Privacy Policy

Last updated: May 6, 2023

This Privacy Statement describes the types of information that Kudo Research, LLC. (“Kudo” or “we”) collects, uses and shares when you interact with our website, provide rewards, incentives and other products through our platform, receive a communication from us, or redeem rewards, incentive or other products that you received from one of our Clients (our “Services”). This Privacy Statement sets forth our policy with respect to the collection, use and disclosure of information that is collected on our Site. By using the Site, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement.

By accessing or using our Site, you acknowledge that you have read, understood, and agree to be bound to the terms of this Privacy Statement and our terms of use.

Kudo provides various reward, incentive and other services to corporate clients (our “Clients”) and is generally a processor, and not a controller, of personal information. Our Clients provide rewards, incentives and other products offered through Kudo to individuals for redemption (each a “Recipient”). To the extent one of our Clients discloses Personal Information of California consumers or households to us, we may be considered a “service provider” under California law. If you are located in the European Economic Area or the United Kingdom, we are a data processor of your personal data and our Client is the data controller of such data under the EU General Data Protection Regulation and the UK General Protection Regulation.

We will only process and use your data in accordance with the documented instructions of our Client, and strictly on their behalf, subject to our agreement and data processing addendum entered into with our Client. Our Client will be solely responsible for meeting any legal requirements applicable to data controllers or “covered businesses” (such as establishing a legal basis for processing and responding to data subject rights requests concerning the data our Client controls).

Kudo works with financial institutions, and may share certain information with them, in order to facilitate the redemption of some awards, incentives and other products. Due to the requirements of such financial rules and regulations, including anti-money laundering laws, Kudo may not be able to delete your information, even upon your request.

If you are visiting this Site on behalf of one of our Clients, please see the “Authorized Users” section below.
Information You Provide to Us
Kudo collects data from and about both its Clients and their Recipients

The information we collect may include your name, address, email address, telephone number, mobile telephone number or geolocation information or any other information you provide while you use our Services such as login or password. If you are a Client, when you create a corporate account with Kudo, we ask for certain information about the Client's business. If you use the Services to purchase a reward, incentive or other product, you may provide certain payment information, such as payment card, PayPal or other financial account information, and billing address. A third-party payment processor collects and processes that information on our behalf; we do not collect or retain your payment information.

When a Client chooses to provide a reward, incentive or other product, Clients may provide certain information to Kudo about a Recipient, such as name, email address or phone number.

If you are a Recipient, we also collect and store any information that you enter on our website in order to redeem your reward through an issuing bank. This may include name, mailing address, ZIP code, phone number, date of birth, or email address. If you use the Services to redeem a reward, incentive or other product, you may provide certain financial account information and billing address. We retain this information to facilitate additional reward, incentive or other product redemptions.
Information Collected From Other Sources
If you are a Recipient, we may obtain information about you from our Client so we can notify you of the reward and customize its presentation. This information may include your name, email address or phone number.
Information Obtained from Third Parties
If a Client provides us with personal information about others, such as Recipients, or if others give us your information, we will only use that information for the specific reason for which it was provided to us, for example, if you have agreed to share information with our Client, we may add this information to the information we already hold about you when you redeemed a prior reward.
Information Use
We may use the information we collect from and about you to:
Send you requested product or service information, including rewards and incentives;
Facilitate the redemption of a reward, incentive or other product;
Respond to Client service requests;
Respond to your questions and concerns;
Improve the content and functionality of our Website and marketing efforts;
Conduct research and analysis;
Display content based upon your interests;
Comply with applicable laws, including to respond to requests from public and government authorities
Enforce this Privacy Statement;
Protect our rights, privacy, safety or property, and/or that of you or others.
Develop new programs, products or services
Protect the security or integrity of the Services and our business;
In accordance with the instructions of our Clients; and
As described to you at the point of data collection.
Information Sharing
We may share the information we collect from and about you:
with financial institutions that issue your rewards, incentives or other products, including your name and email address;
with our Clients, including to facilitate and track the redemption of rewards, incentives or other products;
to our Service Providers, if the disclosure will enable them to perform a business, professional or technical support function for us;
Respond to your questions and concerns;
as necessary if we believe that there has been a violation of this Privacy Statement, our Terms of Use, of our rights or the rights of any third party;
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
Display content based upon your interests;
to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law; and
as described to you at the point of collection.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
We do not sell your personal information to third parties.
We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.

If you do not want us to share your personal information as set forth in this Privacy Statement, contact us at help@kudoresearch.com.
Information We Collect Automatically and Cookie Policy:
As is true of most Web sites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system.

When anyone interacts with our website, certain information about your use of our Services is automatically collected. This information includes computer and connection information, such as statistics on your page views, traffic to and from our Services, referral URL, ad data, your IP address, and device identifiers. This information also may include how you search for our Services, the websites you click on from our Services or emails, whether and when you open our emails, and your browsing activities across other websites.

