KAYO PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy explains how Streamline Power Solutions Ltd trading as Kayo (“Kayo”, “we”, “us”, “our”) collects, uses, stores, shares and protects personal data.

This Privacy Policy applies to personal data collected by Kayo through our website, app, booking systems, customer portal, phone calls, emails, WhatsApp messages, text messages, social media, in-person contact, job attendance, quotations, customer accounts, contractor onboarding, employee administration and other business operations.

Kayo is committed to handling personal data lawfully, fairly and transparently in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection laws.

2. WHO WE ARE

Data Controller:

Streamline Power Solutions Ltd trading as Kayo

Company details:

• * Company name: Streamline Power Solutions Ltd trading as Kayo
• * Company number: [Insert Company Number]
• * Registered office / trading address: [Insert Address]
• * Email: [Insert Privacy / Contact Email]
• * Phone: [Insert Phone Number]
• * Website: [Insert Website]

Kayo is the controller of the personal data described in this Privacy Policy except where we clearly state otherwise.

3. WHO THIS PRIVACY POLICY APPLIES TO

This Privacy Policy may apply to personal data relating to:

• * customers and prospective customers;
• * property owners, occupiers, tenants, landlords and agents;
• * people making enquiries, requesting quotations or booking services;
• * people using our website, app, booking system, customer portal or payment pages;
• * people contacting us by phone, email, WhatsApp, text message, social media or web forms;
• * tradespeople, engineers, contractors and subcontractors working with or applying to work with Kayo;
• * employees, office staff, applicants and workers; and
• * anyone else whose personal data Kayo processes in the course of operating its business.

4. WHAT PERSONAL DATA WE MAY COLLECT

Depending on your relationship with Kayo, we may collect and process the following categories of personal data.

4.1 Customer, enquiry and booking information

We may collect:

• * full name;
• * service address, billing address and other relevant property addresses;
• * email address;
• * phone number;
• * booking details and appointment history;
• * job details, service requirements and property information;
• * customer account, portal or booking system details;
• * communication preferences;
• * photographs, videos and information you provide about faults, damage, works, access or property conditions;
• * complaint details, review details and customer service records;
• * landlord, tenant, managing agent or authorised contact details where relevant; and
• * any other information you provide to us in relation to a booking, enquiry or service.

4.2 Property and job-related information

We may collect and generate information relating to a property, booking or job, including:

• * property address and access details;
• * fault descriptions, job notes and internal assessments;
• * tradesperson / engineer attendance records;
• * quotations, invoices, certificates, reports and compliance records;
• * photographs, videos, test results, readings and inspection findings;
• * before-and-after job records;
• * call notes, call recordings where applicable and lawful, and communication logs;
• * complaint, dispute, refund, chargeback and callback records; and
• * records of recommendations, remedial works, safety issues and historical works carried out at a property.

4.3 Payment and financial information

We may collect:

• * billing address;
• * invoice records;
• * payment status and transaction references;
• * deposit records, refund records and outstanding balance records;
• * limited payment-related information provided by payment providers or processors; and
• * records needed for fraud prevention, debt recovery, chargeback handling and financial administration.

Kayo intends to use Stripe and may use other payment service providers from time to time. Kayo does not intend to store full payment card details itself unless specifically necessary and lawfully handled through appropriate secure systems. Payment card processing may be carried out by third-party payment providers such as Stripe.

4.4 Communications and customer service records

We may collect and store records of communications with you, including:

• * emails;
• * WhatsApp messages, including messages sent via WhatsApp Business;
• * text messages / SMS;
• * website or app chat messages;
• * customer support messages;
• * call notes;
• * call recordings where used and lawful;
• * complaint records;
• * review request and response records; and
• * internal notes made by Kayo in relation to your enquiry, booking, complaint, account or property history.

4.5 Website, app and technical usage information

When you use our website, app or digital systems, we may collect:

• * IP address;
• * device type;
• * browser type;
• * operating system;
• * website usage information;
• * app usage information;
• * login details and account activity;
• * cookies and similar technologies;
• * dates, times and pages viewed;
• * referral sources; and
• * other technical or analytics information generated through use of our digital services.

4.6 Tradesperson / contractor information

Where you work with Kayo or apply to do so, we may collect:

• * name, address, contact details and date of birth where relevant;
• * business name and trading details;
• * right to work evidence;
• * qualifications, competency records and training information;
• * insurance documents;
• * DBS or background information where applicable and lawful;
• * bank details for payment;
• * UTR, VAT and tax-related contractor information where relevant;
• * job allocation records, performance notes, callback records and complaint records;
• * photos, documents, certificates, app uploads and operational records linked to Kayo jobs; and
• * disciplinary, suspension, investigation or contractual records where relevant.

