This privacy policy applies between you, the User of this Website and Yasiel Limited (trading as Kriva), the owner and provider of this App. Kriva takes the privacy of your information very seriously.This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the App.

This privacy policy should be read alongside, and in addition to, our EULA.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data
collectively all information that you submit to Kriva via the App. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Data Protection Act 2018, the UK GDPR, and any national implementing laws, regulations and secondary legislation;

Estate Agent
the person that invited you to use the App

GDPR
the General Data Protection Regulation (EU) 2016/679;

Kriva, or us
Yasiel Limited, which trades as Kriva, a company incorporated in England and Wales with registered number 10968702 whose registered office is at 3 & 5 Station Road, Keynsham, Bristol, BS31 2BH;

User or you
any third party that accesses the App; and

App
the App that you are currently using,

In this privacy policy, unless the context requires a different interpretation:

• the singular includes the plural and vice versa;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• reference to any statutory provision includes any modification or amendment of it; and
• the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

2. This privacy policy applies only to the actions of Kriva and Users with respect to this App.

3. Any data you have provided to your Estate Agent that is used by the App will be subject to the Estate Agent’s Privacy Policy and you should refer to them for details. In respect of such data Yasiel is a processor, acting under the instructions of your Estate Agent.

4. For purposes of the data we collect from you, Kriva is the “controller”. This means that Kriva determines the purposes for which, and the manner in which, the Data you provide to it is processed.

Data collected

5. We may collect the following Data, which includes personal Data, from you:

• name;
• email address;
• IP address (automatically collected);
• web browser type and version (automatically collected);
• operating system (automatically collected);
• your activity on this App,

in each case, in accordance with this privacy policy.

How we collect Data

6. We collect Data in the following ways:

• data is given to us by you;
• data is received from other sources; and
• data is collected automatically.

Data that is given to us by you

Kriva will collect your Data in a number of ways, for example:

• when you download the App;
• when you use the App;

in each case, in accordance with this privacy policy.

Data that is received from third parties

8. Kriva will receive Data about you from your Estate Agent.

Data that is collected automatically

9. To the extent that you access the App, we will collect your Data automatically, for example we automatically collect some information about your visit to the App. This information helps us to make improvements to App content and navigation, and includes your IP address, the date, times and frequency with which you access the App and the way you use and interact with its content.

Our use of Data

10. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our App. Specifically, Data may be used by us for the following reasons:

• internal record keeping;
• improvement of our App and services;
• advising your Estate Agent of your use of the App and requests for additional users,

in each case, in accordance with this privacy policy.

11. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

12. When download the App, the legal basis for this processing is the performance of a contract between us and your Estate Agent.

Who we share Data with

13. We may share your Data with the following groups of people for the following reasons:

• your Estate Agent so they are aware of you use of the App;
• our employees, agents and/or professional advisors – so as to monitor and improve the App;
• third party service providers who provide services to us which require the processing of personal data – Digital Ocean (httpss://www.digitalocean.com/), Scale Grid (httpss://scalegrid.io/) and Google Firebase (httpss://firebase.google.com/) and Blaze Concepts (httpss://www.blazeconcepts.co.uk/) so as to provide the technology that provides the App,

in each case, in accordance with this privacy policy. We will give 30 days’ notice of any change to or addition to this list.

Keeping Data secure

14. We will appropriate use technical and organisational measures to safeguard your Data, for example:

• access is controlled by a password and a user name that is unique to you.
• we store your Data on secure servers.

15. These technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: support@kriva.co.uk

16. We store our data within the UK.

Data retention

17. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

18. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

19. You have the following rights in relation to your Data:

• Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
• Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
• Right to erase – the right to request that we delete or remove your Data from our systems.
• Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
• Right to data portability – the right to request that we move, copy or transfer your Data.
• Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

20. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: support@kriva.co.uk

21. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at httpss://ico.org.uk/.

22. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Changes of business ownership and control

23. Kriva may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Kriva. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

24. We may also disclose Data to a prospective purchaser of our business or any part of it.

25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

26. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

Changes to this privacy policy

27. Kriva reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the App and you are deemed to have accepted the terms of the privacy policy on your first use of the App following the alterations.

You may contact Kriva by email at support@kriva.co.uk

January 2022