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Koia Global Limited Trading as Mava - Website Privacy Policy - 2022-09-13
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Koia Global Limited, Trading as Mava

Company Number 13215185

85 Great Portland Street Great Portland Street, , First Floor, London, England, London, W1W 7LT,

United Kingdom

12 September 2022 

Privacy Policy


1.1 Important information and who we are

Welcome to Koia Global Limited, Trading as Mava’s Privacy and Data Protection Policy (“ Privacy Policy”).

At Koia Global Limited, Trading as Mava (“we”, “us”, or “our”) we are committed to  protecting and respecting your privacy and Personal Data in compliance with the United  Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and  all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy  Policy will tell you about your privacy rights, how the law protects you, and inform our  employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:



Business contacts

Employees/Staff Members

Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data  processed at any time by us.

1.2 Who is Your Data Controller

Koia Global Limited, Trading as Mava is your Data Controller and responsible for your  Personal Data. We are not obliged by the GDPR to appoint a data protection officer and  have not voluntarily appointed one at this time. Therefore, any inquiries about your data  should either be sent to us on email at or sent in a letter to 85 Great  Portland Street Great Portland Street, , First Floor, London, England, London, W1W 7LT,  United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner’s  Office (ICO), the UK supervisory authority for data protection issues ( We  would, however, appreciate the chance to deal with your concerns before you approach  the ICO so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal  with your data on our behalf (known as “Processors”). Therefore, the responsibilities  described below may be assigned to an individual, or may be taken to apply to the  organisation as a whole. The Data Controller and our Processors have the following  responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases  laid out in the GDPR (see 2.2 below for more information on those bases);

Ensure that Processors authorised to process Personal Data have committed  

themselves to confidentiality or are under an appropriate statutory obligation of  confidentiality;

Implement appropriate technical and organisational measures to ensure a level of  security appropriate to the risk associated with the processing of Personal Data;

Obtain the prior specific or general authorisation of the Controller before engaging  another Processor;

Assist the Controller in the fulfilment of the Controller's obligation to respond to  requests for exercising the data subject's rights;

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;

Maintain a record of all categories of processing activities carried out on behalf of a  Controller;

Cooperate, on request, with the supervisory authority in the performance of its  tasks;

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; and

Notify the Controller without undue delay after becoming aware of a Personal Data  Breach;


2.1 Types of Data / Privacy Policy Scope

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).

We may collect, use, store and transfer different kinds of Personal Data about you which  we have grouped together below. Not all of the following types of data will necessarily be  collected from you but this is the full scope of data that we collect and when we collect it  from you:

Profile/Identity Data: This is data relating to your first name, last name, gender, date  of birth.

Contact Data: This is data relating to your phone number, addresses, email  

addresses, phone numbers.

Marketing and Communications Data: This is your preferences in receiving  

marketing information and other information from us.

Billing Data: This is information relating to your debit and credit card information  such as the name attached to your payment details and your billing address.

Transactional Data: This is information of details and records of all payments you  have made for our services or products.

We do not collect any Special Categories of Personal Data about you (this includes details  about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,  political opinions, trade union membership, information about your health, and genetic  and biometric data). Nor do we collect any information about criminal convictions and  offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and  processing of Personal Data. The main avenues we rely on are:

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 from you in order  to fulfil our contractual obligations and provide you with 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.


3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table  containing the different types of Personal Data we collect and the lawful basis for  processing that data. Please refer to section 2.2 for more information on the lawful basis  listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which  we use your data may be broader than described but we will never process your data  without a legal basis for doing so and it is for a related purpose. For further inquiries  please contact us.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us unless you  specifically request that you would not like to receive these communications. From time to  time we may make suggestions and recommendations to you about goods or services that  may be of interest to you.

3.3 Change of Purpose

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 us.

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,  in compliance with the above rules, where this is required or permitted by law.


4.1 How Does Koia Global Limited, Trading as Mava Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. 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.

Every time you access our services on the website you transfer some data across to the browser. We encrypt each transfer at 256-bit and send it through TLS 1.2 (HTTP over TLS), adhering to the FIPS 140-2 certification standard. Each session is limited to 7 days of idle time.  All messages between our services and users are encrypted at rest within our database.

 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 Koia Global Limited, Trading as Mava 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.

4.2 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by Unsubscribing.

Where you opt out of receiving these marketing messages, we will continue to retain other  Personal Data provided to us as a result of interactions with us not related to your  marketing preferences.

4.3 How to Request your Data, Data Removal and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other  rights).

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 may request your personal Data and submit requests for Data removal by emailing Requests will be handled within 15 business days.


5.1 Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data  with subcontractors or affiliates (subject to confidentiality obligations to use it only for the  purposes for which we disclose it to them and pursuant to our instructions).

We may also share Personal Data with interested parties in the event that Koia Global  Limited, Trading as Mava 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.

If Koia Global Limited, Trading as Mava 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).

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy.

5.2 Third-Party Links

This Site 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.


We will only retain your Personal Data for as long as reasonably necessary to fulfil 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.


All our data is stored using Amazon Web Services (AWS), the world's leading cloud computing service provider. AWS is a recognized provider of secure network architecture to protect your information, identities, applications, and devices.

The data is stored in the AWS EU Region that is designed and built to meet rigorous compliance standards, including ISO 27001, ISO 9001, ISO 27017, ISO 27018, SOC 1, SOC 2, SOC3, PCI DSS Level 1.

Your information may be stored and processed in the US or other countries or jurisdictions  outside the US where Koia Global Limited, Trading as Mava has facilities. We are currently storing  data in the EU and so, by using Koia Global Limited, Trading as Mava, you are permitting and  consenting to the transfer of information, including Personal Data, outside of the US.



We keep our Privacy Policy under review and will place any updates on this webpage. This  version is dated 12 September 2021. By using Koia Global Limited, Trading as Mava, you consent  to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of  Koia Global Limited, Trading as Mava will constitute your express acceptance of any  modifications to this Privacy Policy.


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. As a matter of common sense, 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.).

Our staff are not authorised to contract on behalf of Koia Global Limited, Trading as Mava, waive  rights or make representations (whether contractual or otherwise). If anything contained in an  email from a Koia Global Limited, Trading as Mava address contradicts anything in this policy, our  terms or any official public announcement on our website, or is inconsistent with or amounts to a  waiver of any Koia Global Limited, Trading as Mava rights, the email content will be read down to  grant precedence to the latter. The only exception to this is genuine correspondence expressed  to be from the Koia Global Limited, Trading as Mava legal department.