PLEASE READ CAREFULLY
For the purpose of the Data Protection Act 1998 (the Act), we are the data controller. We are registered with the Information Commissioner’s Office for the processing of personal data under registration number ZA089055.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Submitted Information: You may give us information about you by filling in forms on our sites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to receive our newsletter, search for a product, place an order on our sites, enter a competition, promotion or survey, participate in any interactive features that are currently, or may in future, be offered by our sites, and when you report a problem with our sites. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph or other information.
- Collected Information: We may also collect information about you automatically, as set out below:
- Technical Information: Each time you visit one of our sites we may automatically collect technical information about your device or computer, including where available details of the type of computer or device you use, your operating system and platform, a unique device identifier (for example, your device’s mobile number or IMEI number), the Internet protocol (IP) address used to connect your computer or device to the internet, the type and version of browser you use and time zone setting. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
- Information on Use of Our Sites: details of your visits to our sites including, but not limited to, text that you upload, traffic data, location data, weblogs, search results and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access (including products you viewed or searched for), full Uniform Resource Locators (URL) clickstream to, through and from our sites (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Third Party Information: We may receive information about you from third party sources or if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
IP Addresses and Cookies
In particular, our sites use Google Analytics to estimate our users’ usage patterns. Google Analytics counts the number of visitors and tells us things about their behaviour on our sites, such as the typical length of stay on the site or the average number of pages a user views.
As part of the operation of Google Analytics, Google will take the information about your visits to our sites and store the information on its sites in the USA. It is important to note that the USA is not included in the European Economic Area’s (EEA) list of countries recognised as having as stringent data protection regimes as EEA countries. Google will use the information it collects about you to understand your use of our sites, to compile reports on website activity and to provide other services relating to website activity and internet usage.
You can opt-out of Google Analytics for Display Advertising, to prevent your data from being used by Google Analytics, by going to the Google Analytics opt-out page.
We use ‘Session Cookies’, which allow us to track your actions during a single browsing session, but do not remain on your device afterwards. We also use ‘Persistent Cookies’, which remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our site.
Session and Persistent Cookies can be either first or third party cookies. A first-party cookie is set by the website being visited and a third-party cookie is set by a different website. Both types of cookie may be used by us or our business partners.
Any third party cookies will be governed by their own terms and privacy policies, so you should read these before giving your consent to enable these third party cookies.
If at any time you wish to disable our cookies, you may do so through the settings on your browser but if you do so you will not be able to use certain important features of our service.
We may also collect and store personal data on your computer or other device using application data caches and browser web storage (including HTML 5) and other technology.
USES MADE OF YOUR INFORMATION
We use information held about you in the following ways:
Submitted Information: We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to ensure that content on our sites is presented in the most effective manner for you and for your computer or device;
- to send you, using third party agencies as appropriate, a newsletter, information about goods or services, other news from us, or other marketing communications from us, if you have signed up for this;
- for the purposes of system administration; and
- to notify you about changes to our sites.
Collected Information: We will use this information:
- to administer our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our sites to ensure that content is presented in the most effective manner for you and for your computer or device;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our sites about goods or services that may interest you or them.
Third Party Information: We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Please note that if you do withdraw your consent whilst you can still view most of our sites you will not be able to join or receive newsletters, or place orders for products with us, and you accept and acknowledge that we have no liability to you in any such event.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you and to assist us with our marketing or newsletter communication with you (where appropriate).
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Where you are a business customer, credit reference agencies for the purpose of assessing your credit score.
- Where you are a business customer, the referees you specify in your credit account opening application form.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, including with respect to requests regarding licensing of copyrighted content.
- In order to:
- protect our operations, rights, property or safety, that of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE WE STORE YOUR PERSONAL DATA
The data may be stored and processed in Andorra, the UK, Ireland or any other country where Koooky SLU, its subsidiaries, affiliates, agents or suppliers are located. As noted above, the data that we collect from you may be transferred to, and stored at, a destination outside the EEA. Koooky SLU is also based in Andorra, which lies outside the EEA. Please note that countries outside the EEA may not have as stringent data protection regimes as EEA countries.
Information may be processed by staff operating outside the EEA who work for us or for one of our suppliers. We use Quality Fulfilment Partners to provide limited services on our behalf, including packaging, mailing and delivering purchases, answering customer questions about products or services, sending postal mail and processing event registration. We will only provide those companies the information they need to deliver the relevant services, and they are prohibited from using that information for any other purpose.
We partner with highly professional companies to try to ensure that your e-commerce transactions are safe and secure. When you place orders or sign up to our newsletter service, you will be utilising secure server software “SSL”, which encrypts your personal information before it is sent over the Internet. All information you provide to us is stored on our secure servers.
To process your online payments we use the services of PAYPAL and BRAINTREE (a PAYPAL Company). Both are world renowned payment processing system providers, who use some of the most secure means available to try to guarantee the security of your payment information.
Where we have given you (or where you have chosen) a password that enables you to access our sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We shall use reasonable commercial endeavours to store all information you provide to us safely and securely and protect it from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Unfortunately however, the transmission of information via the internet, or storage of information digitally, is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us or our sites or otherwise. Any transmission is at your own risk. Once we have received your information, we will use reasonable commercial procedures and security features to try to prevent unauthorised access.
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our products are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act, and you can contact us to request access by emailing email@example.com. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
You also have the right to ensure that we hold correct and up to date information. If you believe that any information we hold about you is incorrect or out of date, please contact us by emailing firstname.lastname@example.org. We may need to ask you for further information and identification to help us to comply with this request.