Privacy Policy

Privacy Policy

We are committed to protecting your personal data and complying with relevant data protection legislation. This Privacy Policy describes why we collect and how we process your Personal Data through your use of our website and in your interactions with us as a customer. It also outlines your rights and tells you how to contact us if you have questions about your Personal Data.

Our website is not intended for children and we do not knowingly collect data relating to children.

Data Controller: the controller is The Coconut Collaborative Ltd, a company registered in England & Wales (Registration No. 07471527).

Our full details are:

The Coconut Collaborative Ltd, 10 Queen Street Place, London, EC4A 1AG.

Email address: info@coconutco.co.uk

Third party links

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 Personal Data do we collect?

When we refer to “Personal Data”, we mean information from which you may be personally identified.

We may collect the following Personal Data about you, which we have grouped together as follows:

Identity data: first name, last name, user name or similar identifier, age, date of birth, title, family status, gender, marital status;
Contact data: postal addresses, email addresses and telephone numbers;
Financial data: bank account details; payment card information;
Transaction data: such as payments to and from you, purchase or orders made by you, delivery address and details of products you have purchased from us;
Technical Data: includes internet protocol (IP) address, your login data, browser type and version, date and time information, location, browser plug-in types and versions, operating system and platform, and other technical information about the devices you use to access this website.
Profile data: including your username and password, your interests, type of diet, preferences, feedback and survey responses;
Usage Data including information about how you use our website, products and services;
Marketing Data including your preferences in receiving marketing from us and your communication preferences;
Lifestyle Data including shopping habits and preferences, and lifestyle details such as hobbies and interests.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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). In this case, we may have to cancel a product order you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;

order our products;
create an account with us;
request newsletters to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Product tester

If you sign up as a Coconut Collaborative product tester, we will collect profile and lifestyle data in addition to the types of personal data listed in “Direct interactions” above.

Automated technologies or interactions and pixel tags on our website and in our emails.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies server logs, pixel tags (sometimes called “Internet tags”, "web beacons" or "clear GIFS") and other similar technologies. We may also receive Technical Data about the identity of the website you visited immediately before coming to our site and if you visit other websites employing our cookies. Please see our cookie policy for further details.

Pixel tags and cookies in our emails may be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us. We use this information for purposes including:

Determining which of our emails are more interesting to you; and
Determining your activity with our products and services.

The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you don’t need to download the images in the email and the default setting is to view the email in plain text only.

Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources as set out below

Technical Data from the following parties:

analytics providers such as Google based outside the EU;
Contact, Financial and Transaction Data from providers of technical, payment, delivery and mailing services such as Feefo, Mailchimp and Shopify based inside OR outside the EU.
Identity and Contact Data from publicly available sources such as Companies House based in the UK.

How we use your Personal Data

When you supply your Personal Data to us it will always be clear why we are collecting it. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal obligation.
Where you have consented to us sending newsletters or other marketing information to you.
Where you have consented to us gathering profile/lifestyle data from you if you are a product tester.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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 at info@coconutco.co.uk.

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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To create an account with us as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to give feedback or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated) (d) Consent when we ask for your feedback/send a survey
To enable you to partake in a competition, promotion or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics and automated technology to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to personalise your online experience, to develop our business and to inform our marketing strategy)
To keep customers updated on our products via newsletters and make suggestions and recommendations to you about products or recipes that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Consent
To keep potential customers updated on our products via newsletters and make suggestions and recommendations to you about products or recipes that may be of interest to potential customers, and invite potential customers to enter competitions or take a survey	(a) Identity (b) Contact (c) Usage (d) Profile (e) Marketing and Communications	Consent
Testing our current and new products through our product testing programme	(a) Identity (b) Contact (c) Usage (e) Profile (f) Marketing and Communications (g) Lifestyle	Consent

Marketing information from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us such as newsletters and surveys if you have opted in to receive such information. You can always opt out of receiving that marketing by clicking the ‘unsubscribe’ link in the email or by emailing us at info@coconutco.co.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase or other transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Who will your data be shared with?

We may share your personal data with the parties set out below for the purposes set out in the table above.

(1) Internal Third Parties, namely other companies in the Coconut Collaborative Group acting as joint controllers and who are based in the USA and who undertake leadership reporting as well as potential customer and customer engagement.

(2) External Third Parties, namely:

Service providers acting as processors based in the UK who provide IT and system administration services;
Service providers acting as processors based in the UK who provide a marketing automation platform;
Service providers acting as processors based in the UK who provide marketing services to us;
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

International Transfers

We share your personal data within the Coconut Collaborative Group. This will involve transferring your data outside the European Economic Area (EEA) and to the USA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en ; or
Where we share your personal data within the Coconut Collaborative Group, or where we use certain service providers , we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security

We take the security of your Personal Data very seriously and maintain high levels of protection to ensure that there is no loss of or unauthorised access to it. We require our third party data processors to do likewise. We have appropriate technical and organisational measures in place to safeguard your Personal Data. These include technical and physical restrictions on our servers, which are password protected to prevent unauthorised access, modification or misuse.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. In relation to credit card details and once your order has been processed securely online, we do not keep your credit card details. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

Your rights

You have various rights in relation to your Personal Data, as follows.

Right of access – you may request a copy of the Personal Data which we hold about you.

Right to rectification – you are entitled to request to have inaccurate personal data rectified, or completed if it is incomplete.

Right to erasure - you can also ask us to delete, remove, or stop using your Personal Data if there is no need for us to keep it. 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.

Right to restrict processing - you may ask us to restrict the use of your Personal Data in certain circumstances (for example, it is inaccurate).

Right to data portability – we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to object to processing - you can object to us keeping or using your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Withdraw consent at any time where we are relying on consent to process your personal data - this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

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.

Contact us

Questions, comments and requests regarding this notice or your Personal Data can be addressed to us at info@coconutco.co.uk or The Coconut Collaborative Ltd, 16a Great Peter Street, London, SW1P 2BX.

You also have the right to complain to the regulator, and to lodge an appeal if you are not happy with the outcome of a complaint. In the UK this is the Information Commissioner’s Office. Find out on their website how to report a concern.

Last updated: 26^th March 2021