Data and Privacy Policy.
A. Introduction
1. CocoRio is committed to adhering to data protection laws and protecting Your privacy.
2. The purpose of of CocoRio’s data policy (“Data Policy”) is to set out how We collect personal data from ‘You’ (i.e. both Customers and Creatives), what personal data We collect from You, the basis on which We process such personal data, the uses which We may apply to such personal data and a summary of legal rights which You have under UK data protection laws.
3. This Data Policy applies to all personal data which You provide to Us under any means. For example You might provide Us with personal data through use of the CocoRio Website (including, to avoid doubt, Your use of the CocoRio Booking platform).
4. Please note that the account which you may hold with under the CocoRio Website is not intended for use by children. Please prevent children from using either the App orthis account.
Glossary
In this Data Policy, the following capitalised terms shall have the following meanings:
Booking Platform
means the booking platform which is available on the Website and through which you can procure our services;
CocoRio
this is the company who We are, being a company registered in England and Wales under company number 10641258;
Creatives
means the person who provides childcare services to You as a result of You making a booking for childcare services with Us;
Customers
any CocoRio customer (including You);
Data Controller
has the meaning given to that term in the GDPR;
Data Subject
has the meaning given to that term in the GDPR;
GDPR
means GDPR, including as it (subject to applicable amendments) forms part of domestic Law of all or any part of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2019, together with the Data Protection Act 2018, in each case as the same may be replaced, supplemented, substituted or amended from time to time;
Services
means any services which We provide to You;
We or Us
means Cocorio;
Website
a. https://cocorio.co.uk/; and
b. the Booking Platform
Your Account
means the account which You hold with Us on the Website.
Your Personal Data
has the meaning given to this term in Clause 5 (below); and
You or Your
Customer or Creative (as the context applies).
C. Your Personal Data
5. Please note that You may choose to provide us with personal data relating to one or more of the following individuals:
a. You;
b. Your spouse or partner; and
c. one or more of Your children;
For the purposes of this Data Policy document, any personal data relating to any of the above individuals is referred to (collectively) as “Your Personal Data”.
D. Your obligations (please!)
6. We ask that You please let Us know as soon as possible when there are any changes to any of Your Personal Data – by updating Your profile in the account You hold with Us.
7. If You provide Us with any personal data relating to any other adult then We politely remind You that You must get that person’s consent to both the disclosure and to the processing of that personal data in accordance with the terms of this Data Policy.
E. Legal basis for handling Your Personal Data
8. GDPR sets out a number of different reasons for which an organisation may collect and process Your Personal Data. Depending on the circumstances We may collect Your Personal Data for one or more of the following reasons:
Consent
9. In specific situations, We can collect and process Your Personal Data with Your consent.
10. For example, We rely on consent when you click ‘accept’ in relation to this Data Policy as part of the Customer on-boarding process.
11. We may also email You certain marketing materials after You have registered an account with Us and You have accepted such mailing distribution.
Contractual obligations
12. In certain circumstances, We need Your personal data to comply with our contractual obligations.
13. For example, if You book our Services on our the Website then We will process Your address details and details relating to Your finances (for example, Your card details) in order to deliver the Services
Legal compliance
14. If the law requires Us to, We may need to collect and process some or all of Your Personal Data.
Legitimate interest
15. In specific situations, We process Your Personal Data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact Your rights, freedom or interests.
16. For example, We will combine the booking history of Our many customers to identify trends and allow Us to keep up with demand, or develop new products/services. We will also send our Customers members information about sector updates and policy changes by email and post to support their practice and development.
F. When do We collect Your personal data?
We collect Your Personal Data when You do any of the following acts:
17. use the Website to, for example, browse our products and services; and/or view any information We make available and/or interact with a Creative. Where this happens a number of cookies are used by Us and by third parties to allow the Website to function, to collect useful information about visitors and to help to make Your user experience better. For more information about our use of cookies, please see our Cookie Policy which is set below at Section G;
18. request any information about Us to be sent to You;
19. create a new account with Us, use Your account to: make any bookings with Us, buy products, redeem vouchers from Us, or submit an enquiry, on the phone or online.
