PRIVACY POLICY

1. Purpose and scope of the Privacy Policy (Introduction)

We, Coco and Kandy Ltd. (“Coco and Kandy”, “we”, “us” or “our”), UIC 205757034, with seat and address of management in Varna 9000, 11 Yosif Stoyanov St., are the owners of the www.cocoandkandy.com website (the “Website”). In operating the Website we process your personal data in our capacity as personal data controller, as defined in the General Data Protection Regulation (EU) 2016/679 (the “GDPR”). We are committed to protecting your privacy in accordance with applicable data protection laws. When we write “you”, we mean you as our customer, website visitor or other relevant third party such as the contact persons of a company or other organisation we are doing business with and the like. The purpose of this Privacy Policy is to explain how we collect and use your personal data as well as how you can exercise your rights.

Any information you as user of the Website provide is received, stored and managed by us in line with this Privacy Policy.

We may update this Privacy Policy from time to time without prior notice to you. If we make changes, we will notify you by revising the date at the top of the policy in cases where the changes are not substantial or by providing more prominent notice for substantial changes, as appropriate.

By accessing, browsing or otherwise using the Website you confirm that you have read and understood this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must not use the Website.

2. How we collect information?

We may collect personal data from you when you make a purchase on our Website, correspond with us by post, email or telephone, create an account on our Website, request information or assistance from us, subscribe for a newsletter or other marketing communication from us, or otherwise use the Website. We may also automatically collect technical and usage data about your equipment, browsing actions and patterns when you interact with our Website. We collect this personal data by using cookies, server logs and other similar technologies.

If you do not provide certain information when requested, we may not be able to fulfil our obligations to you or respond to your requests, thereby preventing us from providing you with the highest level of service possible. We may also be prevented from complying with our legal obligations (such as our accounting and tax requirements). In cases where we collect your consent, the processing of your personal data will be completely voluntary and your refusal to consent would not lead to any adverse consequences.

3. What information do we collect?

The information we collect may include:

General information and contact details, such as name, phone number, WhatsApp, email address, address and other contact; billing and shipping address, account name, and account password.

Commercial Information, such as details on the items added to the shopping cart/purchased/returned, order history.

Payment information or billing information in connection with your use or purchase of our goods and services, bank details for debit and credit cards and PayPal (credit and debit card numbers from online transactions are not saved and stored).

Photographic images from model photo shoots.

Information Automatically Collected

We automatically collect certain information from you when you access the Website, including the following:

Identifiers, such as IP address and identifiers associated with browser cookies, web beacons, and similar tracking technologies.

Internet or Other Electronic Network Activity Information, such as information about your browser type, operating system, pages accessed on our Website, links clicked, and time spent on the Website.

Geolocation Data, such as your IP address that can reveal your general location.

We use this information to tailor the content of our website and to enhance your shopping and customer service experience.

4. How do we use your personal data and on what legal basis?

We may use information about you for various business and commercial purposes, including to:

• Furnish the products and services you request, process your transactions and send you related information, such as order and shipping confirmations and invoices – necessary to enter into and perform our contract with you;
• Provide customer support and respond to your comments, questions and requests – necessary to enter into and perform our contract with you and also for our mutual legitimate interest to provide you with the requested assistance;
• Notify you of products, services, offers, promotions, events and features that may be of interest to you (marketing purposes) – on the basis of your express consent.
• Manage your online account(s) and provide required updates, security alerts and administrative messages – necessary for the performance of our contractual obligations under the Website Terms and Conditions;
• Detect and prevent fraud and ensure the security of the Website and our operations – necessary for the purposes of our legitimate interest to protect our business;
• Comply with our legal obligations – e.g. for accounting and tax purposes;
• Your personal data collected for the above purposes may be also processed for our protection against any legal claims by you or by third parties, as well as to establish and exercise our legitimate rights – necessary in view of the principles laid down in the applicable legislation on the right of defense against legal claims and of the protection of legitimate rights and interests, as well as our related legitimate interest to exercise the rights related to any legal claims, as provided for in the applicable legislation;
• We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for such further purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. To whom do we disclose your personal data?

