Privacy Policy

A picture of the Kuba head office

Privacy Notice

Last updated: 23rd December 2021

This Privacy Notice describes how we Kuba Limited (“KubaPay”, “we”, “our” or “us”) collect, store, use and disclose personal data regarding individuals (“you”,”visitor”); who visit or otherwise interact with our websites, available at or any other website, webpage, e-mail, text message or any additional extensions, or when you contact us, or you use or are a recipient of our services.

This Privacy Notice contains the following sections:

Kuba is committed to keeping visitor information secure and processed in compliance with our legal obligations. To prevent unauthorised access or disclosure, Kuba has instituted physical, electronic and managerial processes and procedures to protect the information collected. You acknowledge that information given by you is supplied voluntarily.

Please read this Privacy Notice carefully and make sure that you fully understand and agree to it.

Data Collection

While using our service, We may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include:

  • Your name, address, email address, telephone number(s) and other contact details;
  • Information required to provide you with a service, and details of our services that you have used;
  • Your company’s name, your position in the company, the company’s address, company’s email address and telephone number;
  • Information collected through using our websites, e.g. by cookies;
  • Details of any enquiry or complaint;
  • Your payment information;
  • Video information from CCTV recording systems deployed at our sites for security and safety reasons;
  • Telephone call recordings.

We must have a legal basis to process your personal information. In most cases, the legal basis will be one or more of the following:

  • In accordance with a contract;
  • To allow us to comply with our legal obligations;
  • To meet our legitimate interests, e.g. understanding how our customers use our services and to develop new services as well as improving the services we already provide; or
  • Where it is in the substantial public interest in the case of special categories of personal information.

We collect personal information in the following ways:

  • Directly from customers: e.g. when a customer signs up to receive our services or registers on our websites
  • From third parties who use our services
  • From other companies in the ICM Mobility Group
  • From third parties (when we acquire third party marketing lists or information from the electoral roll; get authorisation for a payment you make or when undertaking an identity or credit check)
  • When services are provided together with a business partner and the information is collected by the business partner in order for us to provide you with services

Data Uses

We may use the information we collect in the following ways:

  • To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
  • To improve our website to better serve you.
  • To send periodic emails regarding your order or other products and services.
  • To follow up after correspondence.

The table below sets out what we use your personal information for and the legal basis for doing so:

What we use your personal information forThe legal basis for doing so
Provide you with services that you may request from us
  • In accordance with a contract
  • Compliance with legal obligations
  • Legitimate interests - to provide a high standard of service; to protect the interests of our business and customers
Administer payments
  • In accordance with a contract
  • Compliance with legal obligations
Resolve queries and complaints
  • In accordance with a contract
  • Compliance with legal obligations
  • Legitimate interests - the ensure our business is run prudently, queries are addressed, and complaints are investigated so we can prevent reoccurence
Enhance or improve your experience of our services and websites
  • Compliance with legal obligations
  • Legitimate interest - to ensure that our customers’ experiences of our websites and services are satisfying and to encourage continued interest
Improve and develop our services
  • Legitimate interest - to ensure that our services meet the needs of our customers
Tell you about our services
  • Legitimate interest - to provide our customers with information about our services that may be of interest, provided that we have our customers’ consent to do so
Protect security, e.g. to check your identity when you use our services
  • In accordance with a contract
  • Compliance with legal obligations
  • Legitimate interest - to prevent and investigate fraud and to check your identity in order to protect our business
To comply with our legal obligations
  • Compliance with legal obligations
  • Legitimate interest - to protect our business

Data Sharing

Third-party disclosure

We do not sell, trade, or otherwise transfer the data we collect to outside parties. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. In some cases we may share your personal data with business partners when Kuba and the business partner sponsor an event together or participate in a marketing promotion together and in which you engage.

Third-party providers

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users, read more about Google’s Advertising Principles. We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt-Out page or by using the Google Analytics Opt-Out Browser add-on.

Our Sites and Service (including some of our Service Providers) utilise “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide our Service and ensure that it performs properly, to analyse our performance and marketing activities, and to personalize your experience. For more information, such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, previously indicated by a User. To learn more about our practices concerning cookies and tracking please see our Cookie Policy.

How to manage cookies

Below is a list of the main cookies we use on our websites and what we use them for: - Essential Cookies
CookieNamePurposeMore Information
Essential site cookie
Essential authentication cookie
‘Other relevant cookies’?

Data Security

We are committed to keeping customers’ personal information secure, to protect it from being inappropriately or accidentally accessed, used, shared or destroyed, and against it being lost.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information.

We handle all data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Further details can be found at The Information Commissioner's Office.

Data Location and Retention

Data Location

We may need to transfer customer personal information outside the UK. If we do, we will ensure that information is protected to a level which meets the requirements of the relevant law.

Data Retention

We will only retain customer information for as long as we need it to carry out a particular purpose or meet a particular obligation. Information will then be disposed of securely.

Data Subject Rights

Under the UK General Data Protection Regulation (UK GDPR), data subjects have the right to be informed about the processing of their personal data. In addition, you have the right:

  • to access your personal information at any time;
  • to rectify it when it is inaccurate or incomplete;
  • to request the erasure of your personal data, under certain conditions;
  • to restrict or object to certain processing of your personal data;
  • to data portability and not to be subject to automated individual decision-making.

To exercise the above mentioned rights, you can contact the responsible data controller directly or contact us via the contact form on KUBA’s website. Please use the phrase “Exercising Data Protection rights” in the heading. We will endeavour to provide a response within one month of receipt of a Subject Access Request (SAR). However, if the request is complex, an extension of up to a further two months may be requested from the individual making the request.

For questions or complaints concerning the processing of your personal data, you can contact the Data Protection Officer at

KUBA’s Data Protection Officer

Kuba is registered with the UK Information Commissioner’s Office - Reg. No.: ZB250279. Additionally, Kuba has appointed a Data Protection Officer (DPO) to ensure the application of the principles of personal data protection in the company.

The DPO provides an independent advisory function. They provide advice and make recommendations to Kuba and its staff on their rights and obligations. They monitor Kuba’s compliance with the UK GDPR and serve as a contact point for data subjects on privacy matters. In critical situations, the DPO may investigate matters and incidents on request or on their own initiative.