Marketing Policy

PRIVACY NOTICE

At Couno Ltd, we are passionate about protecting your data and your rights as an individual. When we process your information with us, we take our responsibility seriously and work hard to maintain your privacy.

We are committed to being transparent and so our Privacy Policy shows what data we’ve collected, and how we collect and process it. It outlines how to access and manage your information and how to get in touch if you have any questions.

INTRODUCTION

We understand that your privacy is important to you and that you care about how your information is used and shared. We respect and value the privacy of everyone who uses our services. We will only collect and use information in ways that are useful and consistent with your rights and our obligations under the law.

Our Privacy Policy exists to provide you with key information about:

What data we collect from you and why
How we use or process that data
How you can access and take ownership of your data
How and where you can make a complaint if you’re unhappy

Please read this Privacy Policy carefully and ensure that you understand it.

WHO IS COUNO LTD?

Couno Ltd (Couno) is a limited company registered in England under 07340631. Our registered office is Admirals Offices Main Gate Road, The Historic Dockyard, Chatham, Kent, England, ME4 4TZ. Our trading address is Couno Ltd, 19 Station Rd, Southend-on-Sea, SS1 3JY.

For all data related matters, including subject access requests, please contact our data privacy lead:

Danielle Heath

Couno Limited

19 Station Road

Southend on Sea

Essex, SS1 3JY

Tel: 01702 811222

Email: dheath@couno.co.uk

WHAT DATA DO WE COLLECT?

We will never collect or process special category data, or data relating to criminal convictions or offences, about you. Our services are not intended for children and we do not knowingly collect data relating to children.

We have bought your information from Experian Ltd. A copy of their privacy information can be found here. If you have any concerns about this please contact their UK Data Protection Officer by email to UK.DPOBusinessEnquiries@Experian.com.

We intend to use your contact information to promote and raise awareness of our Company and its services, which we believe will be of interest to you.

To make our processing as clear as possible, we’ve provided a breakdown below.


Processing Activity	Data Processed	Lawful Basis
Send promotional information marketing our Company an raising awareness of our services by email, post and/or telephone	Name and email address	Consent
To respond to your enquiry	Name and email address	In performance of a contract
To unsubscribe you	Name and email address	Legal obligation

WHAT HAPPENS TO YOUR DATA?

Over the coming months, we will send you emails promoting the Company and our services. Should you choose to sign up to any of these services, we’ll process your data accordingly.

WHAT’S OUR LEGAL BASIS?

You must have provided your explicit consent to Experian Ltd for them to sell your data to us for marketing purposes.

Our legal basis for using this data for marketing purposes if therefore consent i.e. with your permission. If you do not believe you have given consent please let us, and Experian know, as soon as possible.

If you provided consent but no longer want your personal information to be used in this way, you have the right to withdraw consent at any time. You can do this by contacting us. You will also need to contact Experian Ltd if you wish to be removed from their records.

When you place an enquiry with us, we have to process your information to respond accordingly. We do this “in performance of a contract” which is a separate lawful basis.

If you choose to unsubscribe from our marketing emails, we will need to keep your details on our “Unsubscribed List” to ensure we don’t mistakenly contact you again. It is our legal obligation to honour your wishes in this respect.

WHO DO WE SHARE YOUR DATA WITH?

Couno Ltd will never share or sell your data to any other company for commercial gain. We only ever “share” or transfer your data as part of our own, core processing activities. So, for example, by using an email campaign platform to contact you.
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. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

HOW DO WE KEEP YOUR DATA SECURE?

Your privacy is important to us, so we take all reasonable and proportionate steps to protect your personal information by:

Putting appropriate security measures in place, to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way.
Limiting access to your personal data on a ‘need to know’ only basis.
Ensuring our staff are trusted and trained in data protection compliance and confidentiality.
Following due process to deal with any suspected personal data breach.
Only transferring your data outside of the European Economic Area (EEA) when the third-party provider participates in and has certified its compliance with the EU-US Privacy Shield Framework.
Only retaining your personal information for as long as necessary to fulfil the purpose we collected it for.

HOW LONG DO WE KEEP IT?

We will only retain and use your personal data for a period of 36 months, at which point it will be permanently deleted. If you wish to remain on our contact lists beyond this 36 month period, unless you engage with us in some other way such as becoming a customer.

YOUR RIGHTS

We fully support your rights and seek to willingly and cheerfully uphold them. However, if you ever feel this is not the case please contact us to discuss the matter further.

At any point you can exercise your:

Right of access – contact us for a copy of the data we hold about you.
Right of rectification – let us know if the data we hold is out of date or inaccurate and we’ll update it.
Right to be forgotten – if you no longer want to use our services, please contact us and we’ll delete all related data.
Right to restrict processing – we only collect the data we need and actively ensure we’re never collecting anything over and above need. You can opt in and out of SDP’s individual services by contacting us.
Right of portability – we will support reasonable requests to transfer your data to another organisation should you require it.
Right to object to automated decision-making and profiling- we do not currently use any automated profiling of any description. In the event you’re unhappy with the way we’re processing your data please contact our Data Privacy Officer.

In the event we refuse to your rights in any way we will provide you with a reason why. You will then have the right to complain to the supervisory authority as outlined below.

To exercise all relevant rights, queries or complaints in relation to this privacy policy or any other data protection matter between you and us, please in the first instance, contact us.