Last updated 07/09/2018.
We are actively preparing for the General Data Protection Regulation (GDPR) that becomes enforceable on May 25th, 2018. We are working alongside our security and development teams, as well as third party providers, to strengthen our security policies and raise awareness about data protection and what is required of our employees to comply with GDPR rules.
The right to be informed and the right of access
Under the GDPR (which replaces the Data Protection Act on May 25th, 2018), you are entitled, if you so request, for a copy of all personal data and Information that Cotlook holds about you, what this is being used for and the recipients to whom this may be disclosed (as applicable). If you require any further information, please contact firstname.lastname@example.org.
The right to rectification
You are entitled to have your personal data rectified if it is inaccurate or incomplete. Contact email@example.com if you need to update your details.
The right to erasure, the right to object and the right to restrict processing
Restrictive processing of Information is built into Cotlook’s processes and procedures from first contact by you. The minimal Information that Cotlook does process about you, in order to provide the goods, services, subscriptions and / or merchandise that you have consented to receive from Cotlook, is processed and stored securely as per Cotlook’s internal policies. Where you have requested for your Information to be erased (or ‘forgotten’) by Cotlook, or you object, secure destruction policies are in place to erase your Information.
The right to data portability
Information can be made available to you, upon request, in a commonly used and machine-readable format, for example, a PDF or Word document.
Articles 12, 13 and 14 of the GDPR outline the requirements on giving privacy information to data subjects. This information is more detailed than in the Data Protection Act 1998.
This Agreement is also governed and construed in accordance with English law. You and Cotlook each submit to the non-exclusive jurisdiction of the English courts in relation to disputes arising out of this Agreement.
What data is being collected?
Information required (Subscribers)
When you either register as a ‘Trial’ User on the Subscriber section of the Website, or fully subscribe to this section as a User, we require certain contact details from you, including without limitation, registration details consisting of your name, postal address, email address and telephone number.
If you subscribe or purchase products, we may also ask for your credit card information, where you have stated that this is your preferred payment method, to enable us to process the payment of the appropriate fee invoice(s). This Agreement is in relation to these contact details, and to any other information, which we may subsequently collect from you as identified in this Agreement (“the Information”).
You will not be able to gain access to the Subscriber section of the Website without providing registration details, otherwise known as the ‘Information’. If you provide Cotlook with false Information, we reserve the right to terminate your access to the Website and suspend all services, with the exception of errors in the Information you have shared with Cotlook; such as spelling / typing errors. You are entitled to have your personal data rectified if it is inaccurate or incomplete. Contact firstname.lastname@example.org if you need to update your details.
Subscribers should also refer to our Terms and Conditions for Website Use by Subscribers before using the Website.
Live Chat is a third-party feature provided by Tawk.to designed to provide an enhanced and more immediate customer response experience to questions and queries relating to subscriptions and / or advertising information whilst browsing the Website.
Tawk.to is also used for tracking and website analytics purposes to enable Cotlook to review the performance of live chat and its effectiveness as a communication tool for Users.
Subscription, advertising and contact forms are available on the Website if you wish to contact us about specific subscription, advertising or general enquiries. The Information collected allows the relevant Cotlook department to contact you in response to your enquiry. The Information will only be stored internally for the purposes of fulfilling your enquiry request.
Minors (persons under the age of 18) are not eligible to use the services offered on the Website and we ask that minors do not submit any Information to Cotlook.
Use of Information
The Information may also be used by Cotlook, from time to time, to allow Cotlook to analyse Website usage, improve the content of the Website, customise the Website’s layout and services, and if you choose to post information on any part of the Website, or if you send Cotlook personal correspondence, such as emails or letters, or if other users, or third parties, send Cotlook correspondence about your activities or postings on the Website, we may collect such information in to a file specific to you, which may be used to monitor your use of the Website (collectively “Internal Uses”).
Information may be retained and used by Cotlook for telling you about Cotlook goods, services, or merchandising and/or any third-party goods, services or merchandising available for sale from Cotlook and for administering promotional campaigns, including selling or promotions to individuals by direct marketing methods (collectively “Marketing Uses”).
