ARTICLE 1. INTRODUCTION
1.1. Data Processor
The Data Processor is: Coconut Digital LTD (“we”,”us”, or “our”) with its registered address 15 Horselers, Hemel Hempstead, HP3 9UH, England, and business registration number: 07112218. Coconut Digital collects and processes personal data from both website Visitors and Customers (“Data Subject”, “you”, “your”, and “yours”).
1.2. Applicable Law
This Privacy and Cookie Policy (“Policy”) is prepared in accordance with both the General Data Protection Regulation (EU 2016/579) (“GDPR”) and the United Kingdom Data Protection Act 2018 (c 12). In light of the European Union (Withdrawal Agreement) Act 2020 c. 1 (“Brexit”), the GDPR remains applicable during a so-called intermediate period after Brexit. New data protection laws may apply in the nearby future, and as a result our privacy and data protection policy may change. Each Data Subject is solely responsible for checking this page regularly and must be aware of the most recent version of this Policy mentioned on the top of this page.
ARTICLE 2. TYPES OF DATA WE COLLECT AND PROCESS
2.1. Personal Data Collection
We collect and process different types of personal data: first and last name, phone number(s), email address(es), login credentials and company name. The complete details about the data we collect and process are mentioned in this Policy or we may specifically ask you prior to the data collection before you will use our services.
2.2. Mandatory and Optional Data
You may freely provide data and your personal information to us. Unless indicated otherwise, all data requested by Coconut Digital is obligatory and if you fail to give such data it may be impossible for us to offer you the requested services. We may also specifically state that giving data is not obligatory, and as a result, you are free to withhold the requested information as it will not have any consequences to the functioning of our services. If you are uncertain which personal data is mandatory, you are welcome to contact us at: privacy@coconutdigital.com
2.3. Usage and Log Data
When you use our services, Coconut Digital may automatically collect usage and log data about how you use and access our website, including information about the device you are using, IP addresses, location information, language settings, and operating system you are using. We may also place cookies when visiting our website, please refer to our Cookie Policy as part of this document.
2.4. Facebook Pixel
Data Subject agrees and acknowledges that we make use of Facebook Pixels on our website, meaning visitor action pixels from Facebook INC. Facebook Pixels allow us to track the behavior after visitors have been redirected to our website after having clicked on a Facebook advertisement. As a result, we may measure the effectiveness of such ads for market research and statistical purposes. At all times, the data collected by Facebook Pixel technology remains anonymous to us, meaning we do not identify any personal data from individual users. However, Facebook may link this information directly to your Facebook account and may use it for their own marketing purposes. Please read their respective privacy and data protection policies. You can turn Facebook’s off by browsing to the following URL: https://www.facebook.com/settings?tab=ads.
2.5. Methods of Processing
Coconut Digital undertakes to implement all necessary and industry-standard security measures to prevent disclosure and unauthorized access of your personal data. We collect and process your personal data by using software tools, following procedures strictly in relation to the purposes of processing data as mentioned in this Policy. The data may be accessible to persons within our organization involved in the daily operations of Coconut Digital, or any authorized third-party service providers, mail carriers, hosting providers, etcetera, appointed by us. The most recent list of these third-party service providers may be requested from us at any time.
ARTICLE 3. LEGAL BASIS OF DATA PROCESSING
3.1. Legitimate Interest
Based on Article 6 GDPR, it is stated that in order for processing to be lawful, personal data should primarily be processed on the basis of the consent of the Data Subject, or some other legitimate basis may apply. We will always answer any questions to clarify the legal basis that applies to the processing of your personal data.
3.2. Legal basis.
We will process your personal data in one of the following situations:
3.2.1. You have given your explicit consent for one or more specific data processing purposes;
3.2.2. The provision of (personal) data is necessary for the performance of an agreement or a pre-contractual obligation which you are subject to;
3.2.3. The collection and processing of data is required to comply with a legal obligation to which we are subject, and either related to a task that is carried out in the public interest or for legitimate interests pursued by us or any third party.
ARTICLE 4. PLACE OF PROCESSING AND THIRD-PARTY PROCESSORS
5.1. Place.
All data is processed at our offices and in any other venue where we conduct our daily business operations. Transfer of data may take place and could involve transferring Data Subject’s data to a country other than their own. However, we always make sure that your data is treated with an adequate level of privacy and data protection.
