Kofo Wholefoods Ltd – ONLINE Privacy Policy

Effective Date: April 2021

Kofo Wholefoods Ltd (“Kofo”, “we,” “us” or “our”)  is committed to safeguarding your privacy rights and ensuring that your personal data is protected. This Privacy Policy explains our use of your personal data when you visit our website (the “Site”) and/or interact with us. It also explains your rights and options around how we use your personal data.

We are the controller of your personal data and our contact details are set out at the end of this Privacy Policy.

Please ensure that you provide a copy of this Privacy Policy to any third parties whose personal data you provide to us.

INFORMATION WE COLLECT ABOUT YOU

We collect various types of information when you visit our Site, communicate with us, and/or purchase our products.

Information we collect includes:

• Visitors to our Site: we collect information, such as browser type, IP address, date and time of visit, average time spent on the Site, cookie ID, and any site that referred you to us.
• Joining our mailing list: we collect information, such as, name and e-mail address.
• Purchasing a product: we collect information, such as, name, email address, postal address, and telephone number. If you make a payment via our Site, you will be transferred to a secure server operated by a third party payment processor. The payment processor will collect your credit card, debit card or account details along with other information in order to process your payment.
• Contacting us: we collect your name, e-mail address, telephone number and other information you voluntarily provide, if you complete our online form or telephone

We collect and use your personal data via cookies on our Site. Please see our Cookies Policy for further information.

How Information is Used

Your personal data will be used by us for the following purposes:

Purpose	Legal Basis
To provide you with the products you have ordered	To manage and perform our contract with you We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be.
To process payments made via the Site e.g., where you purchase a product on the Site
To provide support and to respond to your requests and enquiries	We have a legitimate interest to respond to your requests and enquiries for ongoing business administration
To personalize your visit to the Site and to assist you while you use the Site	We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be.
To improve the Site by helping us understand who uses the Site
To keep a record of your relationship with us.	We have a legitimate interest to manage our business including for legal, personnel, administrative and management purposes and for the prevention and detection of crime provided our interests are not overridden by your interests To comply with our legal or regulatory obligations
To perform general, financial and regulatory accounting and reporting.
To meet our legal and regulatory obligations, and to establish, defend and enforce claims.
To investigate and resolve complaints and manage regulatory matters, investigations and litigation
As necessary, to share data with law enforcement, tax authorities or other government and fraud prevention agencies
To monitor electronic communications for investigation and fraud prevention purposes, crime detection, prevention and investigation
To share personal data with third parties including those that acquire or are interested in acquiring all or part of our assets or shares.
To contact you to tell you about products and services offered by us which we believe may interest you unless you advise us that you do not wish to receive marketing or market research communications from us	If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us you can unsubscribe via the link at the bottom of the relevant marketing e-mail or contact us using the contact details below. We have a legitimate interest to carry out direct marketing.

 

Your Right to Object – Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

Information We Disclose and International Transfers

We may share your personal data with selected third parties in order to achieve the purposes described in HOW INFORMATION IS USED, above. This may include sharing your information with vendors e.g., our IT service providers, payment service providers, and fulfilment partners.

We reserve the right to disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• if substantially all of our assets are acquired by a third party, personal data held by us may be one of the transferred assets;
• if we are under any legal or regulatory duty to do so; and/or
• to protect the rights, property or safety of Kofo, its personnel, users, visitors or others.

Some of our suppliers run their operations outside the European Economic Area (“EEA”) / UK – this may include a country which may not be subject to the same data protection laws as companies based in the EEA/UK – for example, the US.  In these circumstances, we will take steps to make sure they provide an adequate level of protection, and implement appropriate safeguards (including, data transfer agreements). For further information in relation to these safeguards, please contact us using the contact details below.

Retention of Your Information

We retain personal data as long as it is necessary and relevant for Kofo. The criteria used to determine the retention periods include:

• how long the personal data is needed to provide the services and operate Kofo;
• the type of personal data collected; and
• whether we are subject to a legal, contractual or similar obligation to retain the personal data.

YOUR Rights

You have certain rights in relation to your personal data, including the right to:

• request access to personal data we hold about you;
• the correction of your personal data when incorrect, out of date or incomplete;
• request that we erase your personal data;
• opt-out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reason to do so;
• request that we restrict the processing of your personal data – i.e., we would need to secure and retain the data for your benefit but not otherwise use it; 
• withdraw your consent at any time (e.g., for direct marketing); and
• the portability of personal data – i.e., ask for a copy of your personal data to be provided to you, or a third party, in a digital format.

We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please contact us using the contact details below.

You also have the right to lodge a complaint about the processing of your personal data with the data protection authority.

Consequences of not Providing Personal data

Where we require your personal data to comply with our legal requirements, failure to provide this information means we may not be able to provide the requested services to you. We will tell you when we ask for your information whether it is a statutory or contractual requirement to give us the information and the consequences of not providing the information.

Other Important Information

Links to Other Websites

This Privacy Policy applies only to Kofo operated services and applications.  Our Site may contain links to other websites that are not operated or controlled by Kofo. Kofo does not control such third-party websites or their privacy practices.  Any personal data you choose to give to third-party websites is not covered by this Privacy Policy.

Changes to the Policy

We may change this Privacy Policy from time to time by posting a new version of the policy on our Site. We will notify you of any material changes via e-mail or through a notification on our Site. Any changes to the Privacy Policy will become effective immediately after being posted.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at: [email protected]