1. Who is responsible for your data
KAVODA LTD (“KAVODA”, “we”, “us”) is the controller of the personal data described in this policy. We are a private limited company registered in England and Wales, company number 14647624, with our registered office at 29 Queensbridge Drive, Ramsgate, Kent, CT11 9TU, United Kingdom.
For anything to do with your personal data, email support@kavoda.tv with the subject “Privacy”, or write to the address above.
2. What this policy covers
This policy covers the KAVODA TV app on Roku devices, the website at kavoda.tv, the sign-in pages we host for the app (on api.kavoda.tv), the emails we send, and our support conversations with you.
It does not cover what Roku collects on its own account. Your Roku device, the Roku Channel Store, Roku Pay and Roku’s advertising settings are governed by Roku’s privacy policy. Payment details for KAVODA Plus are handled by Roku; we never receive your card number.
3. The data we collect
Data you give us
- Email address, when you create an account or ask for a sign-in link or code.
- Password, if you choose to sign in with one. We store it only as a one-way hash, which means we cannot read it.
- Date of birth, used to apply age ratings (see section 10).
- Your marketing choice — whether you want emails about new series and offers.
- Your messages to our support address, and anything you choose to include in them.
- Launch-updates sign-ups on the website: the email address you enter.
Data collected automatically when you use the app
- Account and session identifiers. A random account ID; before you sign in, a random anonymous ID so that the app can remember your place and your My List on that device.
- Device data. An identifier for your Roku device (Roku’s device ID or one the app generates), the device model and firmware version, the app version, and settings such as your caption language.
- Advertising identifier. The Roku Advertising ID and your “Limit ad tracking” choice, used only for advertising on the free tier (section 5).
- Network data. Your IP address and the approximate country or region derived from it. We use it to offer the service only where it is available, to protect the service against abuse, and to deliver video from a server near you.
- Viewing activity. Which series and episodes you start, watch, pause, skip and finish; how far you got (so you can resume); the series you save to My List; what you search for; the ad breaks and brand clips you were shown; and the time each of these happened.
- Purchases and entitlements. Whether you hold KAVODA Plus, and the transaction identifiers and receipts Roku sends us to confirm it. Not your card details.
- Consent records. Which versions of the Terms of Use and this policy you accepted, your marketing choice, and when and on which device you made them.
- Diagnostics. Errors, failed playback attempts and performance measurements, so we can fix problems.
Data we receive from others
- From Roku: purchase and subscription status for KAVODA Plus; and, only if you give permission on the screen, the email address on your Roku account, so you do not have to type it when signing in.
- From sign-in providers such as Google or Apple: your email address and the confirmation that you signed in — only if we switch those options on and you choose to use them. They are not enabled at the date of this version.
- From our email provider: whether the emails we send you were delivered.
On the website
kavoda.tv sets no cookies and runs no analytics or third-party scripts. If you sign up for launch updates, we receive the email address you enter, the time, and the country your connection comes from, and we send that to our own inbox as the record of your sign-up.
4. Why we use your data, and our legal grounds
Under UK and EU data protection law we need a legal ground for each use of personal data. This table sets them out.
| What we do | Data involved | Legal ground |
|---|---|---|
| Provide the service: play content, run your account, send sign-in links and codes, resume where you left off, keep My List and your history in step across devices. | Account and session IDs, email, device data, viewing activity | Performance of our contract with you; for use without an account, our legitimate interest in offering a working service. |
| Show age-appropriate content and lock titles above your age rating. | Date of birth, viewing activity | Our legal obligations and our legitimate interest in protecting younger viewers. |
| Run KAVODA Plus: confirm your subscription with Roku and remove ad breaks. | Entitlement and receipt data, account ID | Performance of our contract with you. |
| Deliver advertising on the free tier, limit how often you see the same ad, and measure that ads played. | Advertising identifier, IP address, device data, which content was playing | Our legitimate interest in funding a free service. Personalised advertising only where your Roku settings allow it, which is how consent is given where the law requires it (section 5). |
| Order the For You feed and suggest what to watch next. | Viewing activity, account or anonymous ID | Performance of our contract with you and our legitimate interest in a service people enjoy. These suggestions have no legal or similarly significant effect on you. |
| Understand how the service is used and improve it: which episodes people finish, where they drop off, what breaks. | Viewing activity and diagnostics, in aggregated form wherever possible | Our legitimate interest in improving the service. |
| Keep the service secure, prevent fraud and abuse, and offer it only where it is available. | IP address, device data, account activity | Our legitimate interests and our legal obligations. |
| Send service messages: sign-in emails, receipts, notices about your account or changes to these documents. | Email address | Performance of our contract with you; our legitimate interest in keeping you informed. |
| Send marketing emails about new series, features and offers. | Email address, marketing choice | Your consent, which you can withdraw at any time (section 9). |
| Report to the studios and distributors who license content to us how their titles perform. | Aggregated viewing statistics only — no personal data | Our legitimate interest in meeting our contracts with licensors. |
| Keep records, comply with the law and handle disputes. | Consent records, purchase records, correspondence | Our legal obligations and our legitimate interest in defending our rights. |
Where we rely on legitimate interests we have weighed them against your interests and rights, and you can object at any time (section 11).