20. comment on or review our products or services or take part in one of our competitions or public events;
21. sign up to receive one of our newsletters, We may ask for Your name and Your email address as part of that process;
22. make any kind of booking or other appointment with Us;
23. when You communicate with Us, for example via social media or live-chat and to gather support for our campaigns;
24. choose to complete any surveys and You choose to provide Your personal details;
25. have given a third party permission to share with Us the information they hold about You in order to use one of our services;
26. apply for a job to work for Us;
27. attend any events which CocoRio or its Creatives participate in and where any of Your Personal Data is collected (e.g. pictures are taken); and/or
28. when You contact Us by any means with queries, etc.
G. Cookie policy
General
29. The Website uses cookies and similar technologies on each website that we operate. The technologies that we use include JavaScript tags, pixels, local storage, and web beacons, though for simplicity in this Data Policy we use the generic term “cookies” to mean all and any of them.
30. This Cookie Policy concerns the Website.
31. We use cookies for a range of purposes. They help us to present the Website to You, provide important functions, and analyse how You arrive at and use the Website. We also use some cookies to tailor adverts to you when you are on the Website, and when you are browsing other websites.
32. Cookies provide us with information about how the Website is used so we can keep it as up to date, relevant and error free as possible.
The types and categories of cookies we use
33. Cookies enable a small amount of data to be stored on Your device when you access websites and mobile applications on the internet. Cookies can be either:
a. Session cookies - these expire when you close your browser and do not remain on Your device; or
b. Persistent cookies - these are stored in the longer-term on your device. They are normally used to make sure the site remembers your preferences.
34. The cookies that we use on the Website can be categorised as follows:
a. “Strictly necessary” and “functional” cookies are used to support site navigation, search, login, live chat and shopping basket features;
b. “Performance” cookies support performance analysis; and
c. “Targeting or advertising” cookies help us personalise content and tailor advertisements for you.
Strictly necessary and functional cookies
35. Strictly necessary cookies are essential to enable you to move around the Website and use its features and services. These cookies allow the Website to provide essential services to you.
36. The Website uses strictly necessary cookies to:
a. Identify you as being logged in to the Website;
b. Remember the goods and services you ordered when you get to the checkout page;
c. Remember things like information you've entered on order forms when you navigate to different pages during your session on the Website;
d. Remember things like service selections you have made which are essential for us to provide you with services you have requested;
e. Make sure you connect to the right service on the Website when we make any changes to the way the Website works; and/or
f. Identify you as having consented to use of cookies on the Website.
37. Functional cookies are used to remember information you provide when you browse the Website, as well as your choices. For example, they are used to store your user name, log in details and language preferences and any customisations you make to Website pages during your visit. They are necessary to provide features and services specific to individual users.
38. The Website uses functional cookies to:
a. Remember settings you've applied (such as layout, text size, preferences and colours);
b. Remember selections you have made (such as search functions and results, and goods and services);
c. Apply customised content segments to individual users;
d. Apply users' individual service specifications (such as usage or credit allowance);
e. Share information with partners to provide a service on the Website. The information shared is only to be used to provide the service, product or function and not for any other purpose;
f. (If applicable), enable live help services, video content for playback and site search functionality; and/or
g. Share content with social media channels.
Performance cookies
39. Performance cookies allow us to update the Website to cater for user preferences and improve performance. They collect information about how the Website is used, e.g. which pages users visit most often and where error messages are delivered.
40. The Website uses performance cookies to:
a. Provide statistics on how the Website is used (including selections that you have made, and goods and services that you have viewed, during your use of the Website).
b. See how effective our adverts are;
c. Enable us to track and improve the Website by analysing visitor behaviour and results;
d. Improve the management and performance of tags on the Website;
e. To collect user opinions and feedback on the Website experience or products offered;
f. Targeting or advertising cookies;
41. These cookies collect information about your browsing habits on the Website to make advertising both on the Website and other websites you subsequently visit relevant to you and your interests, to limit the number of times those adverts are served to you and to help measure the effectiveness of advertising campaigns. These cookies are provided by third parties, who will also receive information that is collected through use of the cookie.
