kuto

Privacy Policy

Last updated: July 6, 2026

1. Who We Are

Kuto is operated by Iridian LLC, a Texas limited liability company ("Kuto," "we," "us," or "our"). Kuto is an affiliate marketplace that connects Shopify merchants with affiliates who promote their stores. This Privacy Policy explains what information we collect, how we use it, and your rights with respect to it.

By creating an account or using the Kuto platform (including kuto.link and the Kuto mobile app), you agree to this policy.

2. Who This Policy Covers

This policy applies to three types of people who interact with Kuto:

  • Merchants: Shopify store owners who list their store on Kuto and pay affiliate commissions
  • Affiliates: users who generate tracked links and earn commissions on sales they drive
  • End consumers: customers who purchase through a merchant's Shopify store via an affiliate link. Kuto receives limited order-level data about these transactions (see Section 3.5) but does not store consumer PII such as names, email addresses, or shipping addresses.

3. Information We Collect

3.1 Account Information

When you create a Kuto account, we collect your name and email address. If you sign in with Google, we receive your name, email, and Google account ID from Google. If you sign in with Apple, we receive your name (if you choose to share it) and email address from Apple. If you set a password, it is stored as a one-way hash. We never store your password in readable form.

3.2 Merchant Information

If you connect a Shopify store, we collect your store's myshopify.com domain and an access token that allows us to create and manage discount codes on your store. This token is encrypted at rest using AES-256-GCM. We also store the commission rate, consumer discount rate, payout delay, and other listing settings you configure.

3.3 Affiliate Information

If you use Kuto as an affiliate, we store your chosen handle (a public username used as your discount code on merchant stores), the affiliate links you generate, and your pending and available commission balances. Your handle is publicly visible to merchants and, when used as a discount code at checkout, to the merchants' Shopify stores.

3.4 Images and Uploaded Content

Merchants may upload a store logo, and affiliates may upload a custom image for each affiliate link. These images are stored on Cloudflare R2, our cloud object storage provider. Images are processed server-side (resized and converted to WebP) before storage. We do not collect photos from your device camera roll except when you explicitly choose to upload an image using the in-app image picker. Uploaded images may be publicly visible as part of your listing or link in the Kuto catalog.

3.5 Transaction and Order Data

When a sale is attributed to an affiliate link, we receive order data from Shopify via webhook. This includes the Shopify order ID, order total (in cents), and timestamp. We use this solely to calculate and record affiliate commissions. We do not receive or store consumer names, email addresses, shipping addresses, or payment card details. Those remain entirely within Shopify and the merchant's payment processor.

3.6 Payment and Identity Data

Commission payouts are processed through Stripe Connect. When you connect a bank account to receive payouts, Stripe collects your name, date of birth, the last four digits of your Social Security Number, and your bank account details directly. Kuto does not see or store this information. It goes directly to Stripe and is governed by Stripe's Privacy Policy. We store your Stripe account identifier so we can route payouts to you.

3.7 Communications

We store your notification preferences (such as whether you want immediate or digest emails for new sales). When you contact us at [email protected], we retain that correspondence.

3.8 Usage Data

Our hosting provider (Railway) collects standard server logs including IP addresses, request paths, and timestamps. We use this for security monitoring and diagnosing errors. We do not run advertising trackers or third-party analytics pixels.

3.9 Crash Reports and Diagnostics

If the Kuto app or website encounters an error or crash, we collect a diagnostic report so we can find and fix the problem. Crash reports include the technical details of the error (such as a stack trace), your device model, operating system version, and app version. Error reports from our servers may include your account identifier or email address when the error occurred while processing your account's data. We use Sentry (Functional Software, Inc.) to collect and store these reports (see Section 6). Diagnostic data is used only for debugging and reliability. It is never used for advertising or profiling.

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area or the United Kingdom, we process your personal data under the following lawful bases:

  • Contract performance: processing necessary to operate your Kuto account, generate affiliate links, calculate and pay commissions, and collect merchant payments. This is the primary basis for most data processing on the platform.
  • Legitimate interests: fraud detection, security monitoring, platform integrity, and server logging. We have assessed that these interests are not overridden by your data protection rights.
  • Legal obligation: retaining financial records for the period required by applicable law (7 years for IRS purposes).
  • Consent: optional marketing communications, where we have obtained your explicit consent. You may withdraw consent at any time.

5. How We Use Your Information

  • Operating the platform: matching affiliates to merchants, generating tracked links, attributing sales, calculating commissions
  • Processing payments: collecting merchant charges through Shopify's billing system and paying out to affiliates via Stripe transfers
  • Sending transactional emails: new sale notifications, payout confirmations, link disable notices, password resets, and account security events
  • Maintaining the integrity of the platform: detecting fraud, enforcing our Terms of Service, and resolving disputes
  • Communicating with you about your account and material changes to this policy or our terms

We do not use your information for advertising. We do not sell or share your data with third parties for their own marketing or advertising purposes.

