The purpose of this policy is to explain to you how we control, process, handle and protect your personal information while browsing or using this website, including your rights under current laws and regulations. If you do not agree to the following policy, you may wish to cease viewing / using this website.
Koa (East Midlands) Ltd will be what’s known as the “Controller” of the personal data you provide to us. We only collect basic personal data about you which does not include any special categories of personal information about you (known as Special Category Data). This does however include name, address, e-mail, telephone number.
Processing of your personal data
We are based in the UK. Some organisations which provide services to us may transfer personal data outside of the EU, but we will only allow them to do if your data is adequately protected.
Microsoft, Mailchimp and Hubspot are US company’s, it may be that using their products result in personal data being transferred to or accessible from the US. However, we will allow this as we are certain personal data will still be adequately protected (as Microsoft, Mailchimp and Hubspot are certified under the USA’s Privacy Shield scheme).
Under the General Data Protection Regulation (GDPR), we control and process personal information about you electronically using the following lawful bases.
Lawful basis: Consent
1. The reason we use this basis: when you sign up to receive our email newsletter we will ask for your explicit consent to collect and store your personal data. You may withdraw your consent at any time.
2. Data retention period: we will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists. If we have had no meaningful contact with you for a period of 2 years, we will automatically remove you from our marketing database. We will ask you before we do this.
3. Sharing your information: We do share your personal information with third parties and they include: –
Lawful basis: Contract
1. The reason we use this basis: when you buy from Koa (East Midlands) Ltd, you are entering into a contract with Koa (East Midlands) Ltd, allowing us to supply you with products or services.
2. Data retention period: we shall continue to process your information until the contract between us ends or is terminated under any contract terms.
Lawful basis: Legitimate interests
1. The reason we use this basis: it is in our business interest that we monitor the performance of our products, services and website performance.
2. Data retention period: if you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue. For users who register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
3. Sharing your information: we do share your personal information with third parties and they include: –
4. If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your individual rights
1. Under the GDPR, your rights are as follows: –
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
2. You also have the right to complain to the ICO if you feel there is a problem with the way we are handling your data.
3. We handle Subject Access Requests (SAR) in accordance with the GDPR.
Cookies that we use are: –
- Necessary cookies. These are cookies that are required for the operation of the Koaconsulting.co.uk website. They include, for example, cookies that enable you to log into secure areas of the website or use the multipage contact forms.
- Statistics cookies. These cookies help us recognise and count the number of visitors and to analyse how visitors move around the website when they are using it. This helps us improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
Third party cookies
Please note that third parties (e.g. Google Analytics) also set cookies, over which we have limited control. These cookies are only used for analytical purposes, to help us understand how visitors interact with websites by collecting and reporting information anonymously. No personally identifiable data is sent to third parties via cookies.
The following third parties set cookies on the Koa (East Midlands) Ltd website: –
- Google Analytics – This is a product that tracks user behaviour across the website. Google Analytics set some cookies to allow them to follow user paths and identify unique users. We have set up our Google Analytics code so that it does not set or store a UserID, and so that it anonymizes IP addresses. As such, no personally identifiable information is stored.
- Facebook – This enables us to measure, optimise and build audiences for advertising campaigns served on Facebook. In particular it enables us to analyse how our users move between devices when accessing our web site and Facebook, to ensure that Koa (East Midlands) Ltd’s Facebook advertising is seen by our users most likely to be interested in such advertising.
- LinkedIn – This enables us to measure, optimise and build audiences for advertising campaigns served on LinkedIn. In particular it enables us to analyse how our users move between devices when accessing our web site and LinkedIn, to ensure that Koa (East Midlands) Ltd’s LinkedIn advertising is seen by our users most likely to be interested in such advertising.
- YouTube – To track visitor views, and to remember user preferences when viewing YouTube videos embedded in our website web pages.
Further information about cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the koaconsulting.co.uk website. If you would like more information from an independent resource on a range of cookie-related issues, including how to change your browser settings, please visit All About Cookies.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an Email Marketing Service (EMS) provider. An EMS is a third-party service provider of software /applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations, will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise, contact the EMS provider.
Our EMS provider is MailChimp. We hold the following information about you within our EMS system: –
- First name
- Email address
- P address
- Subscription time & date
Data security and protection
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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