Privacy Policy

Effective Date: May  2025

1. Introduction

We at Kletta Limited (“Kletta”, “we”, “our” or “us”) respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you.

We process Personal Data in accordance with:

• the United Kingdom General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom, as applicable; and
• the European Union General Data Protection Regulation ((EU) 2016/679) (“EU GDPR”);

as well as with the Information Commissioner’s Office (ICO) guidance or best practice, and in accordance with the requirements of our contracts agreed with our customers (brokers, insurers, MGAs or other insurance intermediaries).

UK GDPR and EU GDPR are collectively referred to in this policy as “GDPR”. All terms used within our privacy policy have the meaning(s) given to them under the GDPR.

This privacy policy explains how we collect, use, and share information about you when you access or use Kletta’s websites, the Kletta Portal, or our services (collectively, “Services”) or otherwise interact with us, for example, when you attend a Kletta event or interact with us on any of our social media platforms.

The individuals from whom we may gather and use data include:

• customers;
• platform users;
• vendors;
• parties to business contacts; and
• any other people that the user has a relationship with or may need to contact.

1.1. Data Controller

Kletta Limited is your Data Controller and is responsible for your Personal Data.

1.2. What Is Personal Data?

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

All Personal Data we collect is reasonable and necessary to enable us to perform our Services. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together and listed below. Not all of the types of data listed may necessarily be collected from you, but this is the full scope of data that we may collect:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth, profession.
• Contact Data: This is data relating to your phone number, addresses, email addresses and includes professional information such as work email addresses.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Marketing and Communications Data: This is your preference in receiving marketing information and other information from us.
• Customer Support Data: This includes feedback, chat messages, emails, bug reports and survey responses.
• Usage Data: information about how you use our Services.

1.3. Special Categories of Data

We may in limited scenarios also process what is known under the GDPR as special categories of Personal Data. In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. All special categories data collected is listed in the Privacy Table below.

2. What Personal Data Do We Collect?

2.1. Personal Data You Provide to Us Directly

Kletta collects Personal Data that you provide to us directly, for example, when you make use of our Services, book a demo or request customer support. The types of data we collect are set out in the Privacy Table below.

2.2. Personal Data We Receive Automatically

2.2.1. Use of Kletta Services

Kletta collects Personal Data when you visit, use, or interact with our Services. The types of data we collect are set out in the Privacy Table below.

2.2.2. Open Banking Transactional Data

If you choose to link your bank accounts as part of Kletta’s Open Banking Services, we use an open banking account information service, provided by Plaid Financial Ltd. Please note:

Kletta is an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Reference Number: 804718). Plaid provides you with regulated account information services through Kletta as its agent.

Regulated account information services include balance, transaction and merchant data for bank accounts that you give express permission to link to our service, for the purposes of reconciliation services. You can view Plaid’s privacy policy at https://plaid.com/legal/#consumers

2.2.3. Cookies

We may collect Personal Data from website users through cookies. Further details can be found in our Cookie Policy.

2.3. Personal Data Collected from Other Sources

We may collect Personal Data about you from other third-party sources. This could include:

• Other business partners or other people within your organisation that have an existing relationship with you.
• If you are an employee of a customer of ours, and your employer provides us with your contact details or other Personal Data in connection with your use of our Services.
• Personal Data provided to us by government agencies.

3. How Do We Use Personal Data?

3.1. Legal Bases for Processing

Kletta only processes your Personal Data when we have a valid legal basis to do so. This will depend on what information we collected and the context for processing it. Generally, we only collect and process Personal Data on the following bases:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information in order to fulfil our contractual obligations and provide the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests. This covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3.2. Privacy Table

We have set out below, in table format, a description of all the ways we plan to use the various categories of your Personal Data, and which of the legal bases we rely on to do so.

3.3. Kletta as Data Controller

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, where this is required or permitted by law.

3.4. Kletta as Data Processor

In our capacity as Data Processor, we process data on behalf of our customers, who are the Data Controllers, and with whom we have a contractual agreement that dictates how we may process this data.

As Data Processor, Kletta has the following responsibilities:

• To ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR.
• To commit ourselves to confidentiality.
• To implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data.
• To obtain the prior specific or general authorization of the Controller before engaging another Processor.
• To assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights.
• To make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller.
• To maintain a record of all categories of processing activities carried out on behalf of a Controller.
• To co-operate, on request, with the supervisory authority in the performance of its tasks.
• To designate a Data Protection Officer (DPO) where required by the GDPR, publish their details and communicate them to the supervisory authority.
• To support the DPO in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations and to maintain their expert knowledge.
• To ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller.
• To notify the Controller without undue delay after becoming aware of a Personal Data Breach.

