Last updated: 6 November 2020
Welcome to Komi. Unlock your potential.
This Policy sets out the basis on which any personal data we collect from you, or that you provide to us through our mobile / tablet applications or our website (https://komiapp.co/) (together, “Komi”) will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including the EU General Data Protection Regulation 2016 (“GDPR”) and the UK Data Protection Act 2018. Where we decide the purposes and means for the processing of your personal data, we are the data “controller” for the purposes of the GDPR.
You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.
How we use it
Account information (information provided by you when creating an account on Komi)
We process this information in accordance with the terms of our contract with you (for consumer users, being the Komi Terms of Service; for talent users, being the Komi Terms for Talent). For example, we need your contact details to create your account and to process purchases you make.
Additionally, we rely upon our legitimate interests for this processing activity, being our interests in promoting the success of our business by providing you with a quality service with additional functionalities relating to your account with us.
This information is provided by us to our payment processor vendors where necessary.
Newsletter, SMS and marketing messages (information provided by you when signing up to our newsletter or marketing emails)
Consent-based mailing lists
We may process your data to make suggestions and recommendations to you and other users of Komi about: (i) news and updates relating to us, our partners, products, services and content; (ii) content, goods and services that may interest you; and (iii) other promotional activity and events we think may be of interest.
‘Soft opt-in’ mailing lists
In some instances (such as with some of our existing customers) the law may permit us to process your personal information in order to send information to you by marketing messages that we think is of interest for you on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and Komi, content, products and services. We may process your information for this purpose.
If the information is not of interest for you, you can opt-out at any time by emailing us.
We may share your data with email and marketing message vendors to assist us.
Support / enquiry information (information we receive when you get in touch with us for support)
We process this information either in accordance with the terms of our contract with you (for consumer users, being the Komi Terms of Service; for talent users, being the Komi Terms for Talent) (where we need this information to provide our services to you) or in pursuit of our legitimate interests in responding to your enquiry and in order to improve our services (promoting the success of our business).
We may share this information with vendors who assist us with managing customer services enquiries.
Social media information (information we may receive when you link your account to your social media profiles, visit our social media channels or share our content on social media)
For this processing activity, we rely upon your prior consent as the supporting legal basis.
In some cases, this may be a consent provided by you through the relevant third party social media platform and/or a prompting notice provided by them.
Where you link your Komi account to your social media profiles, or when you are logged into your social media account and share content from Komi, we may receive information about you from the social media platform and such platform may receive information or your activity on Komi.
Analytics (collected from your device and interaction with Komi)
We may process this information (on its own or together with your account information) so that we can: (i) understand usage of our services and improve our services, such as by prioritising serving content in our services to you which we think is more interesting for you; (ii) identify and solve problems or bugs; and (iii) develop new services or content we think will be of greatest interest.
We do this in pursuit of our legitimate interests, being our commercial interests in ensuring that our service functions well so that you and other users have the best experiences (promoting the success of our business).
To the extent that our analytics depends on storing or accessing non-essential cookies or other information on or from your device, we will obtain your prior consent.
We use Google Analytics (https://support.google.com/analytics/answer/6004245) to help us understand how our website and services are used.
We may share this information with our trusted business partners or with Komi Talent account holders in an aggregated and non-personally identifiable form.
Competition and promotion related entry information (information we receive when you enter a competition / prize promotion with us such as over email or over social media):
We process this information for the purposes of managing and fulfilling the purposes of the competition and promotion.
We rely up the legal basis of performance of a contract for this processing activity, being the applicable terms governing the competition / promotion that we may make available.
Content information (any information or content, such as user-generated content, you submit to us through your use of Komi such as images, videos, live streams, reviews, comments and other information concerning your use of Komi)
We process this information either in accordance with performing the terms of our contract with you (for consumer users, being the Komi Terms of Service; for talent users, being the Komi Terms for Talent) (where we need this information to provide our services to you) or otherwise in pursuit of our legitimate interests in promoting the success of our business (by providing additional functionality and features to you).
Please note that your submitted content (such as posts, comments, reviews or, for talent, content / services made available for purchase), will be viewable by other Komi users. Subject to us having the right to do so, we may also use this content in Komi marketing and promotional materials
Push notifications (when your device sends you a notification of an activity in Komi applications, such as about a new piece of content available for purchase)
Where required by law, we will obtain your prior consent before sending you push notifications through our applications.
In some cases, you may provide the foregoing consent at a ‘device level' and/or the option for you to consent to the notifications may be prompted through your device rather than our application.
For most mobile and tablet devices, push notifications can be disabled in your device settings.
All questions, comments or enquiries should be directed to us through our customer services options available within our services (such as by contacting our customer services team within our Komi applications).
COOKIE AND ANALYTICS POLICY
Last updated: 5 November 2020
Cookies are small text files that are placed on your computer or mobile/tablet by websites that you visit or applications you use. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies and analytics tools we use and why.
Purpose/ Third Party Access
This cookie is used to collect information about how visitors use Komi. We use the information to compile reports and to help us improve our services. The cookie collects information on the number of visitors, where visitors have come to the website from and the webpages or app screens they visited. We do not facilitate the merging of personally-identifiable information with non-personally identifiable information. We collect the following information through Google Analytics: Bounce Rate, Sessions, Average Pages per sessions, Bounce Rate, where our users come, from (is it organic, social, referral, email), Device usage, Gender, Age range, User interests, what else are the users interested in, Time of day that website is used, Location, Page Views, Entrances, Exits, Average time on page, Returning visitors vs New Downloads, Social Share.
Read Google’s overview of privacy and safeguarding data here.
This cookie will be set on your device for the purpose of remembering your cookie consent preference. This cookie will be set even where you reject all cookies in the cookie consent tool, so that we know not to place any other cookies on your device on your visits to Komi.
During your session
To log you into Komi and keep you logged in, and to ensure that your shopping basket stays full when you move from page to page.
To remember information about you such as your preferred language and configuration.
HOW DO I CHANGE MY COOKIE SETTINGS
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit https://www.allaboutcookies.org/.
Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.