6. How We Share Your Information

We share your information with the following service providers to operate the platform:

  • Stripe: payment processing, affiliate KYC and identity verification, payout transfers, and 1099 tax document generation. Stripe operates as an independent data controller for information collected during Connect onboarding. By using Kuto, you acknowledge that payment processing is handled by Stripe in accordance with the Stripe Connected Account Agreement and Stripe's Privacy Policy.
  • Shopify: we create and manage discount codes on merchant stores using the Shopify Admin API, and receive order data via Shopify webhooks. Merchant customer data subject to Shopify GDPR data requests (customers/data_request, customers/redact, shop/redact) is handled via registered webhook endpoints. See Shopify's Privacy Policy.
  • Resend: transactional email delivery. Your email address is transmitted to Resend solely for the purpose of delivering emails you would expect to receive (sale notifications, payouts, security events).
  • Railway: our hosting and database provider. Your data resides on Railway's infrastructure, which is hosted on Google Cloud Platform in the United States.
  • Sentry (Functional Software, Inc.): error monitoring and crash reporting. Receives the diagnostic reports described in Section 3.9, which can include your account identifier or email address in error context. We have a data processing agreement in place with Sentry. See Sentry's Privacy Policy.
  • Cloudflare: network proxy and DDoS protection for kuto.link, and cloud object storage (R2) for uploaded images (merchant logos and affiliate link images). Cloudflare processes IP addresses and request metadata for all web traffic to kuto.link. Uploaded images are stored in Cloudflare R2 in the United States. See Cloudflare's Privacy Policy.

We may also disclose information where required by law, in response to a valid legal process, or to protect the rights, property, or safety of Kuto, our users, or the public.

We do not share your personal information with merchants, affiliates, or other users of the platform beyond what is necessary to operate it — for example, a merchant can see that a specific affiliate handle generated a sale, but cannot see that affiliate's email address or personal details.

7. International Data Transfers

Kuto is operated from the United States. If you are accessing the platform from the European Economic Area, the United Kingdom, or another jurisdiction with data transfer restrictions, your data will be transferred to and processed in the United States.

These transfers are made under appropriate safeguards. Our hosting provider (Railway/Google Cloud Platform) and payment processor (Stripe) offer Standard Contractual Clauses as the transfer mechanism for EU/UK data. By using the platform, you acknowledge that your data will be processed in the United States under these safeguards.

8. Data Retention

Data CategoryRetention Period
Account information (name, email)Duration of account; deleted within 30 days of account closure (subject to legal holds)
Shopify access tokenDeleted when merchant disconnects their store or closes their account
Transaction and commission records7 years minimum (IRS recordkeeping requirement)
Payout records7 years minimum (IRS recordkeeping requirement)
Server logsUp to 90 days (Railway infrastructure default)
Crash reports and diagnostic dataUp to 90 days (Sentry retention)
Support correspondence3 years after last contact

9. Cookies and Session Data

Kuto uses a single session cookie to keep you logged in on the web. This cookie is strictly necessary for the platform to function and cannot be disabled without also disabling your login session. The mobile app stores your authentication token in your device's secure storage (iOS Keychain / Android Keystore), not in a cookie.

We do not use advertising cookies, tracking pixels, or third-party analytics scripts. We do not respond to Do Not Track browser signals because we do not track users across third-party websites. We honor Global Privacy Control (GPC) signals as an opt-out of any future data sharing for cross-context behavioral advertising purposes (we currently do not engage in such sharing).

The Kuto mobile app does not track you across other companies' apps or websites. We do not use the Advertising Identifier (IDFA on iOS) or any equivalent device advertising identifier. Data collected by the app is used solely to operate your Kuto account and is not shared with data brokers or used for targeted advertising.

10. Your Rights

You have the right to:

  • Access the personal information we hold about you
  • Correct inaccurate information in your account
  • Request deletion of your account and personal data (subject to retention obligations in Section 8)
  • Object to processing based on legitimate interests
  • Restrict processing of your data in certain circumstances
  • Receive a copy of your data in a portable format (data portability)

You can delete your account and its data at any time from your profile page, on the web or in the mobile app, without contacting us. To exercise any other right, contact us at [email protected]. We will respond within 30 days (one month for GDPR; 45 days for CCPA, with one 45-day extension if needed). We may require identity verification before fulfilling a request.

California Residents (CCPA / CPRA)

California residents have the following rights in addition to the above:

  • Know what categories of personal information we collect and why
  • Know the categories of third parties with whom we share personal information
  • Opt out of the sale or sharing of personal information. We do not sell or share personal information
  • Correct inaccurate personal information (CPRA right)
  • Limit use of sensitive personal information. We collect Stripe account identifiers as part of payment processing; this information is not used for any purpose beyond routing payouts
  • Non-discrimination for exercising privacy rights

Categories of personal information collected (per CCPA-defined categories): Identifiers (name, email, account ID); Commercial information (commission earnings, transaction history); Financial information (Stripe account ID; actual banking data is held by Stripe, not Kuto); Internet or network activity (server logs, request paths, crash and diagnostic reports). We do not collect biometric data, geolocation, or inferences drawn from personal information.

Sources: Directly from you (account registration, onboarding forms); from Shopify (order data via webhook); from Stripe (payment event notifications).

EU and UK Residents (GDPR / UK GDPR)

In addition to the rights above, EU/UK residents have the right to lodge a complaint with their local supervisory authority. See Section 4 for the lawful bases under which we process your data. For data processed on the basis of consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

11. Security

We take reasonable technical and organizational measures to protect your data, including: AES-256-GCM encryption of Shopify access tokens at rest; HTTPS for all traffic; bcrypt hashing of passwords; HMAC verification on all Shopify webhooks; and signature verification on all Stripe webhooks. No system is perfectly secure. If you believe your account has been compromised, contact us immediately at [email protected].

12. Children's Privacy

Kuto is not directed at children under 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a minor, we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email and update the "Last updated" date at the top of this page. Your continued use of the platform after the effective date constitutes acceptance of the revised policy. If the change requires your consent under applicable law, we will obtain it before the change takes effect.

14. Contact

Questions or requests regarding this Privacy Policy should be sent to [email protected].

Iridian LLC · Kuto · kuto.link