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Privacy and Cookie Policy

 

  1. Introduction
    • We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
    • This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
    • We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
    • In this policy, "we", "us" and "our" refer to Cosi Care Ltd. For more information about us, see Section 19.
  2. The personal data that we collect
    • In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
    • We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address. The source of the contact data is you.
    • We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
    • We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content, address, contact details and metadata associated with the communication such as the date and time of sending. We obtain this data when people contact us by email, phone, post or via social media. . 
    • We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
    • We may process information collected in connection with any marketing subscription or opt-out request, such as email addresses and marketing preferences (“marketing data”).

 

  • We may process information we obtain when website visitors complete and submit enquiry forms on our website (“enquiry data”), including name, email address, phone number, company name, any personal data included in the subject or message content and any metadata associated with the communication (such as time and date of submission). This information is provided to us by people who complete and submit forms on our website, and our website generates the communication metadata associated with the forms.
  1. Purposes of processing and legal bases
    • In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
    • Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
    • Relationships and communications - We may process contact data, enquiry datatransaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and customers , the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
    • Direct marketing - We may process contact data marketing data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email and/or post for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and customers.
    • Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website,goods and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, goods and services and business generally.
    • Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
    • Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
    • Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    • Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    • Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
    • Using personal data for marketing purposes. We send occasional emails containing information about our business and products to the following categories of people:
  • individual customers who have previously bought our products

(b) people who have subscribed to receive our newsletter or other marketing communications

If you receive such communications from us and do not wish to, you can tell us by using the unsubscribe link in any email we send to you or emailing [insert the correct email address].

  1. Sensitive personal data that we collect
    • The sensitive personal data, also referred to as “special category personal data” is personal data that is deemed to be more sensitive than the personal data as described above and includes data concerning health..
  2. Providing your personal data to others
    • We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
    • We may disclose your personal data to organisations or individuals engaged by us in the course of providing our services: such as individual consultants or their personal service companies who provide software/website programming/development services.
    • We use a number of service providers in connection with our website, services, communications and IT infrastructure, which involves those service providers processing some of the personal data described in this notice to the extent necessary to provide the relevant services. We currently use the following providers:

Service provider name

Nature of services

Types of data processed

Shopify - https://www.shopify.com/

Website hosting.

Contact Data

Transaction Data

Communication Data

Usage Data

Marketing Data

Enquiry Data

Klaviyo

Email Communication, Email Marketing.

Contact Data

Transaction Data

Communication Data

Usage Data

Marketing Data

Enquiry Data

Google Analytics

Website Analytics, Facebook Ads, Instagram Ads, Email Marketing.

Contact Data

Transaction Data

Communication Data

Usage Data

Marketing Data

Enquiry Data

 

  • In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  1. International transfers of your personal data
    • In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
    • We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
    • We transfer some personal data to the service providers described in the ‘Providing your personal data to others’ section above that are based in countries outside the UK. Below we describe these transfers and the safeguards in place to protect personal data once it has been transferred.

Third country (non-UK)/international organisation

Safeguards in place to protect your personal data

Retrieve a copy of the safeguards in place here:

Klaviyo (USA)

Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

 

For more information please contact us at:

info@cosi-care.com

Shopify (Ireland)

Transfer is permitted under the UK adequacy regulations.

For more information please contact us at:

info@cosi-care.com

 

  1. Retaining and deleting personal data
    • This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    • We will retain your personal data as follows:
      1. contact data will be retained for a period of 6 years after the relevant customer contract has terminated;
      2. transaction data will be retained for a period of 1 year following the date of the transaction;
      3. communication data will be retained for a period of 1 year following the date of the communication in question, but if the communication relates to a customer contract we store the communication for 6 years after termination of the customer contract to which the communication relates;
      4. usage data will be retained for 1 year following the date of collection;
      5. enquiry data: submitted web contact forms are stored for 1 year. We receive data in the form of emails, which we store for 2 years and
      6. marketing data: we will continue to use this data until we receive an opt-out request, after which time we will retain the email address and marketing preference information to ensure that we do not send marketing to the unsubscribed email address.
    • Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  2. Security of personal data
    • We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
    • We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
    • The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
    • Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
    • You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
    • You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
  3. Your rights
    • In this Section 9, we have listed the rights that you have under data protection law.
    • Your principal rights under data protection law are:
      1. the right to access - you can ask for copies of your personal data;
      2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
      3. the right to erasure - you can ask us to erase your personal data;
      4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
      5. the right to object to processing - you can object to the processing of your personal data;
      6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
      7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
      8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
    • These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
    • You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
  • Third party websites
    • Our website may include hyperlinks to, and details of, third party websites.
    • In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
  • Personal data of children
    • Our website and services are targeted at persons over the age of 18.
    • If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
  • Updating information
    • Please let us know if the personal information that we hold about you needs to be corrected or updated.
  • About cookies
    • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    • Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    • Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
  • Cookies that we use
    • We use cookies for the following purposes:
      1. authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website (cookies used for this purpose are: [identify cookies]);
      2. shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are: [identify cookies]);
      3. personalisation - we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: [identify cookies]);
      4. security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: [identify cookies]);
      5. analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: [identify cookies]); and
      6. cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: [identify cookies]).
    • Cookies used by our service providers
      • Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
      • We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy. The relevant cookies are:

Cookie name

Default expiration time

Description

_ga

2 years

Used to distinguish users.

_gid

24 hours

Used to distinguish users.

_ga_<container-id>

2 years

Used to persist session state.

_gac_gb_<container-id>

90 days

Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.

 

  • We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.
  • We use Instagram. Instagram gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Instagram 's use of information by visiting ….……. and you can review Google's privacy policy at https://policies.google.com/privacy. The relevant cookies are:
  • "_fbp" is used to distinguish and keep track of your unique users.
  • "_fbc" is only set when a user arrives at your website from an Ad, and the destination URL includes the click identifier "fbclid".
    • We use Klaviyo. Klaviyo gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Klaviyo 's use of information by visiting ….……. and you can review Google's privacy policy at …… The relevant cookies are:

Cookie

Purpose

__kla_id

Tracks when someone clicks through a Klaviyo email to your website

KL_FORMS_MODAL

Tracks when someone subscribes (opts in) to a form

 

 

  • You can contact us:
    1. by post, to the postal address given above;
    2. using our website contact form;
    3. by telephone, on the contact number published on our website; or
    4. by email, using the email address published on our website. (info@cosi-care.com)

 

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