4.7 Employee / worker / applicant information

Where you apply to work for Kayo or work for Kayo, we may collect:

• * name, address, phone number, email address and date of birth;
• * CV, work history, references and qualifications;
• * right to work documentation;
• * payroll, tax, pension and bank details;
• * attendance, absence and HR records;
• * disciplinary, grievance and performance records;
• * emergency contact details;
• * system access records and work communications; and
• * any other information reasonably required for recruitment, employment and business management.

4.8 Photos, videos, certificates and visual records

Kayo may collect, create or receive photographs, videos and visual records relating to:

• * job quoting;
• * works carried out;
• * damage or defects;
• * quality control;
• * certification and compliance;
• * customer complaints;
• * callback investigations;
• * contractor performance;
• * health and safety;
• * insurance claims; and
• * legal disputes.

These records may sometimes incidentally capture individuals, household items, business premises, registration numbers or other personal data.

5. SPECIAL CATEGORY DATA AND SENSITIVE INFORMATION

Kayo does not generally seek to collect special category personal data unless it is genuinely necessary for a lawful business purpose.

However, in some situations we may receive or need to process limited sensitive information, for example:

• * health or vulnerability information relevant to safe attendance at a property;
• * accident or injury records;
• * DBS or background information where lawfully required;
• * equality or HR information where relevant to employment; or
• * information disclosed in the course of a complaint, safeguarding issue or legal dispute.

Where we process special category data, we will only do so where we have a valid legal basis and, where required, an additional lawful condition under data protection law.

6. HOW WE COLLECT PERSONAL DATA

We may collect personal data:

• * directly from you when you contact us, book a job, request a quote, create an account, apply to work with us or communicate with us;
• * through our website, app, customer portal, booking systems, CRM or payment pages;
• * from phone calls, WhatsApp, text, email, social media or live chat;
• * from tradespeople, engineers, employees or office staff handling your booking or job;
• * from landlords, tenants, property managers, agents or authorised representatives;
• * from payment providers, finance systems or accounting systems;
• * from recruitment platforms, referees or onboarding processes;
• * from complaint, dispute or insurance processes; and
• * by generating records ourselves during attendance, works, customer service, administration, quality control, compliance and business management.

7. HOW WE USE PERSONAL DATA

We may use personal data for the following purposes.

7.1 To provide our services

Including to:

• * respond to enquiries;
• * prepare and send quotations;
• * arrange bookings and appointments;
• * allocate jobs to tradespeople or staff;
• * attend properties and carry out works;
• * issue invoices, certificates, reports and updates;
• * manage callbacks, snagging, warranty issues and customer support; and
• * operate customer accounts, job history and service records.

7.2 To manage our relationship with customers and contacts

Including to:

• * communicate about bookings, quotations and works;
• * send reminders, updates and appointment information;
• * respond to complaints, disputes or reviews;
• * manage refunds, chargebacks and debt recovery;
• * keep records of communication and decisions; and
• * provide customer service and aftercare.

7.3 To run, improve and protect Kayo’s business

Including to:

• * train staff and tradespeople;
• * monitor service quality and contractor performance;
• * investigate complaints, callback issues and workmanship disputes;
• * prevent fraud, abuse, bypass or misuse of our systems;
• * protect Kayo’s legal rights and customer relationships;
• * analyse demand, performance and business operations; and
• * improve our systems, booking flow, website, app and customer experience.

7.4 To meet legal, regulatory and safety obligations

Including to:

• * comply with tax, accounting and reporting obligations;
• * keep legally required records;
• * support health and safety management;
• * handle insurance claims and legal disputes;
• * cooperate with regulators, law enforcement or courts where required; and
• * maintain compliance records, certifications and audit trails.

7.5 To recruit, manage and pay workers

Including to:

• * review applications and recruit staff or contractors;
• * onboard tradespeople, employees and workers;
• * verify qualifications, insurance and right to work;
• * manage payments, payroll and HR records;
• * manage performance, conduct and complaints; and
• * protect business operations and confidential information.

7.6 To request reviews, send service follow-ups and carry out marketing

Where lawful, we may use personal data to:

• * request feedback and reviews after a job or service;
• * send service follow-up messages by email, WhatsApp, SMS or similar channels;
• * send service updates, offers or promotions;
• * provide information about Kayo services; and
• * measure the effectiveness of marketing campaigns.

Where required by law, we will ask for consent before sending certain electronic marketing communications, and you can opt out at any time.

