This is the
privacy notice of Cohort Kiddies Club. In this document, “we”, “our”, or “us”
refer to Cohort Kiddies Club.
We are
company number 14605919 registered in the United
Kingdom.
Our
registered office is at Suite 2, Cohort Learning Centre, Pennington Close, West
Bromwich, West Midlands, B70 8BG.
Introduction
This
privacy notice aims to inform you about how we collect and process any
information that we collect from you, or that you provide to us. It covers
information that could identify you (“personal information”) and information
that could not. In the context of the law and this notice, “process” means
collect, store, transfer, use or otherwise act on information. It tells you about
your privacy rights and how the law protects you.
We are
committed to protecting your privacy and the confidentiality of your personal
information. Our policy is not just an exercise in complying with the law, but
a continuation of our respect for you and your personal information.
We
undertake to preserve the confidentiality of all information you provide to us,
and hope that you reciprocate.
Our policy
complies with the Data Protection Act 2018 (Act) accordingly incorporating the
EU General Data Protection Regulation (GDPR).
The law
requires us to tell you about your rights and our obligations to you in regards
to the processing and control of your personal data. We do this now, by
requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as
set out below, we do not share, or sell, or disclose to a third party, any
information collected through our website.
1. Data Protection Officer
We have
appointed a data protection officer (DPO) who is responsible for ensuring that
our policy is followed.
If you have
any questions about this privacy notice, including any requests to exercise
your legal rights, please contact our DPO Tanvir Walele at hello@cohortkiddiesclub.co.uk
2. Data we process
We may
collect, use, store and transfer different kinds of personal data about you. We
have collated these into groups as follows:
Your
identity includes information such as first name, last name, title, date of
birth, and other identifiers that you may have provided at some time.
Your
contact information includes information such as billing address, delivery
address, email address, telephone numbers and any other information you have
given to us for the purpose of communication or meeting.
Your
financial data includes information such as your bank account and payment card
details.
Transaction
data includes details about payments or communications to and from you and
information about products and services you have purchased from us.
Technical
data includes your internet protocol (IP) address, browser type and version,
time zone setting and location, browser plug-in types and versions, operating
system and platform and other technology on the devices you use to access this
website.
Your
profile includes information such as your username and password, purchases or
orders made by you, your interests, preferences, feedback and survey responses.
Marketing
data includes your preferences in receiving marketing from us; communication
preferences; responses and actions in relation to your use of our services.
We may
aggregate anonymous data such as statistical or demographic data for any
purpose. Anonymous data is data that does not identify you as an individual.
Aggregated data may be derived from your personal data but is not considered
personal information in law because it does not reveal your identity.
For
example, we may aggregate profile data to assess interest in a product or
service.
However, if
we combine or connect aggregated data with your personal information so that it
can identify you in any way, we treat the combined data as personal information
and it will be used in accordance with this privacy notice.
3. Special personal information
Special
personal information is data 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.
It also includes
information about criminal convictions and offences.
We do not
collect any special personal information about you.
4. If you do not provide personal information we
need
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 that contract. In that case, we may have to stop providing a service
to you. If so, we will notify you of this at the time.
If the basis changes then if
required by law we shall notify you of the change and of any new basis under
which we have determined that we can continue to process your information
The bases on which we process information about you
The law
requires us to determine under which of six defined bases we process different
categories of your personal information and to notify you of the basis for each
category.
If a basis
on which we process your personal information is no longer relevant then we
shall immediately stop processing your data.
5. Information we process because we have a
contractual obligation with you
When you
create an account on our website, buy a product or service from us, or
otherwise agree to our terms and conditions, a contract is formed between you
and us.
In order to
carry out our obligations under that contract we must process the information
you give us. Some of this information may be personal information.
We may use
it in order to:
· verify
your identity for security purposes
· sell
products to you
· provide
you with our services
· provide
you with suggestions and advice on products, services and how to obtain the
most from using our website
We process
this information on the basis there is a contract between us, or that you have
requested we use the information before we enter into a legal contract.
We shall
continue to process this information until the contract between us ends or is
terminated by either party under the terms of the contract.
6. Information we process with your consent
Through
certain actions when otherwise there is no contractual relationship between us,
such as when you browse our website or ask us to provide you more information
about our business, including job opportunities and our products and services,
you provide your consent to us to process information that may be personal
information.
Wherever
possible, we aim to obtain your explicit consent to process this information,
for example, by asking you to agree to our use of cookies.
If you have
given us explicit permission to do so, we may from time to time pass your name
and contact information to selected associates whom we consider may provide
services or products you would find useful.
We continue
to process your information on this basis until you withdraw your consent or it
can be reasonably assumed that your consent no longer exists.
You may
withdraw your consent at any time by instructing us at hello@cohortkiddiesclub.co.uk.
However, if you do so, you may not be able to use our website or our services
further.
