Privacy policy
1. Data controllers
Your personal data is jointly processed by:
- Alevia Nova Ltd (England and Wales, no. 16601692) — for services related to the Kudu™ technology platform
- Financial Digital Technology (FIDITECH) SAS (Côte d'Ivoire, RCCM CI-ABJ-03-2023-B16-00079) — for agent network operations and wallet management
Contact: contact@kudu.cash
2. Data collected
In the course of providing our services, we may collect the following categories of data:
Identification data
- Name, surname, date of birth
- Email address, phone number
- Identity documents (as part of KYC — Know Your Customer procedures)
Financial data
- Transaction history (transfers, tontines, group funds)
- Wallet addresses (crypto-assets)
- Payment information
Usage data
- IP address, browser and device type
- Pages visited, browsing duration
- Geolocation data (with your consent)
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Account creation and management | Performance of contract |
| Money transfers and transactions | Performance of contract |
| Identity verification (KYC/AML) | Legal obligation |
| Fraud prevention | Legitimate interest |
| Marketing communications | Consent |
| Service improvement | Legitimate interest |
4. Asset custody model
Kudu™ operates a user-custodial model. This means:
- You are the sole holder of your private keys and digital assets
- Kudu™ does not hold, control or have access to your funds
- You are responsible for securing your assets
5. Data sharing
Your data may be shared with:
- Transak — on-ramp provider (fiat-to-crypto conversion) for European users, subject to its own privacy policies
- FIDITECH agent network — independent exchange bureaux in Côte d'Ivoire, Benin and the DRC, for cash-out operations
- Competent authorities — upon legal or regulatory request (anti-money laundering, counter-terrorism financing)
- Scaleway — data hosting provider (France)
6. Data retention
- Account data: duration of the contractual relationship + 5 years after closure
- KYC data: 5 years after end of business relationship (AML legal obligations)
- Transaction data: 5 years (accounting and tax obligations)
- Browsing data: 13 months maximum
7. Your rights
Depending on your place of residence, you benefit from specific data protection rights:
UK and EU users
Under the UK GDPR (supervised by the ICO) and the General Data Protection Regulation (GDPR, supervised by the CNIL for data hosted in France), you have the following rights:
- Right of access to your personal data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing
- Right to withdraw consent at any time
- Right to lodge a complaint with the ICO (UK) or CNIL (France)
Côte d'Ivoire users
Under Law No. 2013-450 on the protection of personal data, supervised by ARTCI, you have rights of access, rectification, deletion and objection to the processing of your data.
Benin users
Under Law No. 2009-09 and the Digital Code (Law No. 2017-20), supervised by the APDP (Personal Data Protection Authority), you benefit from similar rights of access, rectification and deletion.
Democratic Republic of the Congo users
Under Ordinance-Law No. 23/010 establishing the Digital Code, supervised by the ARPD (National Data Protection Authority), you have personal data protection rights.
8. Cookies
The kudu.cash website uses strictly necessary cookies for the operation of the site. These cookies do not require your prior consent.
We do not use advertising or third-party tracking cookies.
9. Security
We implement appropriate technical and organisational measures to protect your data:
- Data encryption in transit (TLS) and at rest
- High-availability infrastructure hosted by Scaleway (France)
- Strict access controls and enhanced authentication
- Monitoring and intrusion detection
10. Contact
To exercise your rights or for any questions regarding the protection of your data:
- Email: contact@kudu.cash
- Phone: +225 05 01 44 73 44