Data Privacy Policy

This Data Privacy Policy aims to inform Users about the scope of comprehensive protection of their personal data recorded in files, records, databases, or other technical means of data processing implemented by COHEDA, located in the City of London, United Kingdom, ensuring respect for the right to privacy of individuals, as well as free access to information that may eventually be registered about them.

COHEDA considers any type of information relating to a User as personal information, and therefore always ensures the privacy and confidentiality of such information. The confidentiality of information regarding Users will involve its maintenance in secure files and/or databases, so that access by third parties not authorized for this purpose is restricted.

For inquiries about this Policy or any circumstances relating to the processing of personal information, Users may contact through any of the following means:

E-mail: support@coheda.com

Notifications and communications sent by COHEDA to the postal address or email address directly provided by the user in the registration forms or those that emerge as the sender's address or email address in cases where communication is initiated by an unregistered visitor, will be considered effective and fully valid. Likewise, communications consisting of notices and messages inserted on the Site or sent during the provision of a service, aimed at informing users about certain circumstances, will be considered effective.

This Privacy Policy covers the following aspects:

• Voluntariness in Data Provision
• Sensitive Data
• Financial Data
• Authorization for the Use of Personal Information
• Collection and Use of Information
• Information Collected by COHEDA
• Transfer of Personal Information
• Disclosure of Information
• Physical Location Where User Personal Data Processing Takes Place
• Site Communications
• Rights of Data Subjects
• We Utilize Appropriate Security Methods
• Changes to this Policy
• What Happens to Your Personal Information When You Close Your Account With Us?

Voluntariness in Data Provision

This Policy is intended to inform users about the processing of personal data carried out by COHEDA, so that they may freely and voluntarily decide whether to provide their personal data when requested or obtained through the use of any of the services available on "www.coheda.com".

As a general rule, when using a service or accessing certain content requires providing personal data, such provision is not obligatory, except in cases where it is specifically indicated that the data is required for the provision of the service.

Sensitive Data

COHEDA does not collect any sensitive data of any nature. If any of the data required are classified in the future as sensitive data by the National Directorate of Personal Data Protection or any other competent authority, no user will be obliged to provide such data in order to access the services provided by COHEDA.

Financial Data

Payment transactions resulting from the purchase of products and/or services by Site Users are handled by third parties separate from COHEDA. The payment process as a whole occurs outside of the COHEDA computer systems. Consequently, COHEDA does not access, process, or store any financial data associated with the User.

Authorization for the Use of Personal Information

The user who provides their personal data expressly authorizes COHEDA to use the provided data for the purposes outlined herein. This also implies acceptance of all the terms contained in this Policy, as well as in the General Terms and Conditions.

Collection and Use of Information

The collection and processing of personal data from Users aim to provide, manage, administer, personalize, update, and improve the products and services made available to users by COHEDA. It is also possible that the personal information of Users may be used for all legal purposes, which may include, but are not limited to, responding to their requests, processing transactions, and for administrative purposes.

Information Collected by COHEDA

The collected information includes:

• Name
• Surname
• Email address
• Website.

Additionally, when using the site, it's possible to receive non-personal information from users such as "references," IP addresses, and various environmental variables.

References

A "reference" is information that the Web browser transmits to the servers of COHEDA and refers to the URL from which the Site is accessed.

IP Address

When accessing COHEDA, it's possible to obtain the Internet Protocol (IP) address and the type of browser used by the User. The IP address also allows knowing the geographic location of the computer or internet browsing device from which COHEDA has been accessed, the date, and time of access. The browser may also allow us to know which internet pages the User has previously visited.

Environmental Variables

The "environmental variables" include, among other things, the domain from which internet access is obtained, the time of access to COHEDA, the type of browser, the operating system or platform used, the internet address or website that refers to COHEDA, and the names of the pages of COHEDA visited by the user.

Cookies

Occasionally, COHEDA may use cookies, which will be installed on the user's computer when browsing the site. Their purpose is to facilitate navigation on the site for the user and provide COHEDA with information that will help improve its services and contents. In no case will the cookies used by COHEDA provide personal information of the user, who will remain fully anonymous in relation to them, as they also do not provide information aimed at the individualization of the user. It is COHEDA's intention to emphasize that it is not necessary for the user to allow the installation of cookies sent by COHEDA to browse the site. This may only be required in relation to certain services and/or contents.

This information is collected for the exclusive internal use of COHEDA, for example, to increase the security of the service.

Transfer of Personal Information

All personal data collected from Users is for the exclusive internal use of COHEDA. Whenever personal information is collected as part of a direct relationship with a user, in respect for the privacy and confidentiality of users, COHEDA will not transfer or disclose that personal information to any third party outside of COHEDA or its affiliates. Personal information of users will only be shared with third parties in the following cases:

• When there is a legal obligation to do so.
• When there is an order issued by a competent Judge.

Disclosure of Information

COHEDA may share certain personal information with third parties according to the terms described below:

• Associates

  It is possible to share information, including personal information provided, with associated third parties, such as resellers. COHEDA ensures that all its partners comply with the obligations imposed by the Personal Data Protection Law, including the implementation of appropriate security systems, and, in the same sense, subscribe to and comply with the principles held by COHEDA regarding the protection and confidentiality of personal data.