Information / personal data will be securely retained only for the purposes identified in this policy and for no longer than is required for these purposes. Information will not be retained following withdrawal of consent or exercising of your rights to restrict, rectify, erase, or object to the processing of your Information.
Transfer of Information
Cotlook also offers Users who have subscribed to the Subscription section of the Website the opportunity to subscribe to the live data feed service from ICE Futures US. If you choose to subscribe to this service, we will forward the Information to ICE Futures US. This is clearly outside the European Economic Area (“EEA”) and as such we will require your consent to transfer the Information in this manner. You will be asked to give your consent if and when you subscribe to this service.
Cotlook will not disclose the Information to any party, for any of those purposes outside of those contained herein, without your prior consent, unless Cotlook is required to reveal your identity and share Information about you by operation of law or regulation.
Cotlook reserves the right to report any activity on the Website, which we suspect violates any relevant laws or regulations, to the appropriate authority, if we are requested by such authority for the Information.
Google’s reCAPTCHA spam filtering service may share suspicious usage information with Google about user activity relating to specific forms on the Website.
Cotlook uses site tracking to monitor customer traffic patterns and site usage to help Cotlook develop the design and layout of the Website to better meet the needs of customers and visitors to the Websites.
Cookies are small files sent from a website which are then stored by your web browser. When you return to the website, the cookie information is used to recognise your last session. Cookies are simple text files, which are safe and secure and do not contain any personal, sensitive information. Cookies can’t install malicious software such as viruses on your device(s).
The cookies on the Website will contain some of the information you provide on the registration page and will also create an internal identification number. This identification number will identify each Website use and will enable Cotlook to personalise the content of the Website for each individual user.
You are always free to decline Cotlook’s cookies if your browser permits, although in doing this, you may not be able to use certain features on the Website.
Adobe® Flash® and Microsoft® Silverlight®: Some elements of this website may make use of Flash® or Silverlight®. Every effort has been made to ensure that these are compatible with all browser versions.
All Information will be kept as confidential and as secure as possible through the use of Cotlook’s secure server software and internal policies. This means that Information can only be exchanged between you, Cotlook, and any third party with whom we transfer the Information to for the purposes detailed above under Transfer of Information. Furthermore, as required by the GDPR, we follow strict security procedures in the processing, secure storage, secure destruction and disclosure of Information, as applicable, which has been provided by you to Cotlook to prevent unauthorised access.
Cotlook uses industry standard practices and robust internal policies to safeguard the confidentiality of the Information held by Cotlook. We treat the Information as an asset that must be protected against loss and unauthorised access. Cotlook employees use many different security techniques to protect the Information from unauthorised access by users inside and outside the company. However, “perfect security” does not exist on the Internet.
Control of your Password (for Subscribers)
Once log-in credentials have been issued by Cotlook to you (the Subscriber), you remain responsible for the proper use and privacy of your User ID and password. Passwords must not be shared and are issued per user. Passwords can be securely reset, when forgotten, directly by the Subscriber, through the appropriate encryption process associated with the ‘Forgot Password’ link on the sign-in page. We strongly advise against disclosing your Cotlook password to any third parties. If your password has been compromised for any reason, you should immediately contact Cotlook by email email@example.com to change your password.
Cotlook will not share your Information with any third parties unless otherwise stated in this policy.
Consent is required for Cotlook to process both types of personal data, but it must be explicitly given. When we are asking you for sensitive personal data, we will always tell you why and how the Information will be used.
Opting Out / Withdrawing Consent
We won’t contact you for marketing or promotional services unless you have provided consent to receive such Information from Cotlook.
You can opt-out from Cotlook Mailing Lists and / or withdraw consent at any time by emailing firstname.lastname@example.org.
There is also an ‘Opt Out’ link in the Mailing List form on the right-hand side of our home page.
You can also click ‘Unsubscribe’ at the bottom of every email we send you.
Data Breach Reporting Procedure
Within 72 hours of discovering a data breach, Cotlook will carry out a thorough investigation, inform regulators and impacted individuals of the breach, identify what personal data has been impacted and how, and complete the relevant documentation.
Raising a Concern
If at any time you have any questions or concerns about your Information, or you would like to contact Cotlook for any other reason, you can contact:
Sarah Olsen (Office Manager) email@example.com