In simple terms, our privacy pledges to you are:
- We will only collect, keep, use and share Personal Data for legitimate business reasons that we explain in this document, or if we’re legally required to do so.
- We will be as clear and open as we can with you on what Personal Data we collect and how it will be processed
- We will keep all Personal Data up to date and reflect your preferences. We will also keep all data safely and securely with appropriate measures to prevent abuse.
This website is not intended for children and we do not knowingly collect data relating to children.
FOR OUR CUSTOMERS, CLIENTS, PROSPECTIVE CUSTOMERS AND PROSPECTIVE CLIENTS
We collect the following Personal Data from or about you as a customer of CoGo:
- Personal Data collected directly from you through business processes such as your name, phone number, postal address and email address. The legal basis for the collection and processing of this data is the provision to you of the services accessed by you.
- Personal Data received indirectly through our suppliers which enables us to create, store and record communications history. The legal basis for collecting and processing this personal data is our legitimate interests in knowing more about our customers.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use your Personal Data:
- For the administration of your account and to contact you about your account (for example with details on the work we produce for you or where we need to perform the contract we are about to enter into or have entered into with you).
- To contact you with marketing messages which you have requested or agreed to receive from us (for example via an email newsletter).
- To contact you with surveys and feedback requests.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Google Analytics, a web analytics service provided by Google, Inc. (“Google”) also places cookies on your computer, to enable Google to provide us with activity reports relating to the website. Google uses this data only to provide us with information on how users use the website and does not associate your IP address with any other data held by Google. The information generated by Google cookies about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Again, if you wish to stop this, you can stop these cookies being collected by changing the settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
CoGo will never sell, rent or swap your personal data or give it to anyone else for them to use for their own purposes without making that clear to you. There are, however, various ways in which we will share your data, as set out below:
- Sharing data within our group:
The CoGo of companies share various operations and business processes. We may share your personal data with any member of our group in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so (for example, whilst you may order a product from us, the delivery of that product might be fulfilled by another member of our group).
- Sharing with organisations providing services to us:
We engage various third parties to provide services to us for specific functions, and this will often mean that we need to share your personal data with them (it is in our legitimate interests to do so, since we may not have the capabilities to provide these services ourselves). In each case, we will ensure that these third parties are only allowed to use your personal data in order to provide the relevant services to us. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.
Some examples of these third parties will include: distribution services, credit card processing services, order fulfilment, analytics, website management, information technology and related infrastructure provision, customer service, e-mail service providers for sending transactional and marketing emails, auditing, and other similar services.
- Sharing data to comply with laws:
There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime.
- On transfer / sale of our business:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will share your Personal Data with social media sites such as Facebook, Twitter and Linkedin to enable them to provide marketing messages that you have agreed to receive from them.
For our followers on Social Media
If you follow one of our social media channels, CoGo will receive Personal Data about you such as your account name, gender, general interests, location and age. The legal basis for processing this data is our legitimate interest in providing social media and marketing content that is of interest to our followers on social media.
We use this Personal Data:
- to provide bespoke social media content (for example by analysing your general interests).
- to create targeted content across all our social media channels (for example by analysing responses to posts, events and videos).
- to find out more about our digital community (for example by analysing the age ranges of our followers).
The CoGo will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate the Sites, provide our services to you and administer your account.
For our website visitors
By using our website, we collect Personal Data about you such as: site referrals, browsing pattern, browser type, location, general interests, gender and age. The data transmitted from your browser includes your IP address, the date and time of the visit, the pages accessed, the access status/ HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is our legitimate interest in operating the sites, providing you with access to the pages you wish to access, understanding the interests of our potential customers and providing you with relevant information about our services.
We use this Personal Data:
- to provide you with bespoke website content (for example by analysing our site visitors’ age ranges);
- to gain insight into your behaviour and preferences (for example by analysing the website pages you visit);
- to create bespoke marketing messages (for example by analysing the click throughs on our site);
- to re-target our website visitors with relevant marketing messages (for example by using cookies hosted on our site); and
- to collect site statistics.
The CoGo will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate our website, provide our services to you and administer your account or otherwise as required or permitted by law.
For our data processors
We use third party processors to collect, export, process and store Personal Data on our behalf. These third parties include cloud storage providers to allow us to maintain business operations, social media platforms to enable them to provide marketing messages that you have agreed to receive from them, web feed management providers to allow us to provide relevant up to date content, customer relationship management solution providers to enable us to provide relevant support and relevant marketing messages, SEO providers and IT and related infrastructure providers to help with our business operations, such as webpage optimisation, data analysis and market research.
International Data Transfers
We use data processors located outside the UK only after taking such steps as are required to ensure that Personal Data they process on our behalf receives protection equivalent to that provided in the EU under GDPR. Our processors have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
- We use a variety of technical and physical safeguards which exist to protect the security and integrity of your Personal Data. This helps protect it from accidental or unauthorised access, use, alteration or disclosure to unauthorised third parties. These measures include device encryption, firewalls and virus checking procedures.
- Where we keep Personal Data files on local devices these devices are protected and accessible only to authorised CoGo employees.
- As a matter of course, we undertake periodic reviews of our security systems to ensure that they remain fit for purpose and that your Personal Data remains safe and secure.
DURATION OF STORAGE
We will maintain records of your Personal Data for as long as you remain:
- a registered subscriber to our mailing list;
- have completed a purchase with the CoGo in the last 36 months; or
- for as long as is necessary to provide our services to you.
If you have not opened any email communication from a CoGo brand or interacted in any other way with our brands for 36 months we will regard you as an inactive subscriber and delete your details from our records except where retention is necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Rights in Relation to Personal Data
- You can update your subscription preferences or unsubscribe from our marketing communications at any time by following the link in the footer of the last email you received from us (“Update your subscription preferences” or “Unsubscribe”) or by sending your request with detailed instructions for our Account Management team.
- You have the right to update and correct the personal information on your account. You also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data. Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request. You also have the right to object to our continued processing of your personal data. You may also have the right to data portability. If you have a complaint about the way in which we use your personal information you have the right to file a complaint with us.
CHANGES TO OUR PRIVACY NOTICE
We will update this Privacy Notice from time to time to reflect changes in our business. All such changes will be posted to the website and where necessary, we will also contact our subscribers by email. This version was last updated on March 22nd 2022. Historic versions can be obtained by contacting us.
The CoGo group of companies is the Data Controller in respect of any Personal Data that you submit to us or that we collect from or about you. If you would like to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy Notice, or our Sites, our contact details are as follows: