Privacy Policy

Privacy policy

Introduction

1.1  We are committed to safeguarding the privacy of our website visitors and service users.

1.2  This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3  We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.5  In this policy, “we”, “us” and “our” refer to Kokoro Consultancy. For more information about us, see Section 13.

  1. Credit

2.1  This document was created using a template from SEQ Legal (https://seqlegal.com).

  1. How we use your personal data

3.1  In this Section 3 we have set out:

(a)   the general categories of personal data that we may process;

(b)   in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)   the purposes for which we may process personal data; and

(d)   the legal bases of the processing.

3.2  We may process [data about your use of our website and services] (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

3.3  We may process “account data“. The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR [specify basis].

3.4  We may process [your information included in your personal profile on our website] (“profile data“).[ The profile data may include [your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details].] The profile data may be processed for [the purposes of enabling and monitoring your use of our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract] OR [[specify basis]].

3.5  We may process [your personal data that are provided in the course of the use of our services] (“service data“).[ The service data may include [specify data].][ The source of the service data is [you or your employer].] The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.6  We may process [information that you post for publication on our website or through our services] (“publication data“). The publication data may be processed [for the purposes of enabling such publication and administering our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.7  We may process [information contained in any enquiry you submit to us regarding goods and/or services] (“enquiry data“). The enquiry data may be processed [for the purposes of offering, marketing and selling relevant goods and/or services to you]. The legal basis for this processing is [consent] OR [[specify basis]].

3.8  We may process [information relating to our customer relationships, including customer contact information] (“customer relationship data“).[ The customer relationship data may include [your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer].][ The source of the customer relationship data is [you or your employer].] The customer relationship data may be processed [for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper management of our customer relationships]] OR [[specify basis]].

3.9  We may process [information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website] (“transaction data“).[ The transaction data may include [your contact details, your card details and the transaction details].] The transaction data may be processed [for the purpose of supplying the purchased goods and services and keeping proper records of those transactions]. The legal basis for this processing is [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely [the proper administration of our website and business]] OR [[specify basis]].

3.10  We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] (“notification data“). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is [consent] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.11  We may process [information contained in or relating to any communication that you send to us] (“correspondence data“). The correspondence data may include [the communication content and metadata associated with the communication].[ Our website will generate the metadata associated with communications made using the website contact forms.] The correspondence data may be processed [for the purposes of communicating with you and record-keeping]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website and business and communications with users]] OR [[specify basis]].

3.16  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

4.1 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.[ We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.]

  1. Retaining and deleting personal data

6.1  This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2  Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3  Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

7.1  We may update this policy from time to time by publishing a new version on our website.

7.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

  1. Your rights

8.1  In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2  Your principal rights under data protection law are:

(a)   the right to access;

(b)   the right to rectification;

(c)   the right to erasure;

(d)   the right to restrict processing;

(e)   the right to object to processing;

(f)   the right to data portability;

(g)   the right to complain to a supervisory authority; and

(h)   the right to withdraw consent.

  1. About cookies

9.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

 

  1. Cookies used by our service providers

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

  1. Our details

13.1  This website is owned and operated by Kokoro Consultancy Ltd

13.2  We are registered in England and Wales under registration number 11326872, and our registered office is at 2b Haddo Street, Greenwich, London, England, SE10 9RN

13.3 Our website address is: https://kokoroconsultancy.co.uk.

13.4  You can contact us:

(a)   by post, to [the postal address given above;

(b)   using our website contact for;

(d)   by email, using the email address published on our website from time to time.

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