Legal

Privacy Policy

COBA TECHNOLOGY LTD understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and, when you use this website, we will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Last updated 08.11.23

Information about us

Our details are as follows:

COBA TECHNOLOGY LTD, registered in England under company number 12265683 (“COBA”). Registered address: 78 Cannon Street, London, EC4N 6HL Main trading address: 78 Cannon Street, London, EC4N 6HL VAT number: 403 4642 29 Data Protection Officer: Nick Simpson (email address: dpo@coba.io) Postal address: 78 Cannon Street, London, EC4N 6HL

COBA is the controller and is responsible for this website and your personal data.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What is personal data?

Personal data is defined in the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) and means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).

What are your rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13. The right to access the personal data we hold about you. Part 11 will tell you how to do this. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 13 to find out more. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold, including where you have successfully exercised your right to object (see below). Please contact us using the details in Part 13 to find out more. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. The right to restrict (i.e. prevent) the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios – e.g. if you want us to establish the data’s accuracy, or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. The right to object to us using your personal data for a particular purpose or purposes. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 13.

Requests, fees and response times

Data accuracy

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Fees

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Further information and complaints

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 13.

What personal data do we collect?

We may collect and hold some or all of the personal and non-personal data set out below.

Title Name Email address Telephone number Address Shipping address Job title Business name Demographic information such as post code, preferences, and interests IP address Web browser type and version

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.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How do we use your personal data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. We may use personal data to:

Develop and manage our relationship with potential and existing clients, suppliers and partners. This may include (i) delivering services or carrying out work that a client, supplier or partner has requested or that we are contractually obligated to do so and (ii) providing information about our product offerings and services that may be of interest to them Communicate with potential and existing clients, suppliers and partners. This may include (i) informing our clients or partners of our product offerings and services that may be of interest to them; (ii) providing information about relevant products or services, including, for example, pricing information, invoices, shipping or production information; and (iii) responding to questions or inquiries from our clients, suppliers or partners.

We may also use client, supplier and partner personal data for other uses consistent with the context in which the information was collected or with your consent.

We may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product development purposes. Such information will not individually identify any of our clients, suppliers or partners.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How long will we keep your personal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting, or necessary technical requirements.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Data security and storage

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Where we store or transfer your personal data

We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

Do we share your personal data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority or regulator. We may also share your personal data with our professional advisers, including lawyers, bankers, accountants and insurers, who provide us with professional services.

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.

Access, third-party links and changes

How can you access your personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

Third-party links

Changes to this privacy notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. This version was last updated on 08.11.23.

Any changes will be made available on www.coba.io.

How to contact us

Questions about your data

To contact us about anything to do with your personal data and data protection, including any request to exercise any of your rights outlined above, please use the following details (for the attention of the Data Protection Officer):

Email address: dpo@coba.io Postal address: 78 Cannon Street, London, EC4N 6HL.