We may use cookies, web beacons, pixel tags, log files or other technologies to automatically collect certain information when you use our Services or interact with our emails. For example, we may automatically collect certain non-personal information from you such as your mobile device identifier or MAC address, browser type, operating system, device model software version, Internet Protocol (“IP”) address, mobile or ISP carrier information, and the domain name from which you accessed the Services. We also may collect information about your use of the Services including the date and time you access the Services, the areas or pages of the Services that you visit, the amount of time you spend using the Services, the number of times you return, whether you open forward or click-through emails and ads, and other usage data.

Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. To learn more about the use of cookies or other technologies to deliver more relevant advertising and your choices about not having this information used by certain Service Providers (defined below), please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers. For more information on our use of cookies, click here.

We may also allow third parties such as Google and Facebook to use tracking technologies to collect or receive information from the Kudo website and elsewhere on the internet and use that information to provide measurement services and targeted ads.
Combination of Information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site, as well as information collected offline or from third party sources, including Clients, to help us tailor our communications to you and to improve our Services.

We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Statement.

If you do not want us to share your personal information as set forth in this Privacy Statement, contact us at help@kudoresearch.com.
Third Parties
We may contract with third parties to perform functions related to the Site and to help us with the services we provide to our Clients. These third parties will have access to your personal information as needed to perform their business functions, but may not use or share that personal information for other purposes. These companies are authorized to use your personal information only as necessary to provide these services to us and/or to support the services we provide to our Clients.
Your California Privacy Rights
California Civil Code Section §1798.83 permits users of our site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to help@kudoresearch.com or write us at 228 Park Ave S, #62949, New York NY 10003.
Visitors from the EEA or the UK
If you are a resident of the EEA or the UK, our legal basis for collecting and using your personal data or information is to do so with your consent, as provided to us by our Client; in performance of a contract with our Client or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. You may contact our Client at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights to:
Access your personal data or information;
Delete, or request deletion of, your personal data or information;
Object to or restrict processing of your personal information;
Request portability of your personal information;
Complain to your local data protection authority at any time;
Object to automated decision making; and
Update your personal data or information.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are visiting our site to redeem an award, one of our Clients has shared your information with us. Before using our Site, please read and familiarize yourself with our Client's privacy and other policies and procedures. If you have questions about the collection and use of information on this Site, please contact our Client, who provided you with a reward, incentive or other product.
Legal Requirements
We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Children
Protecting children's privacy is important to us. We do not direct the Services to, nor do we knowingly collect any personal information from, children under the age of thirteen.
Links to Other Web Sites
This Privacy Statement applies only to the Services. It does not apply to non-Kudo websites and mobile applications, including those of our Clients, that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices. The Services may contain links to third-party sites or applications, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites or applications. The links to third-party sites from the Services do not imply that we endorse or have reviewed the third-party sites.
Data Security
The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about You. While we make every effort to help ensure the integrity and security of our network and systems, the transmission of information via the internet is not completely secure. E-mail sent to or from the Services may not be secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
Data Storage and Retention
Your personal information is stored on our Service Providers' servers in the United States. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement even if you are from an area outside the United States. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Services, or to fulfill any legal or contractual obligations we may have.
Access to Your Personal Information
You may also send us an email at help@kudoresearch.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if we believe doing so would violate any law or legal or audit requirement or cause the information to be incorrect.
Authorized User Notice
If you access the Site on behalf of one of our Clients, you are considered an Authorized User under the Client's contract with us. The Client decides how the information you provide is collected and used, including what is shared with us for our use. Your use of the Site is subject to our privacy policy and terms of use, as well as the contract with our Client. If you have questions about the collection and use of your information on our Site as part of services we provide to a Client, please contact the Client, who may be your employer.

This Site is not intended to collect personal health information or other sensitive information about you as a Client representative. Any such information should remain with the Client and should be shared and used only in accordance with our contracts with our Clients and the Client's privacy and other policies and procedures.

The information we collect from Authorized Users may include your name, address, email address, telephone number, mobile telephone number or geolocation information or any other information you provide while you use our Services on behalf of our Client, such as login or password. We may only be able to change how we share personal information of Authorized Users in accordance with our agreement with our Clients or our Client's instructions.

If you provide us with the name of your company, we may use the name of your company (but not other personal information) on a list of current or former Clients for promotional purposes.
Changes to Our Privacy Statement
We reserve the right to revise this Privacy Statement at any time. When we do, we will post the changes on the Site. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. Your continued use of the Services after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

Please also feel free to contact us at help@kudoresearch.com if you have any questions about our Privacy Statement or the information practices of the Services.