8. OUR LAWFUL BASES FOR PROCESSING

Under UK data protection law, Kayo must have a lawful basis for processing personal data. Depending on the circumstances, we may rely on one or more of the following:

8.1 Contract

Processing is necessary to take steps before entering into a contract or to perform a contract with you, for example to book and deliver services, manage contractor arrangements or manage employment.

8.2 Legal obligation

Processing is necessary to comply with legal obligations, such as accounting, tax, employment, health and safety, fraud prevention or regulatory obligations.

8.3 Legitimate interests

Processing is necessary for Kayo’s legitimate interests, provided those interests are not overridden by your rights and interests. This may include:

• * running and improving our business;
• * managing bookings, contractors, staff and customer service;
• * preventing fraud, abuse, chargebacks and bypass;
• * protecting legal rights and recovering debts;
• * investigating complaints, workmanship issues and disputes;
• * keeping records of work, communications, safety issues and property history;
• * monitoring service quality and operational performance; and
• * maintaining security of systems and information.

8.4 Consent

In some cases, we may rely on your consent, for example for certain marketing communications or optional cookies. Where we rely on consent, you can withdraw it at any time, although this will not affect the lawfulness of processing carried out before withdrawal.

8.5 Vital interests / legal claims / employment law grounds

Where relevant, we may also process data to protect vital interests, establish or defend legal claims, or meet employment, social security or workplace obligations.

9. WHO WE MAY SHARE PERSONAL DATA WITH

Kayo may share personal data where necessary with the following categories of recipients:

9.1 Tradespeople, contractors and staff

We may share relevant booking, property, contact and job information with Kayo staff, self-employed tradespeople, contractors and subcontractors where needed to provide the service or manage the booking.

Tradespeople and contractors receiving Kayo customer data are authorised to use that data only for Kayo business purposes and in accordance with Kayo’s instructions, contractual obligations and data protection requirements. They must not use customer data for private work, personal marketing, bypass arrangements or unrelated purposes.

9.2 Payment, accounting and finance providers

We may share data with payment processors such as Stripe, accountants, bookkeepers, debt recovery providers, banks, finance systems and fraud prevention providers where necessary.

9.3 IT, software and hosting providers

We may use third-party providers for CRM, booking systems, engineer apps, cloud storage, website hosting, communication tools, email, analytics, invoicing, payroll and related services.

9.4 Professional advisers

We may share data with solicitors, accountants, insurers, brokers, compliance advisers or other professional advisers where reasonably necessary.

9.5 Regulators, law enforcement and authorities

We may disclose personal data where required by law, court order, regulatory obligation or where reasonably necessary to prevent fraud, protect rights, or cooperate with lawful investigations.

9.6 Insurers and dispute handlers

We may share data with insurers, claims handlers, complaint investigators, mediators or courts where necessary to handle incidents, complaints, losses or disputes.

9.7 Other parties connected with your booking

Where appropriate, we may share relevant data with landlords, tenants, managing agents, property managers, authorised representatives or warranty / finance partners involved in the booking or service.

Kayo does not sell personal data to third parties.

10. INTERNATIONAL TRANSFERS

Kayo may use software, storage or service providers who process personal data outside the UK.

Where personal data is transferred outside the UK, Kayo will take steps intended to ensure an appropriate level of protection, which may include:

• * using countries recognised as providing adequate protection;
• * using appropriate contractual safeguards;
• * using reputable service providers with suitable security and compliance measures; or
• * taking other lawful transfer measures required by UK data protection law.

11. DATA SECURITY

Kayo takes reasonable technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

These measures may include:

• * password protection and access controls;
• * secure software platforms, apps and cloud systems;
• * role-based access to records;
• * secure storage of documents and records;
• * staff and contractor confidentiality obligations;
• * audit trails and communication records;
• * backup and recovery processes;
• * security monitoring and internal controls; and
• * policies governing data access, retention and deletion.

No system is completely secure, and we cannot guarantee absolute security, but we take data protection seriously and aim to use proportionate safeguards.

12. HOW LONG WE KEEP PERSONAL DATA

Kayo will keep personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• * provide services;
• * maintain customer, property and job history;
• * support repeat work at the same property or for the same customer;
• * handle complaints, callbacks, disputes and warranties;
• * meet tax, accounting and legal obligations;
• * defend legal claims;
• * manage employment, contractor and compliance records; and
• * protect Kayo’s legitimate business interests.

Because Kayo may carry out repeat works for the same property or customer over a long period, and because historical job records, certificates, photographs, communications and compliance information may be relevant to future work, warranty issues, safety issues, complaints or legal disputes, Kayo may retain customer, property and job-related records for a number of years where reasonably justified.

