PRIVACY TERMS AND CONDITIONS FOR ALL USERS
This notice applies to users of Kudoti’s services including users of Kudoti’s application, website, or other services.
This notice describes how the Kudoti and its affiliates collect and use personal data. This notice specifically applies to:
Environmental Assistants / Waste Pickers: individuals who are approved and registered waste pickers on the Kudoti Application. These users collect and/or sort waste.
Buy Back Center (“BBC”) Owners and Agents: Individuals who are approved and registered BBC owners or agents on the Kudoti Application. These users operate waste sorting and storage facilities, who can purchase waste from the Environmental Assistants / Waste Pickers.
Waste Transporters: individuals and/or entities that transport the collected waste from BBCs to regional/municipal waste sorting plants and recyclers.
Sustainability Project: a project that Sustainability team’s of some of Kudoti’s customers are implementing to assist communities of informal waste handlers to organize, skill-up, scale up and grow in terms of the environment, social and economic returns they are able to generate from their efforts. Sometimes referred to as Kudoti in these terms and conditions.
These terms and conditions also apply to Kudoti’s other collections of personal data in connection with Kudoti. For example, we may collect other personal data in connection with our reporting requirements and mapping technology and features.
All individuals subject to these terms and conditions are referred to as “users”.
Our data practices are subject to applicable laws in the places where we operate. This means that we engage in the practices described only if permitted under the existing laws.
2. Responsible party and operator
Kudoti and the registered users are the Responsible Parties for the personal data collected in connection with users’ participation with the Kudoti network.
Kudoti (Pty) Ltd are the data operators for the personal data collected in connection with use of the Kudoti Application.
We process personal data inside South Africa and store it safely in regional Amazon Web Services Data Centers. The personal data of users stored outside South Africa is transferred according to applicable laws.
3. Data collections and uses
3.1. The data we collect. Kudoti collects:
Data provided by users to Kudoti, such as during profile creation, training sessions, event attendances, logging waste collection proofs, the other users or accounts you interact with, such as the other user profiles you are connected to and how you interact with them, recording income generated and earned through users participation in the Kudoti network.
Data from other sources, such as Kudoti partners such as the BBC Agents or other third parties.
The following data is collected by or on behalf of Kudoti:
3.1.1 Data provided by users. This includes:
User profile: We collect data when users create or update their Kudoti accounts.
This may include their name and surname, physical address, contact number, photograph, alternative contact number, identity number, birth date, income range per month, area of operation, literacy level, training received through Kudoti, and tools or equipment provided.
Identity verification: We collect identity verification information for some users for purposes of, including but limited to receipt generation, user support, fraud detection.
This information may be collected by an authorized vendor on Kudoti’s behalf.
Location data: We collect approximate location data from a user’s profile to link environmental assistants/waste pickers with registered BBCs and environmental assistants/waste pickers with other environmental assistants/waste pickers.
Demographic data: We collect demographic data about users, including through user surveys and data requested from users when they create a profile, for purposes of, including but not limited to receipt generation, waste collection efficiencies, user support, fraud detection.
User content: We collect the information users submit when they contact Kudoti support. This may include feedback, photographs or other recordings collected by users when making user requests or complaints.
Information about transactions: We have sight of and collect data about trade and/or transactions between users.
3.1.2. Data created during use of the Kudoti Application. This includes:
Basic proof of work information: We collect transaction information related to the use of the Kudoti Application, including the type of services requested or provided, order details, waste collection and delivery information, date and time of collection and delivery, prices for materials charged, and whether payments are made.
Usage data: We collect data about how users interact with the Kudoti Application. This includes data such as access dates and times, or pages viewed, application crashes and other system activity, type of browser, and third-party sites used before interacting with the Kudoti Application.
Information and content you provide: We collect the content, communications and other information you provide on your profile and on the Application, including when you sign up for an account, create content and message or communicate with others. This can include information in or about the content that you provide (e.g. metadata).
Networks and connections: We collect information about the users that you are connected to and how you interact with them on the Application, such as users you communicate with the most or networks that you are part of.
Device data: We may collect data about the devices used to access the Kudoti Application or use the Kudoti tools, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, serial numbers, device motion data, and mobile network data.
Communications data: We enable Kudoti or authorised third parties to call, text, or send other files to users. To provide this service, Kudoti receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications.
Kudoti may also use this data for incentive and rewards mechanisms and user support services (including to resolve disputes between users), for safety and security purposes, to improve the Kudoti Application, and for analytics.
Equipment and training data: We collect data records of the identities of users who have been issued with certain equipment, such as trolleys, protective gear, scales or other waste management related devices.
3.1.3. Data from other sources. This includes:
Users or others providing information in connection with claims or disputes.
Vendors who help us verify users’ identity, background information, for eligibility to work, for regulatory, safety, and security purposes.
Publicly available sources.
Kudoti may combine the data collected from these sources with other data in its possession.
4. How we use personal data
Kudoti collects and uses the data we collect:
- To track waste collection by users;
- To track user development;
- To track skills enablement of users;
- To track the provision of facilities and tools to users;
- To facilitate market-place or waste processor connection;
- To enhance the security of our users participating in the Kudoti network;
- To determine and allocate incentives and rewards mechanisms for users;
- For user support;
- For research and development.
Kudoti does not sell or share user personal data with third parties for their direct marketing.
Kudoti uses the data it collects for purposes including:
4.1. Improving the Kudoti Application. Kudoti uses the data we collect to provide, maintain, and improve the objects of the users and sustainability projects.
