Privacy Policy
Last updated: 19th November 2025
KODA ("we", "us", "our") is a private European community currently operating a waitlist-only mobile application (the "App"). This Privacy Policy explains how we collect, use, and protect your information when you join the KODA waitlist.
By joining the waitlist or using the App, you agree to the terms outlined here.
1. Who We Are
KODA is operated by:
KODA
Contact email: support@kodamembership.com
We are based in the United Kingdom and process data in accordance with UK GDPR.
As we are currently structured as an individual developer account rather than a company, "KODA" refers to the operator of the App acting under that name.
2. Information We Collect
Because the current version of the App is waitlist-only, we only collect the information needed to manage your application and contact you when the full community launches.
2.1 Information you provide
For women:
- Full name
- Age
- Height
- City and nationality
- English level (self-assessed)
- Travel availability
- Instagram handle
- Photo (optional but recommended)
For men:
- Full name
- Age
- Height
- City and nationality
- Job title
- Instagram handle
- Travel availability
- Photo
2.2 Automatically collected data
When you use the App, we may collect limited technical information:
- Device type
- OS version
- Basic interaction logs
- Crash data (via Firebase)
We do not currently use advertising trackers, behavioural analytics, or third-party marketing pixels.
3. How We Use Your Information
We use your information to:
- Manage waitlist applications
- Verify identity and prevent impersonation
- Assess eligibility for the future KODA community
- Contact you about your application or approval
- Improve the app and user experience
- Ensure safety and authenticity within the community
- Comply with legal obligations
We may also use photos for:
- Internal review/QC
- AI-based moderation tools (internal only)
We do not use your photos or data for marketing without your explicit consent.
4. How We Share Information
We share your information only with:
- Internal team members involved in review
- Authorised contractors working on the App (e.g., developers), all under confidentiality agreements
We do not sell or rent your data.
We do not share waitlist data with scouts, partners, advertisers, or external agencies.
5. Legal Basis for Processing
Under UK GDPR, we process your data based on:
- Consent — you submit your information voluntarily
- Legitimate interests — to operate the waitlist, review applications, and build a safe community
You may withdraw consent at any time by contacting: support@kodamembership.com
6. Data Retention
We keep waitlist data only for as long as necessary to:
- Process your application
- Contact you
- Maintain the integrity of the waitlist
If you request deletion, we will remove your data within 30 days, except for minimal security logs retained as legally required.
7. Your Rights
As a UK or EU individual, you have the right to:
- Access your data
- Correct inaccuracies
- Request deletion
- Withdraw consent
- Object to processing
- Lodge a complaint with the ICO
To exercise these rights: support@kodamembership.com
8. Age Requirement
You must be at least 18 years old to use the App or join the waitlist.
9. Security
We use Firebase and industry-standard security measures to protect your data. However, no digital system is perfectly secure, and you use the App at your own risk.
10. Transfers Outside the UK
Your data may be stored in Firebase servers located outside the UK. These transfers are protected through standard safeguards and encryption.
11. Changes to This Policy
We may update this Privacy Policy as KODA evolves. Updates will be posted in the App and on our website (if applicable).
12. Contact Us
For all privacy matters: support@kodamembership.com