Coco and Kandy will never share, sell or rent your information to third parties for their direct marketing purposes.

We may disclose information collected from and about you as follows (subject to applicable laws):

• With vendors, consultants and other service providers who use the information on our behalf solely to carry out our instructions and for no other purpose (e.g. website developer and support company – SGD, accounting firm, DHL, UPS – delivery, marketing agent who helps with Facebook and Google ads that do not send or use our customers’ data). These providers will act only on our instructions, will be subject to prior verification and will assume contractual obligations containing strict clauses regarding the protection of personal data. We strive to ensure that these third parties use personal data only for lawful purposes in accordance with this Privacy Policy;
• To comply with a request for information by law enforcement, or to the extent required by applicable law, regulation or legal process; (to the extent that we are required to do so by law) in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights;
• If we believe there has been a violation of the Website Terms and Conditions, any user agreements or policies, or to protect the rights, property and safety of Coco and Kandy or a third party;
• In connection with any proposed or actual merger, financing or sale or transfer of all or a portion of our assets or business to another entity;
• With our affiliates, licensees and joint venture partners for the purposes described in and consistent with this Privacy Policy;
• With your consent or at your direction.

Except as provided in this Privacy Policy, we will not provide your personal data to third parties.

6. Where do we store and transfer your personal data?

Personal data that we collect may be stored and processed in and transferred between any of the countries in which we operate, in order to enable us to use your personal data in accordance with this Privacy Policy.

Your personal data may be stored and transferred to countries which might not necessarily have data protection laws equivalent to those in force in the European Economic Area.

However, we will take all reasonable technical, organisational and legal measures to ensure that your personal data is securely processed, providing an adequate level of protection compared to the level of protection offered within the European Economic Area.

7. How do we protect your personal data?

Security is extremely important to us. We maintain appropriate technical and organisational measures to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide.

8. How long do we keep your personal data?

We will only save your personal data as long as necessary in order for us to achieve the purpose it was collected for or as required in order to comply with any mandatory retention periods under applicable law.

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 requirements.

9. Your rights

Under the GDPR you have the following rights:

• Right of access

You are entitled to obtain confirmation from us if your personal data is processed and, if so, to obtain a copy of your personal data being processed by us, as well as information on the processing. Please note that your right of access is not absolute, insofar as restricted by the rights and freedoms of others. For additional copies requested by you, we may impose a reasonable fee with respect to our administrative costs.

• Right to rectification

You are entitled to request from us to rectify your personal data that are inaccurate, and the completion of your personal data that are incomplete.

• Right to erasure

In some cases, you may be entitled to ask us to erase your personal data. This will include, for example, such cases where the personal data are no longer required for the purposes for which they were collected; if personal data have been processed unlawfully; if you exercise your right to object; etc.

• Right to restriction of processing

In some cases, you may be entitled to ask us to restrict the processing of your personal data, for example, if you want to determine the accuracy or the reason for their processing. The restricted processing usually comes down to simply storing your personal data, and any other processing is suspended.

• Right to data portability

In cases where the processing of your personal data is based on your consent or on a contractual necessity and to the extent that your personal data are processed automatically, you are entitled to obtain all such personal data that you have provided to us, in a structured, commonly used and machine readable format, and at your request we will submit these data to third parties where this is technically feasible.

• Right to file a complaint

If you find that in the processing of your personal data we have violated the applicable legislation on the protection of personal data, you are entitled to file a complaint with a competent supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. For the Republic of Bulgaria, the competent supervisory authority is the Commission on Personal Data Protection. You may find the details of the competent EU authorities by following this link.

• Right to withdraw your consent

If we process any of your personal data based on your consent, you may recall your consent at any time.

• Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our legitimate interests as explained above. We will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Where your personal data are processed for direct marketing purposes, you have the right to object at any time. In case of such objection, we will no longer process your personal data for marketing purposes. In practice, you will usually expressly agree in advance to our use of your personal data for marketing purposes, and we will provide you with an opportunity to opt-out of the use of your personal data for marketing purposes. You can also manage your subscriptions by logging into your user account on our website, instruct us not to use your personal data for marketing purposes by email at any time or by following an “unsubscribe” link in our marketing messages.

