Privacy Policy

Koda ("Koda", "we", "us", "our") is a product operated by Intels Hub Ltd, a company registered in England and Wales, of 82A James Carter Road, Mildenhall, IP28 7DE, United Kingdom. Intels Hub Ltd is the data controller for personal data processed through Koda for the purposes of UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

If you have any question about this policy or how your data is handled, contact us at hello@koda.coach.

We collect the following categories of personal data:

• Account data — name, email address, and authentication details (including via Google sign-in, if you choose that option).
• CV and career data — the contents of any CV, career history, achievements, qualifications, and any narration (typed or spoken) you provide about your experience.
• Vacancy and application data — job descriptions you submit and the application content Koda generates or you edit.
• Payment data — limited billing information (such as the last four digits of a card and billing address). Full card details are collected and processed directly by our payment processor and never reach or are stored on our servers.
• Usage and device data — how you use the service, log data, browser or device type, and, if you use our mobile app, limited device identifiers needed to operate the app.

We use your data to:

• Provide the service — parsing your CV, analysing vacancies against your evidence, and generating tailored application content, statements and interview preparation.
• Manage your account, process payments, and communicate with you about your account or the service.
• Maintain the security, integrity and reliability of the service, and prevent fraud or misuse.
• Understand aggregate usage patterns to improve the service.
• Comply with our legal obligations.

Your CV and career data is never used to train third-party AI models, and is never sold to any third party.

Under UK GDPR, we rely on the following lawful bases:

• Contract — processing necessary to provide the service you've signed up for.
• Legitimate interests — for security, fraud prevention, and improving the service, balanced against your rights and interests.
• Consent — for optional communications (e.g. marketing emails), which you may withdraw at any time.
• Legal obligation — where we're required to retain or disclose data by law, including tax and accounting records for payments.

We share personal data only with service providers who process it on our behalf, under contractual confidentiality and data protection obligations, to operate Koda:

• A database and authentication infrastructure provider, to securely store your account and application data.
• A payment processor, to handle subscription and one-time payments — see section 2 above regarding card data.
• A third-party AI language processing provider, to generate tailored application content from the evidence you supply. Your data is sent to this provider solely to produce your requested output and is not used by that provider to train its general-purpose models.
• Cloud hosting infrastructure, to run the application.

We do not sell your personal data. We may disclose data where required by law, to protect our legal rights, or in connection with a merger, acquisition, or sale of assets, in which case we'll ensure continued protection of your data.

Some of our service providers process data outside the United Kingdom, including in the United States. Where this happens, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, or reliance on an adequacy regulation, so your data receives a level of protection equivalent to that under UK law.

We retain your personal data for as long as your account is active, and for a reasonable period afterwards to comply with legal obligations, resolve disputes, and enforce our agreements. You can request deletion of your data at any time — see section 8. Where you delete your account, we will delete or anonymise your personal data within a reasonable period, except where we're required to retain certain records by law (for example, payment records for tax purposes).

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request erasure of your data ("the right to be forgotten").
• Restrict or object to certain processing.
• Receive a copy of your data in a portable format.
• Withdraw consent at any time, where processing is based on consent.
• Lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk.

You can exercise most of these rights directly from Settings within the app (viewing, editing or deleting your data), or by contacting hello@koda.coach. We will respond within one month, as required by law.

We use essential cookies and similar technologies necessary for the service to function (such as keeping you signed in), and limited analytics to understand how the service is used. We do not use cookies for third-party advertising. You can control cookies through your browser settings, though disabling essential cookies may prevent the service from working correctly.

We use industry-standard technical and organisational measures to protect your data, including encryption in transit and at rest, and access controls limiting who can view your data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security, but we work to protect your data to a high standard and will notify affected users and the ICO of any data breach where required by law.

Koda is not directed at, and is not intended for use by, individuals under 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

We may update this policy from time to time to reflect changes in our practices or for legal reasons. We'll update the "last updated" date above, and where changes are material, we'll notify you directly (for example, by email).

For any question about this policy or your data, hello@koda.coach, or write to Intels Hub Ltd, 82A James Carter Road, Mildenhall, IP28 7DE, United Kingdom.