This notice explains how we use personal data about website visitors, account contacts, users and people who contact us. It also explains the different arrangements for personal data in a subscribing business’s appraisals and other content.
1. Who we are
Kinda Living Ltd, trading as Kettly, is the controller where we decide why and how personal data is used for our own account administration, security, billing and communications. We are a company registered in England and Wales, company number 16785491. Email: hello@kettly.co.uk.
2. Personal data in customer content
We normally process personal data in appraisals, notes, uploaded documents and customer audit records on the subscribing business’s instructions under our data processing agreement. The business may be a controller or may be acting for its own client. That organisation’s privacy information explains its reasons for using this data and its lawful basis.
For requests about that information, contact the relevant business. If you contact us, we will help identify the appropriate organisation and pass the request on securely where appropriate. We remain responsible for requests about processing for which we are the controller.
3. Where personal data comes from
We receive information directly from you when you contact us, start a free trial, use Kettly or provide billing details. Your business may provide your name, work email, role and account permissions so we can invite you to use the service. When you start a free trial, Cloudflare Turnstile checks that the form is being filled in by a person, using your IP address and browser details. Our systems and providers generate necessary authentication, security, request and payment records as the service operates. We do not obtain information for advertising profiles.
4. What we use and why
| Information | Purpose and lawful basis | Retention |
|---|---|---|
| Name, work email, business, role and account permissions | Set up and administer access; communicate with account contacts. Legitimate interests in delivering and administering the business service. Contract where the individual is the contracting customer and the processing is necessary for that contract. | While the person has access. Removing a user switches their login off at once; it is kept only so that their name still shows in the history of appraisals they worked on, which is part of the business’s content. |
| Authentication records, password hashes, session identifiers and MFA configuration data where applicable | Authenticate users and protect accounts. Legitimate interests in service security. We do not store readable passwords or hold a copy of your authenticator app. | Sessions end when you sign out, when you close the browser tab unless you chose “Keep me signed in”, and when access is removed. Passwords are held only as one-way hashes, for as long as the login exists. |
| Sign-in time, IP address, browser and related security events | Detect misuse, investigate incidents and secure the service. Legitimate interests in protecting users, customers and Kettly. | 12 months from the event, unless a specific incident needs longer. |
| Name, work email and company name from the free trial form; a one-way fingerprint (keyed hash) of the email address | Run the free trial, and allow one trial per email address. Legitimate interests in offering a fair free trial. | The trial account, its content and its login are deleted 30 days after the trial ends, unless the business subscribes. The fingerprint holds no readable address and is kept for 2 years, so that a trial can’t be repeated. |
| Billing contact, invoices, transaction references and payment status | Administer payment using legitimate interests for corporate contacts; contract where the person is the contracting customer; legal obligation for required accounting and tax records. | Normally six years from the end of the relevant financial year, or longer where tax law requires. Payment providers apply their own relevant retention duties. |
| Enquiries, support correspondence, feedback and attachments | Answer enquiries, resolve issues and improve support. Legitimate interests in customer service and maintaining the product. | Correspondence and form submissions: 24 months after the matter closes. An appraisal attached to feedback is deleted once it is no longer needed for support. |
| IP address, browser, requested resource, timestamp and diagnostic request records | Operate, troubleshoot and secure the service. Legitimate interests in reliable and secure operation. | Up to 7 days in our hosting provider’s logs; longer only for a specific incident. |
| Accepted orders, key contractual notices and records needed for disputes | Establish, exercise or defend legal claims and administer the contract. Legitimate interests; legal obligation where applicable. | Normally six years after the contract ends; longer only where needed for an ongoing claim or legal requirement. |
When relying on legitimate interests, we assess the purpose, necessity and impact on you. We keep only what is needed. If a longer retention period is justified for a particular matter, we restrict use and review when it can end.
5. Who receives information
We use service providers for hosting, authentication, document processing, email delivery, support and payments. The provider register accompanying our data processing agreement identifies their functions, relevant information, roles and locations. Providers acting as our processors must follow our instructions and appropriate contractual protections.
