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Kunpro Ltd trading as Nestflo
Privacy Policy
Sep 2024
1. Who we are
1.1. We are Kunpro Ltd, trading as Nestflo is a limited company registered in England and Wales,
company number 13908049 and registered address at Unit 111, Filwood Green Business Park, 1
Filwood Park Ln, Bristol, England, BS4 1ET.
1.2. We provide pre-viewing management services to letting agencies.
1.3. You can contact us at hello@nestflo.com.
2. Scope of this policy
2.1. We respect your privacy and we are committed to protecting your personal data. This privacy
policy will inform you as to how we look after your personal data when you visit https://nestflo.ai
(“Website”), (regardless of where you visit it from) use our messaging and audio chatbots
(Chatbots) and when you purchase our products and services. This privacy policy will also tell
you about your privacy rights and how the law protects you.
2.2. It is important that you read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This
privacy policy supplements other notices and privacy policies and is not intended to override
them.
3. Controller
3.1. We are the controller and responsible for your personal data.
3.2. We have appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy policy. If you have any questions about this privacy policy, including any
requests to exercise your legal rights, please contact the data privacy manager using the contact
details set out above.
4. Contacting the Information Commissioner’s Office
4.1. You have the right to make a complaint at any time to the Information Commissioner's Office
(ICO), the UK regulator for data protection issues (www.ico.org.uk).
4.2. We would, however, appreciate the chance to deal with your concerns before you approach the
ICO so please contact us in the first instance.
5. Changes to the privacy policy and your duty to inform us of changes
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5.1. We keep our privacy policy under regular review. This version was last updated on 12 September
2023.
5.2. It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
6. Third-party links
6.1. The Website and our Chatbots 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.
6.2. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our Website, we encourage you to read the privacy policy of every website you
visit.
7. The data we collect about you
7.1. Personal data, or personal information, 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).
7.2. We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together as follows:
• Identity Data: includes first name, maiden name, last name, username or similar identifier,
marital status, date of birth and gender.
• Contact Data: includes billing address, delivery address, email address and telephone numbers.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in types and versions, operating system and
platform, and other technology on the devices you use to access the Website, our Chatbots and our
other products and services.
• Profile Data: includes your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
• Usage Data: includes information about how you use the Website, our Chatbots and our other
products and services.
• Marketing and Communications Data: includes your preferences in receiving marketing from
us and our third parties and your communication preferences.
7.3. We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data could be derived from your personal data but is not considered
personal data in law as this data will not directly or indirectly reveal your identity. However, if
we combine or connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal data which will be used in
accordance with this privacy policy.
7.4. Except under clause 7.4 above, we do NOT collect any Special Categories of Personal Data
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about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership, genetic and biometric data).
8. If you fail to provide personal data
8.1. Where we need to collect personal data by law, or under the terms of a contract we have with you
(for example, a contract to provide you our Chatbots and our other products and services), and
you fail to provide that data when requested, we may not be able to perform the contract we have
or are trying to enter into with you. In this case, we may have to cancel a product or service you
have with us, but we will notify you if this is the case at the time.
9. How is your personal data collected?
9.1. We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your personal data by filling in forms, using our Chatbots
or by corresponding with us by phone, email or otherwise. This includes personal data you provide
when you:
o apply for our products or services;
o use our Chatbots;
o create an account on the Website;
o authorise marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Website and our chatbot, we
will automatically collect Technical Data about your equipment, browsing actions and patterns. We
collect this personal data by using cookies, server logs and other similar technologies. We may also
receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We will receive personal data about you from
various third parties and public sources (sometimes based outside the UK), like:
o analytics providers such as Google;
o advertising networks;
o search information providers;
o providers of technical, payment and delivery services;
o data brokers or aggregators; and
o publicly available sources.
10. How we use your personal data
10.1. We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:
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• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
10.2. Generally, we do not rely on consent as a legal basis for processing your personal data although
we will get your consent before sending third party direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at any time by
contacting us.
11. Purposes for which we will use your personal data
11.1. We have set out below, a description of the ways we plan to use your personal data, and which of
the legal bases we rely on to do so. We have also identified what our legitimate interests are where
appropriate.
11.2. Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data.