42. The Website uses targeting or advertising cookies to:
a. Tailor advertising presented on the Website and other websites you visit based on your interests and behaviour;
b. Monitor and improve the effectiveness of our adverts;
c. Limit the number of times you are shown adverts;
d. Personalise your experience of the Website through targeted content and promotions;
e. Test changes in the Website’s design and layout to enhance your experience of using it; and/or
f. Create a profile for you based on the products and services you’ve used or shown an interest in.
43. You can find further information about how Google will use personal data, if you give consent on our sites or app, in Google’s Privacy and Terms site: https://policies.google.com/technologies/partner-sites
H. What sort of data do We collect and how We use it
44. We want to deliver excellent customer service. In order to achieve this We do need to have relevant information about our service users.
The types of data We collect and how We use it
45. When You register with Us, We ask You for Your name, billing/delivery address, contact telephone number, email address, credit card or other payment information. We will use Your information to verify Your credit card details for Your purchase, process Your order and to send You Your goods. We will also send You a receipt via email and We may use Your telephone number to contact You regarding Your purchase (such as processing returns).
46. As part of the registration process You may chose to provide details of Your spouse or partner and of Your child(ren).
47. We may also contact You after a booking has happened in order to follow up on Your interest and ensure that We have answered it to Your satisfaction.
48. We may ask You and You may consent to participate in research, surveys, prize draws and other promotions. If You choose to participate in these surveys, We may ask for information such as Your name (and potentially the name of Your spouse or partner and/or child(ren), e-mail address, contact information, feedback and survey responses. We will use such personal data to give greater insight and accuracy into our research and We may also contact You to provide further information regarding Your response. We will also use such personal data to administer our prize draws (where applicable). If You request further information We will use Your personal data to respond to the request. We may also use this information to develop and improve our products and services and our customer relationships (where relevant).
49. We require information about Our Customers in order to be able to deliver Our customer service and benefits and to provide other products and services. This will include name, address and contact details.
50. If You communicate with Us requesting guidance or further information We may ask for information such as Your name, e-mail address, telephone number and postal address (where applicable). We will use this information to respond to and communicate with You about Your questions, comments or enquiry.
51. We collect Your name and address directly from the App and the Website in order to gather support when We run a campaign which normally endeavours to represent the interests of the childcare sector. In this context, We will use Your Personal Data about in order to collate statistical information to be presented to government in support of our campaigns.
52. In some cases We may require evidence of documentation to be able to use certain services or to take up employment with Us.
53. If You make a complaint about one of our services then We will normally require Your name, contact details and relevant information about Your concern, in order to be able to resolve the matter.
54. Your employment history and details of referees (who We presume consent to Us contacting them if We wish to proceed with Your application).
55. Information about Your partner/spouse and/or child(ren) if relevant to the enquiry or registration.
J. Who do We share Your Personal Data with?
We sometimes share Your Personal Data with trusted third parties which include:
56. IT companies that support the Website development and support other business related software, for example: www.simplybook.me.com, www.monday.com;
57. Banking services to process payments;
58. Our Creatives in order to assist them to provide the Services;
59. print and distribution processors; and
60. marketing companies that help Us manage our marketing communications for example an e-newsletter platform, online survey and online learning journal provider.
61. Our insurance underwriter (only where required as a condition of the provision of any insurance policy).
K. In some cases We may have a legal obligation to share Your personal data with the following organisations
62. If We are legally required to do so, for example, by a law enforcement agency, court or local government department that deals with child protection issue.
63. To enforce or apply the terms and conditions of Your contract with Us.
64. If it is necessary to protect our rights, property or safety or to protect the rights, property or safety of others.
65. As part of any transaction whereby We transfer the management out or take over any other organisation or part of it (including Us).
L. How do We protect Your Personal Data?
66. We take the security of Your personal data seriously. We have internal policies and strict controls in place to try to ensure that Your Personal Data is not lost, accidentally destroyed, misused or disclosed and to prevent unauthorised access. Any payment transactions will be encrypted.
67. Where We engage third parties to process personal data on our behalf, they:
a. are obligated to comply with the requirements of data protection laws;
b. are obligated to only use the data for the purpose/s for which it was supplied; and
c. are under a duty of confidentiality; and are required to implement appropriate technical and organisational measures to ensure the security of Your Personal Data.