3.5. How We Protect Personal Data

We are strongly committed to keeping your Personal Data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure this, including:

• encrypting our databases;
• restricting physical and logical access;
• enforcing user authentication and password protection; and
• adhering to security-by-design development practices; 

Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality.

If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.

However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Kletta to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4. Who Do We Share Personal Data With?

Sometimes we may need to share your Personal Data with third parties. This will usually be because you have asked us to, or:

• if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation;
• to protect the safety, security, and integrity of our products, employees, or users, or the public; or
• if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law.

We may also share Personal Data with interested parties in the event that:

• Kletta anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology; or
• if Kletta is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of, or in connection with, that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

When we share Personal Data with third parties which are providing us with services, or providing services to you on our behalf, we always have an agreement in place to ensure protection of your Personal Data i.e. that it is only used for agreed purposes and in accordance with applicable laws such as the GDPR.

We may also collect, use, and share information that is non-Personal or has been aggregated and de-identified in a way that cannot be used to identify you, for any purpose permitted under applicable law.

5. How Long Do We Retain Personal Data?

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Any specific retention periods we have established for specific processing activities will be set out in the Privacy Table above. The following retention criteria are applied:

• Legal Requirements: Compliance with legal obligations and regulatory requirements.
• Contractual Obligations: Duration of the contract and any post-contractual obligations.
• Business Needs: Operational needs for maintaining records and managing business relationships.
• Customer Requests: Honoring requests for data deletion or retention preferences.
• Risk Management: Assessing the risks associated with retaining or deleting data.

If a specific retention period cannot be determined, data will be reviewed periodically to ensure it is still necessary for the purposes outlined above.

6. What Are Your Data Protection Rights?

6.1. Your Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:

• Right To Be Informed: You have a right to be informed about our purposes for processing your Personal Data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
• Right Of Access: This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it (also known as a "Data Subject Access Request").
• Right To Rectification: You have a right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right To Erasure: You have the right to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it; where you have successfully exercised your right to object to processing; where we may have processed your information unlawfully; or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with requests of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right To Object: You can object to the processing of Personal Data we hold about you. This effectively allows you to stop or prevent us from processing your Personal Data. Note, however, that this is not an absolute right and it only applies in certain circumstances, for example:
  • Where we are processing your Personal Data for direct marketing purposes.
  • Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  • In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Right To Restrict Processing: You have the right to request the restriction or suppression of personal data. Note, however, that this is not an absolute right and it only applies in certain circumstances, for example:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right To Data Portability: You have the right to request the transfer of your Personal Data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
• Withdraw Consent: You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

6.2. Exercising Your Rights

If you think we hold any Personal Data about you which is incorrect or if there are any changes to your Personal Data, please let us know so that we can keep our records accurate and up to date.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

Please note that where Data Subjects exercise their rights in respect of the data held by our customers (Data Controllers), we will make every effort to support them in fulfilling their obligations. Any support we do provide is as agreed with our customers in our customer agreements or other relevant contracts.

To request access to the personal data we hold about you, or to amend, update, or correct your information, please email support@kletta.com. We will provide you with the relevant application form to complete and return. Please note that we can only begin processing your request once the form has been fully completed and submitted to us.

6.3. Your Control Over Kletta’s Use of Your Personal Data

If you do not want us to use your Personal Data for purposes set out in our privacy notice, we may not be able to provide you with access to all or parts of our Services. However, you may delete your account or user profile with us at any time. This will remove your account page from our systems and our related software.

We do not guarantee the ability to delete all stored data. If you would like us to delete personally identifiable data, let us know and we will take action on your request as soon as practicable.

Your account information is protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal data by selecting and protecting your password appropriately; limiting access to your computer or device; and by signing off after you have finished accessing your account.

7. What Else Should You Know?

7.3. Third-Party Links

Our website or other social media platforms may include links to third-party websites, plug- ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit.

7.4. Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate.

Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

7.5. About this Privacy Policy

This policy is not intended to be a contractual document unless expressly stated in any relevant contract we enter.

We keep our Privacy Policy under review and will place any updates here.

By using Kletta’s Services, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Kletta’s Services will constitute your express acceptance of any modifications to this Privacy Policy.

8. Complaints

You have the right to lodge a complaint with the data protection supervisory authority responsible for data protection matters in your location. For the UK, this is the Information Commissioner’s Office (ICO).

9. Changes

This policy may change from time to time and is effective from date of posting to our website and Kletta Platform. For significant changes we will also let you know by email or through the Kletta Platform and Kletta App.