• Third-party data processing service providers

  For the provision of its services, COHEDA may contract certain services to third parties. These services may include, without limitation, automated data processing, information storage, electronic communications delivery services, transaction processing. For the proper provision of services, third parties responsible for them may require access to the databases of COHEDA. However, COHEDA does not transfer any personal information of any kind to these third parties; their access to the databases of COHEDA is strictly limited to activities necessary for the provision of the service, and they are prohibited from extracting data or making total or partial copies of the databases of COHEDA.
  COHEDA ensures that all its suppliers comply with the obligations imposed by the Personal Data Protection Law, including the implementation of appropriate security systems, and, in the same sense, subscribe to and comply with the principles held by COHEDA regarding the protection and confidentiality of personal data.

Physical Location Where User Personal Data Processing Takes Place

The information collected regarding the use of the site may be processed and stored within the territory of the United Kingdom or outside of it. USERS WHO ARE NOT RESIDENTS OF THE UNITED KINGDOM EXPRESSLY ACCEPT THE POSSIBLE TRANSFER OF PERSONAL INFORMATION TO THE UNITED KINGDOM OR OTHER COUNTRIES THAT MAY BE DISCLOSED OCCASIONALLY. This consent will be deemed tacitly granted when the user has registered on the site or has made use of any of the services and contents available on it. In any case, COHEDA guarantees that the information will be processed only in a jurisdiction that ensures adequate legal protection to the data subjects.

Site Communications

Occasionally, user data may be used to send communications to the users themselves regarding the products and services provided by COHEDA, its associates, or business partners. When a User prefers not to be contacted for these purposes, they may:

• Contact COHEDA using the contact information provided here and request not to receive information about products and services.
• Follow the instructions included in the emails sent by COHEDA for this purpose.

Finally, messages related to the status or changes regarding the services will be sent to Users whenever necessary. For example, if our service is modified, adds new features, or updates its operation.

Rights of Data Subjects

Under GDPR (General Data Protection regulation) subjects have a number of rights relating to their personal data, these will come into force on the 25th May 2018, for further information please see https://ico.org.uk

Right to Restrict Processing

Subjects have the right to request COHEDA restrict processing of their personal data where there is no legitimate interest on the part of COHEDA to do so:

• Where the accuracy of the personal data is contested, to restrict the processing until such time as the accuracy has been sufficiently verified.
• Where subjects object to the processing and where COHEDA is considering whether there are legitimate grounds to override the request.
• When processing is unlawful and subjects oppose erasure and request restriction instead.
• If COHEDA no longer need the personal data but subjects require the data to establish, exercise or defend a legal claim.

Subjects can exercise the right at any time by contacting COHEDA.

Right of Access

The GDPR Act gives subjects the right to access information held about them. Subjects can exercise this right by contacting COHEDA. COHEDA is required to verify subjects identify before processing any right to access request, once verified the data shall be provided within 28 days. The data shall be provided free of charge however an admin fee may be applied where a request is manifestly unfounded or excessive, particularly if it is repetitive.

Right to Erasure

As an individual subjects have the right to request the erasure of any data that COHEDA holds about them, this is not an absolute right, for example it does not override COHEDA requirement under UK law to keep financial data such as invoice information.
Subjects can make a request where their personal data is no longer necessary in relation to the purpose for which it was originally collected/processed, for example if the subject cancels all services they have with COHEDA.
To make a right to erasure request cutomers may contact COHEDA customer service.

Right to Rectification

The GDPR provides the right to have any personal data rectified that may be incorrect or incomplete. Customers can update their own personal details via the client area however if this is not sufficient they contact COHEDA customer service.

Right to Object

Subjects have the right to object to the processing of their personal data where there is no legitimate or lawful reason to do so. To make a right to object request subjects can contact COHEDA customer service.

We Utilize Appropriate Security Methods

At COHEDA, security is paramount. COHEDA adopts all logical and physical security measures required by regulations, as well as those that result from appropriate prudence and diligence in protecting the Users who have placed their trust in COHEDA, to safeguard the personal information gathered against unauthorized access, alteration, or destruction. COHEDA evaluates and improves its security systems whenever necessary.

Changes to this Policy

In the event of a modification to this Policy, we will publish those changes in this section, on the main page of the Site, and in other places deemed appropriate to notify Users about the changes. COHEDA reserves the right to modify this Policy at any time, and Users should therefore regularly familiarize themselves with it, by reading it with a frequency of no less than once a week.

What Happens to Your Personal Information When You Close Your Account With Us?

In the event that a User decides to close their account with COHEDA, our Privacy Policy will continue to apply to that User. All their personal information will be marked as unavailable; however, the User should note that this does not mean the deletion of their information. User information will continue to be stored in the systems of COHEDA, remaining unavailable and only used to resolve any disputes or legal situations that may arise, and until the fulfillment of the legal term of prescription of contractual obligations.

Last Policy Update Date: March 06, 2024.