KOPE.AI Platform; c) to analyse how you use, and the effectiveness of, our KOPE.AI Platform and our Service; d) to count users who have visited our  KOPE.AI Platform or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve our KOPE.AI Platform, our Service and the effectiveness of our emails; e) to measure the effectiveness of our content; and f) to learn what parts of our KOPE.AI Platform are most attractive to our users, which parts of our KOPE.AI Platform are the most interesting and what kind of features and functionalities our visitors like to see; and g) to help us understand the type of marketing content that is most likely to appeal to our visitors and customers; and h) to help us with the selection of future product and service lines, website design and to remember your preferences.	Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice [https://www.kope.ai/policies/cookies] for further details. In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our KOPE.AI Platform, it is in our legitimate interest to use your personal data in such a way to improve our KOPE.AI Platform and our Service.

 Business administration and legal compliance

Activity	Description	Lawful Basis
Complying with our legal obligations or in connection with the administration of our business	We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.	Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order. We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.