7. Information we process for the purposes of
legitimate interests
We may
process information on the basis there is a legitimate interest, either to you
or to us, of doing so.
Where we
process your information on this basis, we do after having given careful
consideration to:
· whether
the same objective could be achieved through other means
· whether
processing (or not processing) might cause you harm
· whether
you would expect us to process your data, and whether you would, in the round,
consider it reasonable to do so
For example,
we may process your data on this basis for the purposes of:
·
record-keeping for the proper and necessary administration of our business
·
responding to unsolicited communication from you to which we believe you would
expect a response
·
protecting and asserting the legal rights of any party
· insuring
against or obtaining professional advice that is required to manage business
risk
·
protecting your interests where we believe we have a duty to do so
8. Information we process because we have a legal
obligation
Sometimes,
we must process your information in order to comply with a statutory
obligation.
For
example, we may be required to give information to legal authorities if they so
request or if they have the proper authorisation such as a search warrant or
court order.
This may
include your personal information.
Specific
uses of information you provide to us
9. Information provided on the understanding that
it will be shared with a third party
Our website
allows you to post information with a view to that information being read,
copied, downloaded, or used by other people.
Examples
include:
· posting a
message our forum
· tagging
an image
· clicking
on an icon next to another visitor’s message to convey your agreement,
disagreement or thanks
In posting
personal information, it is up to you to satisfy yourself about the privacy
level of every person who might use it.
We do not
specifically use this information except to allow it to be displayed or shared.
We do store
it, and we reserve a right to use it in the future in any way we decide.
Once your
information enters the public domain, we have no control over what any
individual third party may do with it. We accept no responsibility for their
actions at any time.
Provided
your request is reasonable and there is no legal basis for us to retain it,
then at our discretion we may agree to your request to delete personal
information that you have posted. You can make a request by contacting us at hello@cohortkiddiesclub.co.uk.
10. Complaints regarding content on our website
We attempt
to moderate user-generated content, but we are not always able to do so as soon
as that content is published.
If you
complain about any of the content on our website, we shall investigate your
complaint.
If we feel
it is justified or if we believe the law requires us to do so, we shall remove
the content while we investigate.
Free speech
is a fundamental right, so we have to make a judgment as to whose right will be
obstructed: yours, or that of the person who posted the content that offends
you.
If we think
your complaint is vexatious or without any basis, we shall not correspond with
you about it.
11. Information relating to your method of payment
Payment
information is never taken by us or transferred to us either through our
website or otherwise. Our employees and contractors never have access to it.
12. Job application and employment
If you send
us information in connection with a job application, we may keep it for up to
three years in case we decide to contact you at a later date.
If we
employ you, we collect information about you and your work from time to time
throughout the period of your employment. This information will be used only
for purposes directly relevant to your employment. After your employment has
ended, we will keep your file for six years before destroying or deleting it.
13. Communicating with us
When you
contact us, whether by telephone, through our website or by e-mail, we collect
the data you have given to us in order to reply with the information you need.
We record
your request and our reply in order to increase the efficiency of our business.
We keep
personally identifiable information associated with your messages, such as your
name and email address so as to be able to track our communications with you to
provide a high-quality service.
14. Complaining
When we
receive a complaint, we record all the information you have given to us.
We use that
information to resolve your complaint.
If your
complaint reasonably requires us to contact some other person, we may decide to
give to that other person some of the information contained in your complaint.
We do this as infrequently as possible, but it is a matter for our sole
discretion as to whether we do give information, and if we do, what that
information is.
We may also
compile statistics showing information obtained from this source to assess the
level of service we provide, but not in a way that could identify you or any
other person.
15. Affiliate and business partner information
This is
information given to us by you in your capacity as an affiliate of us or as a
business partner.
It allows
us to recognise visitors that you have referred to us, and to credit to you
commission due for such referrals. It also includes information that allows us
to transfer commission to you.
The
information is not used for any other purpose.
We
undertake to preserve the confidentiality of the information and of the terms
of our relationship.
We expect
any affiliate or partner to agree to reciprocate this policy.
Use of
information we collect through automated systems when you visit our website
16. Cookies
Cookies are
small text files that are placed on your computer’s hard drive by your web
browser when you visit any website. They allow information gathered on one web
page to be stored until it is needed for use on another, allowing a website to
provide you with a personalised experience and the website owner with
statistics about how you use the website so that it can be improved.
Some
cookies may last for a defined period of time, such as one day or until you
close your browser. Others last indefinitely.
Your web
browser should allow you to delete any you choose. It also should allow you to
prevent or limit their use.
Our website
uses cookies. They are placed by software that operates on our servers, and by
software operated by third parties whose services we use.
When you
first visit our website, we ask you whether you wish us to use cookies. If you
choose not to accept them, we shall not use them for your visit except to
record that you have not consented to their use for any other purpose.
