Our aims
We, at Couno, understand that your privacy is important to you and that you care about how your information is used and shared. We respect and value the privacy of everyone who uses our services and will only collect and use information in ways that are useful and consistent with your rights and our obligations under the law.
Our Privacy Notice aims to provide you with key information about:
- What data we collect from you and why
- How we use or process that data
- How you can access and take ownership of your data
- How and where you can make a complaint if you’re unhappy
Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of our Privacy Notice is deemed to occur upon your first use of our Site. You will be required to read and accept this Privacy Notice when signing up for any of Couno’s services. We reserve the right to update or amend this notice when it is required.
If you do not accept and agree with this Privacy Notice, you must stop using our Site immediately.
Who are we?
Couno is a limited company registered in England under 07340631. Our registered address is Admirals Offices Main Gate Road, The Historic Dockyard, Chatham, Kent, England, ME4 4TZ
Our Data Protection Officer is responsible for handling our compliance with data protection law and for effectively handling all queries from data subjects about their personal data.
For all data related matters, including subject access requests, please contact:
Win Giles
Smarter Data Protection Ltd
Construction House
Comet Way
Southend
Essex, SS2 6GD
Tel: 01702 596002
Email: win@smarterdataprotection.com
What data do we collect?
To make our practices as clear as possible, we’ve provided a breakdown of the data we collect from you. As we develop and add new products or services that require us to collect or handle data differently, we’ll update this section of our Privacy Notice to reflect those changes.
We will never collect or process special category data, or data relating to criminal convictions or offences, from you. Our website is not intended for children and we do not knowingly collect data relating to children.
The personal data we would like to collect from you is as follows:
| When you |
You provide |
Via |
Lawful basis for collection |
Contact us by
phone, email or
via our website |
First name, Surname, Job, title/function, Telephone number,
Email address |
Telephone, Email, Website |
In performance of a contract |
| Access our IT support services |
First name, Surname, Job, title/function, Telephone number,
Email address |
Telephone, Email, Website |
In performance of a contract |
| Provide services to us or to become a supplier |
Name, Contact details, Bank details, Identification documentation |
Telephone, Email, Website |
In performance of a contract |
| Promote our products and services |
First name, Surname, Telephone number, Email, addressPostal, address |
Telephone, Email, Website |
With consent |
| Unsubscribe (non-contact list) |
First name, Surname |
Telephone, Email, Website |
Legal obligation |
If you choose not to provide your data, then we may not be able to offer key services to you.
Collecting data from third parties
From time to time we compliantly purchase data for marketing purposes from Experian Ltd.
If we obtained your contact details this way you should have received a Privacy Notice from us. You can view that Privacy Notice here
What happens to your data?
General correspondence
- We will use this data to respond to your enquiry in a satisfactory way.
- Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with internal policy and procedure. Email monitoring or blocking software may also be used.
- Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
- This information will be stored in emails, our and in our Contacts Database if you use our Contact Us form on our website.
IT Support Service
- This information will be used by our team to provide IT support services.
- In the course of providing these services, we may encounter wider information relating to employees, suppliers and customers.
- All information will be managed according to any Data Protection Agreement (DPA) and Non-Disclosure Agreement (NDA) that is in place.
- Information will also be used to process payments and to comply with accounting and taxation purposes.
Supplier/Service Provision
- In the course of providing these services to us, you may encounter wider information relating to our employees and customers.
- All information will be managed according to any Data Protection Agreement (DPA) and Non-Disclosure Agreement (NDA) that is in place.
- Information will also be used to process payments and to comply with accounting and taxation purposes.
Promotion and Marketing
- With your consent we may send you marketing materials promoting our products and services by email, telephone and/or post.
- Your personal information will be stored in email and our secure third party email marketing platform.
What is our lawful basis for processing your data?
We collect and process your data using the following lawful bases:
- In the performance of a contract
This means we process your data where it is necessary for the performance of a contract we’ve entered with you, or with the intent to enter into a contract with you
- With legitimate interests
This means we process your data in the legitimate the interest of our business in order to provide you with the best service/product and the most secure experience. We always consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.
We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting our Data Protection Officer.
In any instance where we’re processing your data based on legitimate interests, you still have the right to object to your data being processed in that manner. To do this please contact our Data Protection Officer.
- To comply with a legal or regulatory obligation
This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation.
This means we’ve asked for your explicit consent to process your data in a certain way, and you’ve provided it. You have the right to withdraw your consent at any time.
- To protect the vital interests of a data subject
This is in the rare situation where vital interests of yourself or another person needs protecting.
Who do we share your data with?
We employ the services of a small group of trusted data processors to enable the smooth running of our business and only process your data in line with our explicit instructions.
- Couno will never share or sell your data to any other company for commercial gain. We only ever “share” or transfer your data as part of our own, core processing activities. So, for example, by using a card payment processing provider to take payment for goods or 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.
Cookies
For more information on how we use cookies and how they affect your browsing experience, please see our Cookies Policy.
How do we keep your data secure?
Your privacy is important to us, so we take all reasonable and proportionate steps to protect your personal information by:
- Putting appropriate security measures in place, to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way.
- Limiting access to your personal data on a ‘need to know’ only basis.
- Ensuring our staff are trusted and trained in data protection compliance and confidentiality.
- Following due process to deal with any suspected personal data breach.
- Only retaining your personal information for as long as necessary to fulfil the purpose we collected it for.
International Transfers
Transfer of personal data to countries or organisations outside of the EEA should only take place if appropriate measures are in place to protect the security of that data.
Sometimes your data is transferred to countries outside of the European Economic Area (EEA), when this occurs, we ensure that the third-party provider participates in and has certified its compliance with the EU-US Privacy Shield Framework.
How long do we keep it?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for satisfying any legal, accounting or reporting requirements. If you would like more specific information on our data retention periods, please contact our Data Protection Officer.
Your rights
We fully support your rights and we will always seek to uphold them. However, if you ever feel this is not the case please contact our Data Protection Officer, to discuss the matter further.
At any point you can exercise your:
- Right of access – contact us for a copy of the data we hold about you.
- Right of rectification – let us know if the data we hold is out of date or inaccurate and we’ll update it.
- Right to be forgotten – if you no longer want to use our services, please contact us and we’ll delete all related data.
- Right to restrict processing – we only ever collect data we need and actively ensure we’re never collecting anything over and above need. You can opt in and out of our services by contacting us.
- Right of portability – we will support reasonable requests to transfer your data to another organisation should you require it.
- Right to object to automated decision making and profiling- we do not currently use any automated profiling of any description.
In the event you are unhappy with the way we’re processing your data please contact our remote DPO.
In the event we refuse to your rights in any way we will provide you with a reason why. You will then have the right to complain to the supervisory authority as outlined below.
Contact us
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance, contact us:
Data Protection Officer,
Win Giles
Smarter Data Protection Ltd
Construction House
Comet Way
Southend
Essex, SS2 6GD
Tel: 01702 596002
Email: win@smarterdataprotection.com
If this does not resolve your compliant to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the United Kingdom’s Supervisory Authority.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113
Email: https://ico.org.uk/global/contact-us/email/