Retention periods may vary depending on the type of data and purpose. Kayo may keep some information longer where:

• * required by law;
• * a complaint, dispute, callback, warranty issue or claim is ongoing;
• * records may reasonably be needed for future property work or customer support;
• * records are relevant to safety, compliance or historical job context; or
• * retention is reasonably necessary to protect Kayo’s legal position.

Kayo intends to operate a separate Data Retention and Storage Policy setting out more detailed retention periods and storage rules.

13. YOUR DATA PROTECTION RIGHTS

Depending on the circumstances, you may have rights under UK data protection law, including the right to:

• * request access to your personal data;
• * request correction of inaccurate or incomplete personal data;
• * request erasure of personal data in certain circumstances;
• * request restriction of processing in certain circumstances;
• * object to certain processing, particularly where we rely on legitimate interests or direct marketing;
• * request transfer of certain personal data to you or another provider where applicable;
• * withdraw consent where processing is based on consent; and
• * complain to the Information Commissioner’s Office (ICO).

These rights are not absolute and may be subject to legal exemptions or conditions.

If you wish to exercise any of your rights, please contact Kayo using the contact details in this Privacy Policy.

14. MARKETING, FOLLOW-UPS AND REVIEW REQUESTS

Kayo may contact customers and prospective customers by email, phone, WhatsApp, SMS or similar channels for service-related communications and, where lawful, for marketing, follow-ups, reminders and review requests.

This may include:

• * requesting a review after a completed job;
• * checking whether further work is required;
• * sending reminders or updates about bookings;
• * informing you about relevant Kayo services; and
• * sending promotions or offers where lawful.

You can opt out of marketing communications at any time by:

• * using the unsubscribe option where available;
• * replying to tell us you no longer wish to receive marketing;
• * contacting Kayo directly; or
• * updating your preferences where that option is available.

Even if you opt out of marketing, Kayo may still contact you about service-related matters, bookings, invoices, complaints, legal notices or other non-marketing operational communications.

15. COOKIES AND SIMILAR TECHNOLOGIES

Kayo’s website and app may use cookies, analytics tools and similar technologies to support website functionality, remember preferences, understand usage and improve our services.

Some cookies may be essential for website operation, while others may be optional, such as analytics or marketing cookies.

More detailed information about cookies and similar technologies will be provided in Kayo’s Cookie Policy and, where appropriate, through cookie notices or consent tools on our website.

16. CALL RECORDINGS, WHATSAPP, APP RECORDS AND BUSINESS COMMUNICATIONS

Kayo may keep records of calls, WhatsApp messages, emails, SMS messages, booking notes, CRM records, app uploads, complaint communications, uploaded files, photographs, videos and other business records for purposes including:

• * customer service;
• * booking management;
• * quality control;
• * evidence of works;
• * contractor and employee management;
• * complaint handling;
• * debt recovery;
• * fraud prevention;
• * legal claims and dispute resolution; and
• * regulatory or compliance purposes.

Where phone call recording is used, Kayo will seek to do so lawfully and transparently.

Where tradespeople or staff use a Kayo app, CRM or other business system to upload notes, photographs, job updates, certificates or other records, those records may be stored and used by Kayo for operational, legal, customer service, compliance and quality control purposes.

17. THIRD-PARTY LINKS AND SERVICES

Kayo’s website, app or communications may contain links to third-party websites, platforms or services. Kayo is not responsible for the privacy practices of those third parties. If you use third-party services, you should review their own privacy policies.

18. CHILDREN’S DATA

Kayo’s services are generally aimed at adults, property owners, tenants, landlords, businesses and responsible representatives rather than children.

We do not knowingly seek to collect children’s personal data unless it is incidental, necessary for a booking or otherwise lawfully provided by a responsible adult. If you believe Kayo has received children’s personal data inappropriately, please contact us.

19. CHANGES TO THIS PRIVACY POLICY

Kayo may update this Privacy Policy from time to time to reflect changes in law, business operations, systems or data practices.

The latest version will be made available through our website, app or other appropriate channels and will take effect from the stated “last updated” date unless otherwise indicated.

20. HOW TO CONTACT US

If you have questions about this Privacy Policy, wish to exercise your rights, or want to raise a data protection concern, please contact:

Streamline Power Solutions Ltd trading as Kayo

• Email: [Insert Privacy / Contact Email]
• Phone: [Insert Phone Number]
• Address: [Insert Registered / Trading Address]

21. COMPLAINTS TO THE ICO

If you are unhappy with how Kayo handles your personal data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator.

You can find details at the ICO website.

Kayo would appreciate the chance to deal with your concerns first, so please contact us before escalating a complaint where possible.