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PRIVACY AND COOKIE POLICY
This privacy policy sets out how Coote O’Grady (trading as COG Legal) Limited uses and protects your personal data.
1. Important information and who we are
This privacy policy gives you information about how Coote O’Grady Limited (trading as COG Legal) collects and uses your personal data through your use of this website, including any data you may provide when you register with us or sign up to our newsletter or use our products or services.
This website is not intended for children, and we do not knowingly collect data relating to children.
Coote O’Grady Limited is the controller and responsible for your personal data (collectively referred to as “COG Legal”, “COG”, "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9) please contact us using the information set out in the contact details section (paragraph 10).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
· Contact Data includes billing address, delivery address, email address and telephone numbers.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
· Profile Data includes your username and password, orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you interact with and use our website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Your interactions with us. You may give us your personal data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: use our products or services; request marketing to be sent to you; or give us feedback or contact us.
· Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
· Third parties or publicly available sources. We may receive personal data about you from various third parties such as Technical Data from analytics providers or search information providers and Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
4. How we use your personal data Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do 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).
· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
We have set out below, in list format, a description of all the ways we plan to use the various categories of 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.
Purpose/Use
To provide our products and services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
Type of data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
(f) Profile
(g) Usage
(h) Marketing and Communications
Legal basis
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
Purpose/Use
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Dealing with your requests, complaints and queries
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Legal basis
(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 and manage our relationship with you)
Purpose/Use
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Legal basis
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
(b) Necessary to comply with a legal obligation
Purpose/Use
To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Legal basis
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Use
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing
Type of data
(a) Technical
(b) Usage
Legal basis
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Use
To send you relevant marketing communications and make personalised suggestions and recommendations to you about products or services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Legal basis
(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business)
(b) Consent, having obtained your prior consent to receiving direct marketing communications
Purpose/Use
To carry out market research through your voluntary participation in surveys
Type of data
(a) Identity
(b) Contact
Legal basis
Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).
Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
We may also have obtained your contact details from Cognism Data, a Specialist marketing data provider. We use this information to send you marketing communications about our products and services that we believe will be of interest to you, based on the profiles provided by Cognism.
We process this data based on our legitimate interest in growing our business and promoting our services to new customers.
Your Rights: You have the right to object to this processing at any time. If you do not wish to receive further marketing, please click the 'unsubscribe' link in our emails, reply 'STOP', or email us at info@coglegal.com. We will promptly remove your details from our marketing list.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the information set out in the contact details section (paragraph 10).
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.
5. Disclosures of your personal data
We may share your personal data where necessary with third parties for the purposes set out in the table above. 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.
6. International transfers
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
· We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
· We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
7. Data security
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. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
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. 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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. Your legal rights
You have a number of rights under data protection laws in relation to your personal data. You have the right to:
· Request access to your personal data (commonly known as a "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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
· Opt out at any time to the processing of your personal data for direct marketing purposes.
· Request the transfer of your personal data to you or to a third party. 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.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, 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.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios: if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using the information set out in the contact details section (paragraph 10).
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.
10. Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
· Email address: info@coglegal.com
· Postal address: 14 Station Road, East Boldon, Tyne and Wear NE36 0LD
11. Complaints
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.
12. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. 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 relationship with us, for example a new address or email address.
13. 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.
COOKIE POLICY
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We may use the following cookies:
Strictly necessary cookies.These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They may include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies.These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies.These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
You can find more information about the individual cookies we use and the purposes for which we use them in the list below:
COOKIES - GOOGLE ANALYTICS
Purpose
These cookies help us understand how visitors interact with our site. Typical cookies include:
You can opt out of Google Analytics by installing the browser add-on:
https://tools.google.com/dlpage/gaoptout
More information
https://policies.google.com/technologies/cookies
COOKIES - HUBSPOT
Purpose
These cookies allow us to track website visits, form submissions, and email interactions for analytics and marketing. Typical cookies include:
More information
https://legal.hubspot.com/privacy-policy
Choices about cookies
When you first visit our website, you’ll see a cookie consent banner allowing you to accept or reject cookies. You can also control or delete cookies through your browser settings.
Here’s how to manage cookies in major browsers:
If you disable cookies, some parts of our website may not function properly.
If you have any questions or concerns about our use of cookies, please send us an email at info@coglegal.com.
Copyright © 2022 COG Legal - All Rights Reserved.
Coote O’Grady™ Limited, trading as COG Legal is a limited company registered in England and Wales.
Registered number: 10169973. Registered office: 14 Station Road, East Boldon, NE36 0LD
Winner European Women of Legal Tech 2020 – Caroline O’Grady
Runner-up in Legal Procurement Awards 2019 – Process Improvement Award
Winner of World Procurement Awards 2018 - Best New Consultancy Project
Winner Best Independent Financial Management Services 2021 - North East - SME News Legal Awards 2021!
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