LAST UPDATED: 10TH JULY 2018
We are the Coco Swim (“we”, “us”, “our”), and we are committed to protecting your privacy.
Coco Swim is the controller for the purposes of the General Data Protection Regulation (the “GDPR”).
2) WHAT INFORMATION DO WE COLLECT, AND HOW?
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
- information you give us:you may give us information about yourself if you sign up for an account on our Website, place an order for products, complete any online forms (such as registration forms, competitions, and surveys), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Website, or correspond with us (by email, telephone, instant chat, social media or otherwise).
Depending on what you provide, this information can include your name, address or location, phone number and email address, date of birth, gender, purchase information, shopping preferences, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).
- information our IT systems collect about you:each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes:
- device information: the information provided by your device will differ depending on which type of device you are using (whether it’s a PC, Mac, iPhone, Android, or otherwise) and the settings on that device, but includes the type of device you have (such as an iPhone 6S or Samsung Galaxy S7), the device’s IP address, the browser you are using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.
3) WHAT DO YOU USE MY INFORMATION FOR?
To provide you services and the Website, including to allow you to order and receive products using our Website, administer your account and to optimise your experience we need to use the information that we collect in a number of different ways.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information to tailor these messages to you. You may unsubscribe from email marketing communications by modifying your preferences in the promotional emails we send you.
We also carry out research, analysis, and surveys on your use of our Website, and views. Finally we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security.
Please note that we do not sell your information without your consent (whether your name, address, emails address, financial information, or otherwise) to any third party.
Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data:
- To fulfil the orders you make through our website,we collect your Name, addresses, phone number, Order details, like the products you are buying, the size and price. The legal basis is the performance of a Contract with you.
- To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us)we collect your name, email, password and addresses and your contact history with us. The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.
- To monitor the quality of our customer services,we collect your name, email and addresses and your contact history with us. The legal basis is the legitimate interests in running our business.
- To administer, maintain and optimise our Website and our services,we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
- To send you marketing communications and personalised offers,we collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device information; Shopping preferences; Cookie identifiers; Internal identifiers; Country. The legal basis is the legitimate interests to electronic direct marketing of similar products and services to that which you have acquired using our Website or, when such is not applicable, your Consent.
- To manage our loyalty programmes,we collect your Name; Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is our legitimate interests in running our business and improve the shopping experience.
- Analysis of your behaviour and purchases in our Website,we collect your Name Email; Phone Number; Addresses; Date of Birth; Purchase history; Browsing history and behaviour; Device Information; Shopping preferences; Nickname; Cookie identifiers; Internal identifiers; Country; Spent tier level and Wealth. The legal basis is our legitimate interests in running our business and improve our Website and your experience.
- Carry on research, analysis, enquiries and surveys on your use of our website,we collect your Name; Addresses; Email; Device information, demographic information (including gender, country of residence and household income) and content of survey responses. The legal basis is our legitimate interests in running our business and improve our Website and your experience.
- Advertising and retarget advertising,we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
4) WHO DO YOU SHARE MY INFORMATION WITH?
To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
- Third party service providers for business purposes:to function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
- Courier companies, such as EMS, that we use in order to deliver the products to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address;
- Payment providers (PayPal) that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in the European Union, United States and China and are engaged depending on your location;
- Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimisation of the website. These providers are based in the United States and in Europe.
- Research companies that we can engage to help us carry out surveys regarding your use of our Website and Services.
- IT/technology providers that we use to support, maintain and provide our technology and IT infrastructure that supports our Website and the storage of your information.
- advertisers for marketing purposes:we can provide your information to our advertising and social media partners (including Facebook and Twitter, where you choose) where they require the data to select and serve relevant adverts about our products and services to you and others;
- to comply with legal requests:on occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands;
- aggregated information with third parties:we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Website, purchase of products, and other general, grouped information about our customers on the basis of our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies to help measure traffic, and other providers to allow them to better stock products, and our investors. Please note that we do not share your information with any third party advertisers or networks for the provision of third party advertising on our Website.
We use technology such as "cookies" to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our Website:
CATEGORY 1: STRICTLY NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
CATEGORY 2: PERFORMANCE COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. You may opt in to these cookies using your browser settings but it may affect the performance of our Website.
CATEGORY 3: FUNCTIONALITY COOKIES These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt in to these cookies using your browser settings but it may affect the functionality of our Website.
CATEGORY 4: TARGETING COOKIES OR ADVERTISING COOKIES These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
CATEGORY 5: SOCIAL MEDIA COOKIES These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. Please refer to the respective privacy policies for how their cookies work.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.
You can withdraw your consent to these cookies at any time through the following options:
- Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
Many web browsers support Do Not Track technology. While we strive to offer you choices when you use our website and services, we do not promise that we will be able to receive or honour web browser Do Not Track signals.
6) HOW LONG WILL YOU USE MY INFORMATION FOR?
We retain the data you provide to us for as long as you have your account with us and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.
In some circumstances you can ask us to delete your data as set out below.
After you have terminated your use of our services, we may store your information in an aggregated and anonymised format.
7) WHAT ARE MY PRIVACY RIGHTS?
You have certain rights in relation to the personal data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organization needs to show a valid power of attorney issued by you. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at firstname.lastname@example.org.
- Access.You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. To get to know this information please contact us by email@example.com
We may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person) or where another exemption applies.
- Portability.You have the right to receive a subset of the personal data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such personal data to another party. The relevant subset of personal data is data that you provide us with your consent or for the purposes of performing our contract with you.
If you wish for us to transfer the personal data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property).
- Correction.You have the right to correct any personal data held about you that is inaccurate. You can edit your personal information in “My Account” settings. You can also request the correction by emailing us. Please note that in some cases we can ask you to explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
- Erasure.You may request that we erase the personal data we hold about you in the certain circumstances. Please scroll below to know what those are:
- you believe that it is no longer necessary for us to hold the personal data we hold about you;
- we are processing the personal data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the personal data;
- we are processing the personal data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data;
- you no longer wish us to use the personal data we hold about you in order to send you promotions and special offers;
- you believe the personal data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing the data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case.
Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too.
- Restriction of Processing to Storage Only. You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).
Please scroll below to know the cases where you may request we stop processing and just store the personal data we hold about you.
- you believe the personal data is not accurate for the period it takes for us to verify your claim;
- we wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data for storage but not further process it;
- we wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
- you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
You also have the right to object to our processing of data about you and we will consider your request in other circumstances as detailed below:
- we are processing the data we hold about you (including where the processing is profiling) on the basis of our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest;
- Withdrawal of Consent.You can withdraw your consent at any time by unsubscribing at the bottom of each email received or by writing emailing us as set out below.
- by emailing us at firstname.lastname@example.org.
9) UPDATES TO THIS POLICY