M. Where do We store Your Personal Data?
68. We require from our data server providers that all data You provide to Us is stored on secure computers or servers located within the UK or European Economic Area, or, if located outside of these jurisdictions, such data will be transferred in accordance with GDPR and other relevant data legislation.
69. We may also store paper records in locked filing cabinets or locked cupboards.
70. Our third party processors will also store Your Personal Data on secure IT systems which may be situated inside or outside of the European Economic Area. They may also securely store data in paper files.
71. Your credit card details are passed to a third-party payment processor. We do not retain Your payment information.
N. For how long do We keep Your Personal Data?
72. We will only retain Your personal data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
73. To determine the appropriate retention period for Your 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.
O. Automated Decision Making
74. We may monitor, analyse, and compile statistical and performance information based on and/or related to Your use of the services, in an aggregated and anonymised format.
75. We may also use Your personal information to communicate with You about our products, services and promotions. This correspondence may be generated from Your interest based on Your sales profile and/or Your enquiry.
P. Your rights
76. As a data subject, You have a number of rights. For example (and this is not an exhaustive list), You can:
a. request to access and obtain a copy of Your Personal Data on request;
b. request that We change incorrect or incomplete data; and
c. request that We delete or stop processing Your Personal Data, for example where the data is no longer necessary for the purposes of processing.
77. Where We rely on Your consent to processing Your Personal Data You can request to withdraw Your consent at any time for example, You may choose to stop receiving one of our newsletters by informing Us of this decision or clicking the unsubscribe link in any e-mail We send to You.
78. You may instruct Us to restrict, suspend or amend Our usual processing practices of Your Personal Data, in any of the following scenarios:
a. If You want Us to establish the accuracy of the data;
b. where Our use of the data is unlawful but You do not want Us to erase it; or
c. where You want Us to hold the data even if We no longer require it as You need it to establish, exercise or defend legal claims; or
d. You have objected to Our use of Your Personal Data but We need to verify whether We have overriding legitimate grounds to use it.
79. If You would like to exercise any of these rights or have any questions about this Data Policy, please contact our data manager at: info@cocorio.co.uk
80. Please note that if You do withdraw Your consent, this decision that will not affect the lawfulness of any processing carried out before You withdrawal Your consent.
Q. How to contact the Information Commissioner Office (ICO)
81. If You are concerned about the way Your Personal Data is handled and remain dissatisfied after raising Your concern with our privacy team, You have the right to complain to the Information Commissioner Office (ICO). The ICO can be contacted at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or https://ico.org.uk/
R. Changes to this Data Policy
82. We keep this notice under regular review. Any changes to this notice will be posted on the Website, so that You may be aware of how We use Your Personal Data at all times.
S. Date of this privacy notice
83. This privacy notice was last updated on 9 June 2023 January 2024.
T. Personal data in respect of Your child(ren)
84. When You register with Us in respect of Your child(ren) You will be asked to provide their date of birth details, it is entirely up to You whether or not You provide those details and/or any other details about Your child(ren)YourYour.
85. It is entirely up to You whether or not You choose to provide Us or our Creatives with personal data relating to Your child(ren) (Child Health Data). For example, You may choose to provide Child Health Data as part of the Customer booking journey through the Website, or when communicating with an employee of Our’s or with a Creative – and perhaps You may choose to do so because You judge it sensible to do so because, for example, it is in the safey interest of Your child(ren) that the Creative is aware of such information.
86. CocoRio will never directly ask You to provide to Us any Child Health Data. If You chose to provide Child Health Data to Us then the only circumstances we will process this data is to communicate such information to the Creative who is scheduled to provide the Services to Your child(ren).
87. We have instructed Our Creatives to also never directly ask You to provide to them any Child Health Data.
88. Child Health Data is a ‘special category’ of personal data under GDPR and specific legal requirements apply to such personal data and to any entity that processes such data. It is our understanding of GDPR that, these circumstances, We are legally entitled to process Your Health Data pursuant to “the social care condition” as set out in Condition 2(2) of Schedule 1 of the Data Protection Act 2018.
CocoRio Limited
January 2024