Privacy Policy

In this Privacy Notice:

Data Protection Legislation means (i) before 25 May 2018, the EU Data Protection Directive 95/46 and all national implementing laws (including the UK Data Protection Act 1998); and (ii) on or after 25 May 2018, the EU General Data Protection Regulation 2016/679 (“GDPR“); together with all other applicable and national implementing legislation relating to privacy or data protection; and where we use the terms “personal data“, “data subject“, “controller“, “processor” and “process” (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation.

Introduction

Coubari Limited is committed to keeping your personal data private. We shall process any personal data we collect from you in accordance with Data Protection Legislation and the provisions of this Privacy Notice. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Data Controller

For the purpose of the GDPR Coubari Limited is the data controller of your information. This means that we are responsible for deciding how we hold and use your personal data. We are required under Data Protection Legislation to notify you of the information contained in this Privacy Notice.

Collecting Information From You

Coubari Limited will collect and process your personal data you provide us through application forms, our website, face-to-face and electronic communication (including telephone conversations) in order to provide our services to you.

The Kind Of Information We Hold About You

We may collect, store, and use the following categories of personal data about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth
Gender
Employment status and salary
Marital status and dependants
Other information about an individual that you or they disclose to us when communicating with us

Please note, however, that in certain circumstances it may be still lawful for us to continue processing this information even where consent has been withdrawn, if one of the other legal bases described below is applicable.

Lawful Grounds For Using Your Information

We are permitted to process your personal data in compliance with Data Protection Legislation by relying on one or more of the following lawful grounds:

You have explicitly agreed to us processing such information for a specific reason.
The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you.
The processing is necessary for compliance with a legal obligation we have.
The processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
to provide services to you;
to ensure that our customer accounts are well-managed;
to protect our business interests;
to ensure that complaints are investigated;
to evaluate, develop or improve our services; or
to keep our customers informed about relevant services, unless you have indicated at any time that you do not wish us to do so.

Purposes Of Processing

We may use your information for the following purposes and under the following legal bases:

How we use your information	Legal basis
To provide and manage your account(s) and our relationship with you	Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this Where it’s in our legitimate interests to ensure that our customer accounts are well-managed, so that our customers are provided with a high standard of service, to protect our business interests and the interests of our customers
To handle enquiries and complaints	Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this Where it’s in our legitimate interests to ensure that complaints are investigated, for example, so that our customers receive a high standard of service and so that we can prevent complaints from occurring in future
To provide our services to you	Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this
To evaluate, develop and improve our services to you and other customers	Where it’s in our legitimate interests continually to evaluate, develop or improve our products as well as the experiences of users of our site, so that our customers are provided with a high standard of service
To protect our business interests and to develop our business strategies	Where it’s in our legitimate interests to protect our people, business and property and to develop our strategies Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this
To contact you, by post, phone, text, email and other digital methods. This may be: to help you manage your accounts to meet our regulatory obligations to keep you informed about products and services you hold with us and to send you information about products or services (including those of other companies) which may be of interest to you.	Where the law requires this Where we have agreed to contact you in our agreement Where the law requires this Where you agree Where it’s in our legitimate interests to share information with our customers about products / services that may be relevant and beneficial to them. Where we send you marketing messages, you can always tell us when you no longer wish to receive them. Please see more information in the Contact Us section
To monitor, record and analyse any communications between you and us, including phone calls	Where it’s in our legitimate interests, to check your instructions to us, to analyse, assess and improve our services to customers, and for training, for the enhancement of our customer service provision and protection of our business interests

Information Sharing

We keep all your personal data confidential. However, in order to be able to service your needs to the best of our ability, we may share any information you provide to us with our market research partners. If you have provided information to other members of our group, those entities may also share that information with us. We will ensure that if we share such information with third parties, any such disclosure is at all times in compliance with Data Protection Legislation.

Retention And Disposal Of Data And Output

We will only keep the information we collect about you on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required.

We will normally destroy or erase data after statutory timelines lapse. However, we may retain your information, or information relating to your account after you cease to be a customer for longer than this, provided it is necessary for a legal, regulatory, fraud prevention or other legitimate business purpose.

Storage Of You Personal Data And Data Security

All information you provide to us is stored in our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know basis. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Communication With You

We may communicate with you via electronic mail (e-mail). We will never ask you for your password.

Rights Over Your Personal Data

Under certain circumstances, by law you have the right to:

Be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed and storage periods).
Object to your personal data being processed for a particular purpose or to request that we stop using your information.
Withdraw, at any time, any consent that you have previously given to us for our use of your personal data.
Ask us to stop or start sending you marketing messages at any time.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.
Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where you think that we do not have the right to process it.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will provide this information free of charge unless the request is manifestly unfounded or excessive. We will comply with our legal obligations as regards any individual’s rights as a data subject.

If you would like to contact us in relation to any of the rights set out above please contact us using the following contact details. To protect your privacy and security, we may take reasonable steps to verify your identity before providing you with the details.

Coubari Limited, 35 Berkeley Square, Holborn, London W1J 5BF.

Right To Complain To The ICO

You can contact the ICO if you have any concerns about how Coubari Limited has handled your personal data and you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. You can contact the ICO via their helpline on 0303 123 1113. You can find out more information about your rights as a data subjects, their regulatory powers and actions they can take on their website https://ico.org.uk/

This Privacy Notice

The content or services mentioned on our website may be changed in future and consequently this Privacy Notice may also change. Any changes we may make to this Privacy Notice in the future will be posted on this page and where appropriate, notified to you by email. We recommend that you re-visit this page regularly and inform us if you do not agree to any term mentioned here.