5.2. Third-Party Processors.
The following third-party processors will process data on behalf of Coconut Digital. Please refer to their respective Privacy Policies.
| Company and Jurisdiction | Service | Link to Privacy Policy |
| Slack, INC. (USA) | Business Communication Platform | https://www.slack.com/privacy |
| Asana, INC. (USA) | Application to organize, track, and manage work | https://asana.com/terms#privacy-policy |
| Hubspot, INC. (USA) | CRM system | https://legal.hubspot.com/privacy-policy |
| Google Analytics (Google LLC., USA) | Website visitor analytics | https://policies.google.com/privacy |
| Facebook, INC., USA | Social Network Site | https://www.facebook.com/privacy |
| WordPress (Automattic, INC., USA) | Website and content management system | https://wordpress.com/blog/2017/12/04/updated-privacy-policy/ |
| Stripe | Payment Processor | |
| PayPal | Payment Processor |
ARTICLE 5. RETENTION TIME
5.1. Data Retention.
Your personal data shall be stored and processed for as long as it is required by the applicable law and the legitimate purpose(s). Personal data collected for our legitimate interests shall be kept as long as necessary. We decide to retain personal data for a longer period of time, but always as long as your consent is not withdrawn, for the performance of a legal obligation or after an order issued by an authority or a court of law.
5.2. Expiration.
Once the retention period has expired, your personal data shall be removed, and as a result, the right to access, correct, delete or transfer your data cannot be exercised by you anymore.
ARTICLE 6. PURPOSE
6.1. Purposes of Data Processing
There are several purposes for collecting and processing your personal data, primarily it is necessary to provide our services to you. In addition we do so for the following reasons:
6.2. Device Permissions
Depending on Data Subject’s device, Coconut Digital may request specific permissions that allow us to access device data. These device permissions must be given by the Data Subject before the respective information can be accessed by us. You can always revoke your consent through the device settings, depending on your device and operating system.
ARTICLE 7. PERSONAL DATA FROM MINORS
7.1. Data Collection Minors
The Data Subject must be – at all times an adult according to the applicable law. Minors may use the services of Coconut Digital only with the assistance and permission of a parent or legal guardian. Persons under the age of thirteen (13) may under no circumstances visit our website, submit personal data and use our services, and if you suspect this is the case please report it immediately to us.
7.2. UK Underaged Policies
The competent data protection authority in the United Kingdom is the Information Commissioner Office, and they have formulated guidelines covering the protection of personal data from minors. Please refer to the following URL. https://ico.org.uk/for-organisations/guide-to-data-protection/key-data-protection-themes/children/
ARTICLE 8. DATA SUBJECT RIGHTS
8.1. Rights.
According to the applicable law, Data Subjects may exercise specific rights in connection to their data collected and processed by us. These rights may depend on the applicable law. According to Chapter 3 of the GDPR, you have the following rights:
8.2. Public Interest.
In the case your personal data is processed for a public interest, Data Subjects may object by presenting a ground related to their particular situation in order to justify such an objection.
8.3. Marketing.
You agree and acknowledge that if your personal data is processed for direct marketing purposes, you can object to that at any time, and without providing any reason whatsoever. However, you can never object to the use of your personal data necessary to execute our contractual duties with you.
ARTICLE 9. EXERCISING YOUR RIGHTS
9.1. Requests
Any requests to exercise your legal rights can be sent to us through the email address provided in this document. These requests can always be exercised free of charge and will be addressed by us as withing fourteen (14) days.
9.2. Legal Purposes
We may use your data in a court of law or the phases leading to litigation, and such legal action may arise from the violation of this Policy or other agreements with Coconut Digital or the improper use of our services. Also, we may be forced to reveal your personal data after we have received a request from the public authorities.
ARTICLE 10. CHANGES
We may make changes to this Policy at any time. We recommend you to check this page regularly and refer to the date of the last modification mentioned at the top of this page. However, should our new Privacy Policy affect processing activities performed based on your consent, we shall collect your consent again.
ARTICLE 11. COOKIE POLICY.
11.1. Cookies
As is common with almost all websites, this website uses cookies. Cookies are small files that are downloaded onto your computer meant to improve your experience. This page describes what information the cookies collect, how we use it, and why we sometimes need to store them.
11.2. How We Use Cookies
We use cookies for several reasons as detailed below. There are no industry standards for disabling cookies without completely disabling the functionality and all features available on our website.
11.3. Account-Related Cookies
At the moment you create an account with us, we will use cookies for managing the signup and login process. These cookies will usually be deleted when you log out, but in some cases, they are used to remember your site preferences when logged out.
11.4. Third-Party Cookies
We also do sometimes use cookies provided by trusted third parties. The following section sets out which third party cookies you might encounter on our website.
This site uses Google Analytics for helping us to understand how you use our website and ways that we can improve your experience. These cookies may track things such as how long you spend on the website and the pages that you visit so we can continue to produce engaging content.
11.5. Disabling Cookies
You can prevent the use of cookies by changing the settings in your browser. However, disabling cookies will affect the functionality of our website and also certain essential features on the website. For that reason, it is recommended that you do not disable them.
11.6. More Information
We hope this Policy has clarified your legal relationship with us regarding the processing of your personal data. If you still have questions, please email us at privacy@coconutdigital.com.
This Privacy and Cookie Policy has been prepared based on the General Data Protection Regulation (2016/579) and multiple other legislations.