If you
choose not to use cookies or you prevent their use through your browser
settings, you will not be able to use all the functionality of our website.
We use
cookies in the following ways:
· to track
how you use our website
· to record
whether you have seen specific messages we display on our website
· to keep
you signed in our site
· to record
your answers to surveys and questionnaires on our site while you complete them
· to record
the conversation thread during a live chat with our support team
17. Personal identifiers from your browsing
activity
Requests by
your web browser to our servers for web pages and other content on our website
are recorded.
We record
information such as your geographical location, your Internet service provider
and your IP address. We also record information about the software you are
using to browse our website, such as the type of computer or device and the
screen resolution.
We use this
information in aggregate to assess the popularity of the webpages on our
website and how we perform in providing content to you.
If combined
with other information we know about you from previous visits, the data
possibly could be used to identify you personally, even if you are not signed
into our website.
18. Our use of re-marketing
Re-marketing
involves placing a cookie on your computer when you browse our website in order
to be able to serve to you an advert for our products or services when you
visit some other website.
We may use
a third party to provide us with re-marketing services from time to time. If
so, then if you have consented to our use of cookies, you may see
advertisements for our products and services on other websites.
Disclosure
and sharing of your information
19. Information we obtain from third parties
Although we
do not disclose your personal information to any third party (except as set out
in this notice), we sometimes receive data that is indirectly made up from your
personal information from third parties whose services we use.
No such
information is personally identifiable to you.
20. Third party advertising on our website
Third
parties may advertise on our website. In doing so, those parties, their agents
or other companies working for them may use technology that automatically
collects information about you when their advertisement is displayed on our
website.
They may
also use other technology such as cookies or JavaScript to personalise the
content of, and to measure the performance of their adverts.
We do not
have control over these technologies or the data that these parties obtain.
Accordingly, this privacy notice does not cover the information practices of
these third parties.
21. Credit reference
To assist
in combating fraud, we share information with credit reference agencies, so far
as it relates to clients or customers who instruct their credit card issuer to
cancel payment to us without having first provided an acceptable reason to us
and given us the opportunity to refund their money.
Control
over your own information
22. Your duty to inform us of changes
It is
important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes.
23. Access to your personal information
At any time
you may review or update personally identifiable information that we hold about
you, by signing in to your account on our website.
To obtain a
copy of any information that is not provided on our website you should contact
us to make that request.
After
receiving the request, we will tell you when we expect to provide you with the
information, and whether we require any fee for providing it to you.
24. Removal of your information
If you wish
us to remove personally identifiable information from our website, you should
contact us to make your request.
This may
limit the service we can provide to you.
25. Verification of your information
When we
receive any request to access, edit or delete personal identifiable information
we shall first take reasonable steps to verify your identity before granting
you access or otherwise taking any action. This is important to safeguard your
information.
Other
matters
26. Use of site by children
We do not
sell products or provide services for purchase by children, nor do we market to
children.
If you are
under 18, you may use our website only with consent from a parent or guardian
Certain
areas of our website are designed for use by children over 15 years of age.
We collect
data about all users of and visitors to these areas regardless of age, and we
anticipate that some of those users and visitors will be children.
Such child
users and visitors will inevitably visit other parts of the site and will be
subject to whatever on-site marketing they find, wherever they visit.
27. Encryption of data sent between us
We use
Secure Sockets Layer (SSL) certificates to verify our identity to your browser
and to encrypt any data you give us.
Whenever
information is transferred between us, you can check that it is done so using
SSL by looking for a closed padlock symbol or other trust mark in your
browser’s URL bar or toolbar.
28. How you can complain
If you are
not happy with our privacy policy or if you have any complaint then you should
tell us.
If a
dispute is not settled then we hope you will agree to attempt to resolve it by
engaging in good faith with us in a process of mediation or arbitration.
If you are
in any way dissatisfied about how we process your personal information, you
have a right to lodge a complaint with the Information Commissioner’s Office
(ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would,
however, appreciate the opportunity to talk to you about your concern before
you approach the ICO.
29. Retention period for personal data
Except as
otherwise mentioned in this privacy notice, we keep your personal information
only for as long as required by us:
· to
provide you with the services you have requested;
· to comply
with other law, including for the period demanded by our tax authorities;
· to
support a claim or defence in court.
30. Compliance with the law
Our privacy
policy has been compiled so as to comply with the law of every country or legal
jurisdiction in which we aim to do business. If you think it fails to satisfy
the law of your jurisdiction, we should like to hear from you.
However,
ultimately it is your choice as to whether you wish to use our website.
31. Review of this privacy policy
We may
update this privacy notice from time to time as necessary. The terms that apply
to you are those posted here on our website on the day you use our website. We
advise you to print a copy for your records.
If you have
any question regarding our privacy policy, please contact us.