5. Advertising on the free tier
The free tier of KAVODA TV is paid for by advertising. Ads are delivered through Roku’s advertising platform and its advertising partners. To request and play an ad, the following is shared with them: your Roku Advertising ID, your IP address, your device type, the name of the app and the category of content playing, and your “Limit ad tracking” choice. This is used to deliver the ad, to stop you seeing the same ad too often, and to measure that it played. Where your Roku settings allow it, Roku and its partners may also use the advertising identifier to personalise ads across apps.
Your controls. On your Roku, go to Settings → Privacy → Advertising and turn on Limit ad tracking, or reset your advertising identifier. We pass that choice on with every ad request. KAVODA Plus removes ad breaks altogether.
We do not use your date of birth, your email address or sensitive information for advertising, and we do not give advertisers your email address. We do not sell personal data. Under some US state laws the disclosure of identifiers to advertising partners for cross-context behavioural advertising counts as “sharing”; you can opt out of it with the Roku setting above or by emailing us (section 11).
6. Who we share data with
- Companies that run the service for us (processors acting on our instructions, bound by contract to protect your data): cloud hosting and database providers for accounts and the catalogue (Supabase and DigitalOcean), content delivery and security (Cloudflare), email delivery (Resend), product analytics (PostHog), and managed caching infrastructure.
- Roku, as the platform your device runs on: Roku processes KAVODA Plus payments, confirms subscriptions to us, and delivers advertising, under Roku’s own privacy policy.
- Advertising partners, as described in section 5.
- Content licensors — the studios and distributors whose series you watch — receive aggregated statistics only, such as plays and completion rates per title and territory. They do not receive anything that identifies you.
- Professional advisers and insurers, where needed for legal, accounting or insurance purposes.
- Authorities and law enforcement, where the law requires it or to protect the rights, property or safety of KAVODA, our viewers or others.
- A buyer or successor, if KAVODA or the KAVODA TV service is sold or reorganised. We will tell you if that happens and the new owner will be bound by this policy until it changes it in accordance with section 14.
7. International transfers
KAVODA is based in the United Kingdom. The servers that run the service are in the United States, video and images are delivered through a global network, and some of the companies in section 6 process data in the United States or the European Union. So if you are in the UK or the EU, your personal data is transferred outside the UK and the European Economic Area.
When that happens we protect it with safeguards recognised by UK and EU law: the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, and, where the recipient is certified, the UK–US Data Bridge and the EU–US Data Privacy Framework. You can ask us for details of the safeguards that apply to you.
If you are in the United States, your data may likewise be processed in the United Kingdom and the European Union.
8. How long we keep data
We keep personal data only as long as we need it for the purposes above, and then delete it or make it anonymous.
- Account data (email, date of birth, preferences, My List, resume positions): for as long as your account exists. When you delete your account, it is removed from our live systems promptly and from backups within 90 days.
- Use without an account: data tied to an anonymous ID is kept for up to 12 months after the device was last used.
- Viewing and interaction events: in identifiable form for up to 24 months, after which they are aggregated or deleted.
- Consent records: for as long as we need to show that we met our legal obligations, up to 6 years after your account closes.
- Purchase and entitlement records: for the period tax and accounting law requires, up to 6 years.
- Support correspondence: up to 24 months after the matter is closed.
- Security logs (including IP addresses): up to 12 months.
- Marketing and launch-updates lists: until you opt out, or until we close the list.
9. Marketing emails and your choices
With your permission, we send occasional emails about new series, new features and offers on KAVODA TV. If you join the launch-updates list on the website, you will get one email when KAVODA TV goes live and the occasional short note before then.