11.3. Please contact us if you need details about the specific legal ground we are relying on to process
your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing
(including basis of legitimate
interest)
To register you as a new
customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your
order including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(e) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate
interests (to recover debts due to us)
To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Asking you to leave a review
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate
interests (to keep our records updated
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or take a survey
and to study how customers use our
products/services)
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate
interests (to study how customers use
our products/services, to develop them
and grow our business)
To administer and protect our
business and this website
(including troubleshooting, data
analysis, testing, system
maintenance, support, reporting
and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests (for running our business,
provision of administration and IT
services, network security, to prevent
fraud and in the context of a business
reorganisation or group restructuring
exercise)
(b) Necessary to comply with a legal
obligation
To deliver relevant website
content and advertisements to
you and measure or understand
the effectiveness of the
advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate interests
(to study how customers use our
products/services, to develop them, to
grow our business and to inform our
marketing strategy)
To use data analytics to improve
our website, products/services,
marketing, customer
relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests
(to define types of customers for our
products and services, to keep our
website updated and relevant, to
develop our business and to inform our
marketing strategy)
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To make suggestions and
recommendations to you about
goods or services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Necessary for our legitimate interests
(to develop our products/services and
grow our business)
12. Marketing
12.1. We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.
12.2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this marketing).
12.3. You will receive marketing communications from us if you have requested information from us
or agreed to receive such marketing communications.
12.4. We will get your express opt-in consent before we share your personal data with any third party
for marketing purposes.
12.5. You can ask us or third parties to stop sending you marketing messages at any time by following
the opt-out links on any marketing message sent to you or by contacting us at any time.
12.6. Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, warranty registration, product/service
experience or other transactions.
13. Cookies
13.1. You can set your browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some parts of the Website
or our Chatbots may become inaccessible or not function properly.
13.2. For more information about the cookies we use, please see
[https://nestflo.ai/assets/documents/cookie-policy.pdf].
14. Change of purpose
14.1. 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
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purpose is compatible with the original purpose, please contact us.
14.2. 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.
14.3. Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
15. Disclosures of your personal data
15.1. We may share your personal data with the following third parties for the purposes set out in this
privacy policy.
• Service providers who provide IT and system administration services, OpenAI,
https://openai.com/.
• We share anonymous data with OpenAI, such as conversation details (excluding usernames,
contact details, etc.) between users and the Nestflo automated chatbot.
• HM Revenue & Customs, regulators and other authorities.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as set
out in this privacy policy.
15.2. We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.
16. International transfers
16.1. Some of our external third parties are based outside the UK and the EEA so their processing of
your personal data will involve a transfer of data outside the UK and the EEA.
16.2. Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree
of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the
UK which give personal data the same protection it has in the UK.
16.3. Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the UK and the EEA.
17. Data security
17.1. We have put in place appropriate security measures to prevent your personal data from being
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accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal data on our instructions
and they are subject to a duty of confidentiality.
17.2. We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.
18. Data retention
18.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting
or reporting requirements. We may retain your personal data for a longer period in the event of
a complaint or if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.
18.2. To determine the appropriate retention period for personal data, we consider the amount, nature
and sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal,
regulatory, tax, accounting or other requirements.
18.3. In some circumstances we will anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes, in which case we may use this
information indefinitely without further notice to you.
19. Your legal rights
19.1. Under certain circumstances, you have rights under data protection laws in relation to your
personal data.
19.2. You have right to request access to your personal data (commonly known as a "data subject
access request"). This enables you to receive a copy of the personal data we hold about you and
to check that we are lawfully processing it.
19.3. You have 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.
19.4. You have the right to request erasure of your personal data. This enables you to ask us to delete
or remove personal data where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal data 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 your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of your request.
19.5. You have the right to object to processing of your personal data 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
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your fundamental rights and freedoms. You also have the right to object where we are processing
your personal data for direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your rights and
freedoms.
19.6. You have the right to request restriction of processing of your personal data. This enables you
to ask us to suspend the processing of your personal data in the following scenarios:
• 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.
19.7. You have the right to request the transfer of your personal data to you or to a third party. 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.
19.8. You have the right to withdraw 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.
19.9. If you wish to exercise any of the rights set out above, please contact us.
19.10. No fee usually required: You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
19.11. What we may need from you: We may need to request specific information from you to help us
confirm your identity and ensure your 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.
19.12. Time limit to respond: We try to respond to all legitimate requests within one month.
Occasionally it could take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you updated.