10. Exercise of your rights

To exercise your rights related to our processing of your personal data, please contact us using any of the options specified below (under section “Contact us“). We will respond to your comments, questions and requests within one month of receiving them. If necessary, this period may be extended by another two months, taking into account the complexity and the number of requests, and you will be informed accordingly within the initial period of one month.

Please note that in some cases your rights are limited – for example, if we prove that we have a legal basis to process your personal data, such rights may be unenforceable.

We may need to require additional information from you in connection with your request, so that we can verify your identity and that you have the corresponding right. This is an additional security measure to ensure that your personal data will not be disclosed to any third parties who are not entitled to receive them, as well as to be able to process your request.

We will perform the actions related to the satisfaction of your rights above free of charge, except if your demands are clearly unfounded or excessive, in particular due to their repeatability – in such cases we may impose a reasonable charge, with a view to our administrative costs, or may refuse to take action on your request.

11. Policy Amendments

We keep this Privacy Policy under review and we may update it from time to time by posting a new version on our Website. You should check this page occasionally to ensure you are happy with any changes. In case of significant amendments to this Privacy Policy, we will notify you by e-mail.

12. Cookie Policy

This Policy sets out the basis on which we use cookies and other web technologies such as pixel tags, web beacons, etc. (hereinafter also referred to as “cookies”) in relation to your visits to our Website. Please read the following carefully to understand our views and practices regarding the usage of cookies.

• Loggings:

In the server log files, Coco and Kandy Ltd. automatically retrieves and stores some of the data which the browser customarily transfers if your browser prepares such. This data cannot be attributed to certain persons by us nor will it be combined with the data from other sources.

• Cookies

A cookie is a small text file that is saved on your computer or mobile device when you visit our Website. We use cookies on our Website for a variety of reasons which you can learn about below.

Cookies can be session cookies or persistent cookies. Session cookies are temporary files that remain on your computer or mobile device until the end of the user session or the closing of the Website. Persistent cookies remain on your computer or mobile device for a period of time determined by the cookie’s parameters or until you manually delete them.

• By using cookies, we obtain information to help us improve our Website and to deliver a better and more personalised service. They enable us:

(a) to estimate our audience size and usage pattern;

(b) to store information about your preferences, and so allow us to customise our Website according to your individual interests;

(c) to speed up your searches;

(d) to recognise you when you return to our Website.

(e) for targeting adverting purposes. We use these cookies to serve you with advertisements that may be relevant to your interests. The information may also be used for frequency capping purposes (e.g. to ensure that we do not display the same advertisement to you repeatedly) and to help us regulate the advertisements you receive and measure their effectiveness.

• We share information about your use of our Website with our analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of other services.
• More information on the name of cookies, their description and default expiration period is available in the table below.

For further information on cookies and how they work, please visit www.allaboutcookies.org.

• Consent and control of the use of cookies

Before cookies are placed on your computer or mobile device, you will be shown a notice requesting your consent to set the cookies mentioned above on your computer or device. By consenting to the placing of cookies, you are enabling us to provide you with a full experience and functionality of our Website.

In addition to the option described above, you may choose to enable or disable cookies in your internet browser. Most internet browsers also allow you to choose whether you wish to disable all cookies or only third party cookies. By default internet browsers accept cookies, but you can change this by activating the setting on your browser, which allows you to refuse the setting of cookies. If you select this setting, you may be unable to access certain parts and functions of our Website.

13. Contact

Questions, comments and requests regarding this Cookies Policy are welcomed and should be addressed to:

info@cocoandkandy.com

or write to us on

11 Yosif Stoyanov str. 4/3

Varna

Bulgaria

14. Changes to our Cookies Policy

We may amend this Cookies Policy from time to time. Any changes we may make to our Cookies Policy in the future will be posted on our Website. You are invited to check this page from time to time.