- It is off by default. In the app we ask you once, when you first start, whether you would like these emails (“Email me about new series and offers”). On the website you choose by entering your email in the launch-updates form.
- Change your mind at any time: in the app under Settings → Email updates; with the unsubscribe link at the bottom of every marketing email; or by emailing support@kavoda.tv. Opting out takes effect straight away for anything we have not already sent.
- Service emails still arrive. Opting out of marketing does not stop the emails the service needs to send you: sign-in links and codes, receipts, and important notices about your account or about changes to these documents.
- We keep a record of the choice you made, when, and the version of this policy it was made under, and we never pass your email address to advertisers.
10. Children and age ratings
KAVODA TV is not intended for children under 13, and we do not knowingly collect personal data from anyone under 13. Viewers aged 13 to 17 may use the service with a parent or guardian’s permission. If you believe a child under 13 has given us personal data, email support@kavoda.tv and we will delete it.
Every series on KAVODA TV carries an age rating. We ask for your date of birth so that titles above your age are hidden or locked, and we use it for nothing else: not for advertising, and never shared with advertising partners.
11. Your rights
If you are in the United Kingdom or the European Union
You have the right to: access the personal data we hold about you; have inaccurate data corrected; have your data erased; restrict how we use it; receive the data you gave us in a portable form (portability); object to uses based on our legitimate interests, and to direct marketing at any time; and withdraw consent wherever we rely on it, without affecting what was done before. You also have the right not to be subject to decisions based solely on automated processing that have legal or similarly significant effects; we make no such decisions.
If you are in the United States
Depending on your state, you may have the right to know what personal data we collect and how we use and share it; to access, correct and delete it; to receive a portable copy; to opt out of the sale of personal data, of its sharing for cross-context behavioural advertising, and of targeted advertising and profiling; to limit the use of sensitive personal data; and not to be discriminated against for exercising these rights. You may also appeal a decision we make about a request.
For California residents: in the 12 months before this version we collected the categories of personal data described in section 3 (identifiers, commercial information, internet and app activity, coarse location, age, and inferences used to order the feed). We have not sold personal data. We have shared identifiers and app activity with advertising partners through Roku’s platform to deliver advertising, as section 5 describes. We do not knowingly sell or share the personal data of anyone under 16.
How to use your rights
- In the app: Settings → Delete account removes your account and its data; Settings → Email updates changes your marketing choice; your date of birth and captions settings can be changed in Settings.
- On your Roku: Settings → Privacy → Advertising → Limit ad tracking opts you out of personalised advertising and of the sharing described in section 5.
- By email: support@kavoda.tv, subject “Privacy request”. We may ask you to confirm your identity — usually by replying from the email address on your account. We respond within one month (45 days for US state-law requests), free of charge unless requests are clearly excessive. An authorised agent may act for you with your written permission.
Complaints. We would like the chance to put things right first, so please contact us. You can also complain to the UK Information Commissioner’s Office at ico.org.uk or on 0303 123 1113; in the EU, to the supervisory authority in your country; and in the United States, to your state attorney general.
12. Security
We protect personal data with measures appropriate to the risk: encrypted connections throughout the service, encrypted video delivery protected by short-lived access tokens, passwords stored only as hashes, access to systems limited to the people who need it, and providers bound by contract to the same standards. If a breach ever puts your rights at risk, we will tell you and the regulator as the law requires. No system is perfectly secure, so please keep your sign-in details to yourself.
13. Cookies and device storage
- The website kavoda.tv uses no cookies, no analytics and no third-party scripts or fonts.
- The app stores your settings and the tokens that keep you signed in within the app’s own storage on your Roku device. Deleting your account, or removing the channel from your Roku, clears it.
- The sign-in pages on api.kavoda.tv use only the browser storage strictly necessary to complete a sign-in (for example the code you are approving), cleared when you are done. They set no advertising or analytics cookies.
- Roku collects its own data about your device and the apps you use, under Roku’s privacy policy and settings.
14. Changes to this policy
We will update this policy when the service or the law changes. Each version carries a version number and effective date at the top. For changes that matter to you we will give notice in the app or by email, and the app will ask you to accept the new version before you continue. Earlier versions are available on request.
15. Contact and complaints
Email support@kavoda.tv with the subject “Privacy”, or write to KAVODA LTD, 29 Queensbridge Drive, Ramsgate, Kent, CT11 9TU, United Kingdom. Regulators: the Information Commissioner’s Office (ico.org.uk) in the UK; your national supervisory authority in the EU; your state attorney general in the United States.