Some providers, including Stripe for certain payment, fraud-prevention and regulatory activities, act as independent controllers. Their privacy notices explain those activities. Where needed, we also disclose limited information to professional advisers, insurers, authorities or a business buyer, subject to a lawful basis and appropriate confidentiality and data-protection safeguards.
We do not sell personal data or use it for advertising. We do not use customer content to train AI models. Optional autofill involves provider processing and retention described in the register; absence of model training does not mean immediate deletion.
6. International processing
Our primary customer database is in London, United Kingdom. Other processing, remote access and support may take place outside the UK. The completed provider register identifies relevant countries and safeguards; the database location does not describe every processing activity.
For restricted transfers we use a lawful mechanism appropriate to the actual recipient and processing: applicable UK adequacy regulations, including the UK Extension to the EU-US Data Privacy Framework where certification covers the transfer, or appropriate safeguards such as the UK International Data Transfer Agreement or EU standard contractual clauses with the UK Addendum. Where required, we assess the protection provided and implement supplementary measures. Contact hello@kettly.co.uk for information or a copy of the relevant safeguards, with confidential details redacted where necessary.
7. Your rights
Depending on the circumstances and lawful basis, you may ask to access, correct or erase your personal data, restrict its use, object to processing based on legitimate interests, or receive relevant data in a portable form. Portability does not apply to every category of information. If we rely on consent for a particular activity, you may withdraw it without affecting earlier lawful processing.
Contact hello@kettly.co.uk. We respond without undue delay and normally within one month. Where the law permits an extension, verification or clarification, we will explain what is needed and any effect on the response period. Rights are subject to applicable legal conditions and exemptions; removing a login does not automatically require deleting necessary customer audit records or statutory accounts.
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. AI autofill suggests appraisal information for a user to review; it does not itself approve transactions or determine individual eligibility.
8. Questions and complaints
You can raise a data-protection concern or complaint at hello@kettly.co.uk. You do not need to use a special form or legal terminology. We will acknowledge a complaint within 30 days, make appropriate enquiries without undue delay, keep you informed as appropriate and explain the outcome.
You may also complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint or by calling 0303 123 1113. We would welcome an opportunity to address your concern directly. The ICO explains its own complaint-handling process on its website.
9. Browser storage and cookies
Kettly uses your browser’s storage, not cookies, to keep you signed in and to remember the display choices you make. Both are part of the service you ask for.
Sign-in storage is strictly necessary for the service. Display choices are remembered because Kettly would be hard to use without them: the lines and panels you fold, which site folders are open, the revisions ticked to compare, the last appraisal you had open and whether you have seen the welcome. They stay in your browser and hold no appraisal figures. You can remove them at any time by clearing your browser’s data for kettly.co.uk.
| Storage purpose | Information and duration | User control |
|---|---|---|
| Sign-in and security | Session tokens, kept for the browser tab, or until you sign out if you choose “Keep me signed in”. | Signing out removes the local session information. Blocking necessary storage may prevent sign-in. |
| Display preferences | Folded lines and panels, open folders, revisions ticked to compare, the last appraisal open and whether the welcome has been seen; kept until you clear them. | Clearing your browser’s data for kettly.co.uk removes them. |
We do not use advertising trackers. We count visits to kettly.co.uk with Cloudflare Web Analytics, which sets no cookies, uses no browser storage and does not follow you across other websites: it records the page, the site you came from, your browser and device type and your country. It is not used inside Kettly itself. The free trial form uses Cloudflare Turnstile, which may use its own storage to check that you are a person. External payment pages may use their own cookies and storage, explained on those pages. Clearing browser data also removes locally stored information; it does not delete information held on our servers.
10. Security and updates
We use access controls, encryption and other appropriate measures to protect personal data. Our customer-processing safeguards are described in Annex B of the data processing agreement. No service can guarantee absolute security; report suspected misuse promptly.
We publish changes to this notice here and notify affected people where appropriate. A changed notice does not by itself authorise an incompatible new use of personal data or change our customer contracts.