Kupiku Privacy Policy

Version 2.0, updated May 22nd, 2018

In this Privacy Policy, we describe the type of data, including personal data (collectively, "data"), that we and our associated companies collect from you when you use the Kupiku.com website and certain Kupiku services as described in this Privacy Policy (collectively, our "services"), how we and our associated companies use and disclose that data, and your options to access or update your data.

This Privacy Policy may be amended from time to time. The respective latest version of the Privacy Policy at the point of time of the purchase of a product via Kupiku.com or registration to the Kupiku.com website (whichever occurs later) shall apply. The data controllers are Kupiku B.V, Overwegwachter 4, Rotterdam, 3034 KG, Netherlands, and the associated entities engaged by Kupiku B.V., for the purpose of carrying out the services outlined in our Terms Of Use.

Kupiku and associated entities act as joint data controllers, who are jointly responsible for compliance with data protection legislation. Kupiku B.V. is primarily responsible for exercising of rights of data subjects and providing information about data processing.


The following definitions are used throughout this Privacy Policy:

Kupiku Website. Any website that is the property of Kupiku B.V., including but not limited to everything hosted under the top-level domain kupiku.com.

Kupiku Account. An account you create and which Kupiku may use in communicating with you or providing Kupiku services to you, which contains your first name, last name, email, address(es), and username. It is accessed via a username and password and can be used to manage your Personal Data.

Kupiku Terms of Use means Kupiku Subscription Agreement, Kupiku Terms of Use for a service, or other agreement you have in place with Kupiku covering Kupiku services.

Kupiku Orders, Kupiku Auctions, Kupiku Gift Certificates, Kupiku Snipe It, Kupiku Wish List, and Kupiku Blog, may be collectively referred to as "Kupiku Services".

Personal Data means any data relating to an identified or identifiable natural person.

Why We Collect Data and What We Collect

We collect data for various reasons, such as:

a) To provide you with our services, or information. We may collect data which are required to provide you with support, and services, including the proper processing of your orders, provision of support, reporting of issues and bugs, and other processing connected with use of Kupiku website, services, or information. You explicitly fill in the data required for you to receive orders you place, support, or services, whether you use Kupiku Services, use our support feature, sign up for a Kupiku Account, participate in a survey, and/or subscribe to receive marketing and/or technical information and content, or these data are collected in the course of use of Kupiku Services. We may use third-party service providers, acting as data processors, to assist us in provisioning Kupiku Services to you or in our operations. For example, we may use third-party service providers to provide data storage and backup services. With your consent, your Personal data may also be transferred to third-party service providers, acting as separate data controllers, who provide products and services complementary to Kupiku Services (further data processing performed by these service providers is governed by their privacy policies). The legal basis for this data processing is performance of contract between you and us.

b) To protect us from fraud and unlawful use of our software or services. We may collect data which are required to protect us from any fraudulent, unlawful, or unauthorized use of our services, or which are necessary to ensure security of our services, including both data provided by you (see above) and data collected in the course of use of Kupiku Services. The legal basis for this data processing is Kupiku's legitimate interest in protection from fraud and unlawful use of Kupiku services.

c) To improve our offerings based on usage. We may collect data based on your use of Kupiku Services, and we do not associate these data with your name. We use these data to better understand usage patterns of our services and behavior of our collective audience. At times we may share this information in aggregated anonymous form with third parties. Collection of data based on your use of Kupiku Services is done only if you permit it. The legal basis for this data processing is our legitimate interest in improving the services we offer you.

d) For internal evidence of Kupiku and to protect the rights and interests of Kupiku and other users. We may collect data which are required to keep evidence of provision of services to you, of any communication between you and us, of your contact details, of your use of our services, of any payments, refunds, and of any issues or disputes between you and us. We may use and disclose these data where we believe, in our sole judgment, that it is legitimate and appropriate to do so to protect our rights and interests and the rights and interests of other users of Kupiku Services, or where we believe there has been a violation of this Privacy Policy that could affect the interests of Kupiku or its customers. The legal basis for this data processing is our legitimate interest in keeping internal evidence and protecting the rights and interests of us and other users.

e) To promote and market our services. We may use feedback that you provide voluntarily on our services. As permitted by applicable law, we may use this in the form of quotes or in other ways in accordance with the Kupiku Terms of Use. We also may use data that we collect and aggregate to assist us in determining appropriate marketing and advertising for our services. In doing so, we may share anonymous aggregated data with third parties to assist us with these efforts. With your consent or if permitted by applicable law, we may also use your contact details to send you commercial communications about our services. We also may use third-party service providers to assist us with our email marketing; in that case, the third-party service provider will have access to your email address, your name, and other information necessary to engage in the marketing. Such third-party service provider will act as a data processor and will not use your data for any other purpose. The legal basis for this data processing is our legitimate interest in promoting and marketing our services.

f) To fulfil legal duties stipulated by accounting, taxation and other laws. We may use and disclose your personal data where required by law, such as in keeping and disclosing our accounts, in keeping and disclosing our tax records, and in response to a court order, valid subpoena, or other legal process. The legal basis for this data processing is our compliance with our legal obligations.

You may object to the processing of your personal data for the purposes b) to e) at any time.