This includes using the data to:
- Create and update users’ profiles and dashboards.
- Verify users’ identity and eligibility for participation in the Kudoti network.
- Facilitate market-place or waste processor connection.
- Facilitate generating records of proofs of work and/or payments.
- Track and share the progress of the Recyclers, Sustainability networks and of users participating therein.
- Perform internal operations necessary to facilitate the Kudoti network, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.
4.2. Safety and security. Kudoti (Pty) Ltd develops and maintains the Kudoti application, the application and the data are hosted on Amazon Web Services.
We use personal data to help maintain the safety, security, and integrity of the Kudoti Application and users. This includes:
Screening users before enabling their complete registration as a user to ensure adequate training and verification. This also includes comparing details that we have on file against special identifying data of other users to prevent identity-borrowing.
Profile passwords must be updated by each user on a three-month cycle. For user’s security, users are required to personally select a password for their profile.
Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
We follow Amazon Web Service's best practise of protocols as described here.
4.3. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience.
This helps us to improve and enhance the objects of the Kudoti network, improve our ability to prevent the use of the Kudoti Application for illegal or improper purposes, and facilitate appropriate community upliftment schemes through training or similar support.
We may use the data we collect to personalize marketing communications that we send, including based on user location, and past use of Kudoti’s application, training received, and tools or equipment issued.
4.4. Non-marketing communications. Kudoti may use the data we collect to generate and provide users with information about key events, training sessions, materials pricing updates and other activities essential for the development of the Kudoti network; receipts; or inform them of changes to our terms.
4.5. Legal proceedings and requirements. We may, but are not obliged, to use the personal data we collect to investigate or address claims or disputes relating to use of Kudoti’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
4.6. Automated decision-making. We use personal data to make automated decisions relating to use of our application. This includes deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Kudoti, its users, and others.
Data sharing and disclosure
Some of Kudoti’s applications and initiatives, require that we share data with other users. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with sponsor reporting obligations or claims or disputes. Kudoti may share the data we collect:
5.1. With other users. This includes sharing:
User’s first name and surname, the user’s selected BBC, the user’s waste collection history, and previous earnings from waste collection activities through the Kudoti network.
For BBCs we may share data with environmental assistants / waste pickers such as physical address(es), contact details, name, surname and photo of BBC agent(s).
BBC owner or agent’s first name and surname and other registered users associated to the functioning of the BBC with Kudoti administrators and user support.
For environmental assistants / waste pickers, we may share data with the BBC(s), such as name and photo, approximate location, total record of waste collection, earnings generated from the user’s participation in the Kudoti network, length of registration as a user of the Kudoti Application, and contact information.
We also provide users with receipts containing information such as a breakdown of weight of waste collected, the BBC to which the waste was delivered, the date and/or time of delivery and such other information required on basic receipts of work.
5.2. At the user’s request. This includes sharing data with other people at the user’s request. For example, for registration purposes when Kudoti facilitates training that will be provided by a third party.
5.3. With Kudoti subsidiaries and affiliates. We share data with our subsidiaries and affiliates to help us provide the Kudoti Application or conduct data processing on our behalf. For example, Kudoti through Kudoti (Pty) Ltd operates data and may store data in servers situated in the United States or the United Kingdom.
5.4. With Kudoti service providers and business partners. Kudoti provides data to consultants, research firms, and other service providers or business partners. These include:
- Research partners, including those performing surveys or research projects in partnership with Kudoti or on Kudoti’s behalf
- Identity verification providers
- Cloud storage providers
- Payment processors and facilitators
- Marketing partners and marketing application providers
- Data analytics providers
- Vendors that assist Kudoti enhance the security of its application and the provision of tools and equipment
- Consultants, lawyers, accountants, and other professional service providers
6. Data retention and deletion
Kudoti retains user profiles, transactions, and other personal data for as long as a user maintains their Kudoti profile.
Kudoti may retain certain user data after receiving a profile deletion request if necessary, such as to comply with legal requirements.
Users may request the deletion of their profile at any time through email@example.com
Following such requests, Kudoti deletes the data that it is not required to retain for purposes of regulatory, tax, or other legal requirements. For example, Kudoti retains some data for these purposes; while it retains such data, it may also use it for purposes of security, fraud prevention and detection, and research and development.
7. Grounds for processing
We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to facilitate the Kudoti network, for purposes of Kudoti’s legitimate interests or those of other parties, to fulfil our legal obligations, or based on consent.
We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary, but generally include processing personal data:
7.1. To facilitate the Kudoti network. In order for the Kudoti application to function, we must collect and use certain personal data. This includes:
- User profile data, which we use to establish and maintain user profiles, verify user identity, communicate with users about their equipment, training and accounts, and enable users to determine the value of waste collected to receive fair payments or earnings
- Usage data, which is necessary to maintain, optimize, and enhance the Kudoti Application, including to connect waste pickers/environmental assistants with BBCs and/or sorting plants, and record the weight and value of waste collected
- Transaction information
- Information relating to user support
7.2. For purposes of the legitimate interests of Kudoti or other parties
We use personal data to maintain and enhance our users’ security, including purposes such as combating fraud; improving the Kudoti Application, direct marketing, research and development.
7.3. To fulfil Kudoti’s legal obligations
Kudoti may share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.
8. Updates to this Agreement
We may occasionally update these terms and conditions. Use of the Kudoti Application after an update constitutes consent to the updated notice to the extent permitted by law.
We encourage users to periodically review these terms and conditions for the latest information on our privacy practices.