Categories of data involved in data processing include:

  • names,
  • email address,
  • phone number,
  • username,
  • password,
  • cookies,
  • IP address,
  • SSH public key,
  • physical address,
  • order history
  • information about subscription and payments

Where appropriate, we will prompt you to give us your consent to the collection and processing of your data as described above. This may happen within Kupiku Services, or in another environment set up by Kupiku, always in a clear and conspicuous manner. You can manage your data and opt-outs as described in the Transparency section below.


Our services are not designed for and are not offered to children under the age of 13. If we discover that a person under the age of 13 has submitted information directly to us, we will endeavor to delete the information from our systems.


To respect your privacy, before usage of your personal data, we will inform you about the categories of data we collect and the purposes we use it for. We will also inform you about the data management options that you may have. For this purpose, we use agreements, terms of use, and consent notices embedded in the Kupiku.com website. Should you wish to access and manage your data, you can do so here, you can update and manage your data and also provide us with an opt-out of certain personal data collection.


Collected personal data are shared based on Subscription Agreement, Terms of Use of a service in use, and this Privacy Policy. Additionally, we share collected personal data within the group of companies described above, which act as joint data controllers and process personal data for the purposes described above.

According to Kupiku Terms of Use covering a particular service, as part of the service functionality, collected personal data may be shared with other representatives of your company.

We may share your data with certain third parties which help us provide you with Kupiku Services, or to run our business, for example to providers of data storage and backup services. We may also share your data with individual representatives of your company.

Your personal data may also be shared with other organizations or individuals if we have obtained your consent to do so.

We may also share your data with certain third parties if we are obliged to do so under applicable legislation (especially with tax authorities or with other government bodies exercising their statutory powers) or if such sharing is necessary to achieve the purposes defined above (especially with government bodies or with parties harmed by your illegal acts, if applicable).


To secure your personal data, our services are designed with security and privacy in mind.

We encrypt your data in transfer and at rest where it is technically feasible. External web resources are protected by encryption.

We review the processes of personal data usage before implementing them. This is done to minimize data usage and to make sure that you as the data owner is informed about the processing. When the reason for data storage expires, we remove your personal data from our servers or anonymize it for further usage. By the nature of the activity within which your data is collected, it may appear in datasets used for research. Before using the datasets for research or other purposes you are not informed of, we remove or anonymize your personal data in the datasets.

We use partners to host our services and websites and to process your data in accordance with this Privacy Policy. While choosing the partners, we ascertain their compliance with legal regulations and security standards to make sure your data are stored in a secure location with appropriate security measures in place.

Location of Your Information

Any servers or services that contain personal data are located within the E.U. At times, Kupiku may process or transfer some of your personal data (such as name and email) to our affiliate companies outside of the EU. Any such transfer will be made in accordance with the applicable laws on data protection and this Privacy Policy and will be based on relevant adequacy decision of the European Commission, especially on standard data protection clauses or Privacy Shield decision.

Data retention, withdrawal of approval, access to data and your rights

If at any time you choose to cease using Kupiku Services, you may ask for your data to be removed from our servers by sending a request to [email protected] or via your Kupiku Account . After the data removal, we may keep pseudonyms of your personal data solely for a record about the data removal. Generally, we retain your data as long as we need to in order to achieve the purpose for which it was collected. We may retain your information if it is required to comply with legal obligations and/or defense in case of violation of Kupiku Terms of Use and/or Privacy Policies. We may also have copies of your information in application logs, weblogs, and/or backups made for security and support purposes if this is mentioned in a Kupiku Terms of Use or consent text accepted before the personal data collection. These backups will not be accessible as separately delineated information. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our services, we will not be responsible for retention of any of your data.

You may manage your Personal Data in your Kupiku Account, including providing us with an opt-out for certain kinds of data collection. You are responsible for the correctness of the Personal Data you provide to us. We expect you to check the Personal Data you provide to us and if any inconsistency takes place, update your Personal Data or report the inconsistency to Kupiku.

As permitted by applicable law, E.U. residents may request a copy of the information that we hold about them. To do so, please go to your Kupiku Account and ask for a copy through the means available there, or contact [email protected]. We may charge a reasonable fee in accordance with applicable law for this service.

Moreover, as set out in locally applicable personal data protection law, you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request a restriction on the processing of your personal data; (v) request personal data portability; or (vi) object to the processing of your personal data.

  • Right of access. You may have the right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to request access to your personal data. The information about personal data processing includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom your personal data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your personal data undergoing processing. For additional copies requested, we may charge a reasonable fee based on administrative costs.
  • Right to rectification. You may have the right to obtain from us the rectification of inaccurate personal data. Depending on the purposes of the processing, you may have the right to have incomplete personal data made complete, in particular by providing a supplementary statement.
  • Right to erasure (right to be forgotten). Under certain circumstances, you may have the right to require us to delete your personal data.
  • Right to a restriction on processing. Under certain circumstances, you may have the right to require us to restrict the processing of your personal data. In this case, the respective personal data will be marked and may only be processed by us for certain purposes.
  • Right to personal data portability. Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit these personal data to another entity.
  • Right to object. Under certain circumstances, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

These rights can be exercised via the email address [email protected].

You may also contact Kupiku to get up-to-date information about your personal data processing and any personal data recipients.

You may lodge a complaint related to the processing of your personal data with the competent data protection supervisory authority.

Changes to this Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on Kupiku Website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with an advance notice of such change by highlighting the change on Kupiku Website.


If you have any questions or concerns, or wish to submit any feedback to us regarding our Privacy Policy, please contact us at [email protected].