Privacy and Cookies Policy
- WHO ARE WE? We are COCUNAT S.L. and we process your personal data as joint controllers. This means that we are jointly responsible for using and protecting your data. (See more – which goes to Item 1.)
WHAT DO WE USE YOUR PERSONAL DATA FOR? We’ll use your data (obtained online or in person) to manage your sign-up as a user, manage the purchase of products or services, deal with your inquiries, as well as send you our personalized communications should you wish to receive them, among other purposes. (See more – which goes to Item 2)
WHY DO WE USE YOUR DATA? We have lawful grounds to process your data for different reasons. The main one is that we need to process your data to perform the contract you enter into with us upon signing up, purchasing or enjoying any of our services or features. We also use your data for other reasons, such as dealing with your inquiries or sending you newsletters you have subscribed to. (See more – which goes to Item 3)
WITH WHOM DO WE SHARE YOUR DATA? We will share your data with service providers that help us or provide us with support. (See more – which goes to Item 5)
- YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In some cases, you also have other rights, such as objecting to the use of your data or their portability, as we’ll explain in detail below. (See more – which goes to Item 6)
BEFORE WE START…
- In this Privacy and Cookies Policy, you’ll find all relevant information on how we use our customers’ and users’ personal data, regardless of the channel or means (online or in person) you use to interact with us.
- We are transparent about what we do with your personal data so you understand the implications of the manner in which we use them or your rights with regard to them:
- We encourage you to read our full Privacy and Cookies Policy to understand in detail how we’ll use your personal data and the rights you have with regard to them.
- All the information will always be available in this Privacy and Cookies Policy so you can read it whenever you want, and what’s more,
- you’ll also find information on each processing activity carried out on your personal data as you interact with us.
- Some terms we’ll use in this Privacy and Cookies Policy are as follows:
- When we talk about our Platform, in general, we’re referring to any of the digital or in-person channels or means you’ve used to interact with us. The main ones are:
▪ Our Website.
▪ In person, at any of our Brick-and-Mortar Stores.
- WHO IS THE CONTROLLER FOR YOUR PERSONAL DATA?
The Controller for your personal data is:
- ▪ COCUNAT S.L., a company currently operating in Spain under the brand COCUNAT NATURAL & TOXIC FREE (hereinafter “COCUNAT”): whose mailing address is: Carrer Folgueroles 17, local COCUNAT (Barcelona), Spain.
- and whose Data Protection Officer has the email address: [email protected]
In other words, COCUNAT (hereinafter jointly “Us” or the “Joint Controllers”) are the Joint Controllers. This means that we have regulated and are jointly responsible for processing and protecting your data.
- FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
Depending on the products, services or features you want to enjoy at any given time, we’ll need to process one type of personal data or another, which – in general, as the case may be – can be divided as follows:
- your identification details (e.g., your name, surname(s), image, language and country from where you interact with us, contact information, etc.);
- financial and transactional information (e.g., your payment or card details, information about your purchases, orders, refunds, etc.);
- connection, geolocation and browsing information (e.g., location information, device ID number or identifier for advertisers);
- commercial information (e.g., if you’ve subscribed to our newsletter); and
- information about your tastes and preferences.
Please bear in mind that when we ask you to fill in your personal data to give you access to a certain feature or service of the Platform, we’ll mark some fields as mandatory, as we need this information in order to provide you with the service or give you access to the feature in question. If you choose not to provide us with this data, you may not be able to sign up as a user or enjoy these services or features.
In other cases, we may passively collect information by using tracking tools such as browser cookies or other technologies similar to our Platform or the communications we send you. In certain cases, a third party may have provided us with information about you when using a feature or service of the Platform, such as when they’ve sent you a gift card, you’ve received a subscription as a gift or if they’ve sent an order to your address.
In such cases, we’ll only process your data in relation to that feature or service, in accordance with the provisions set out in this Privacy and Cookies Policy.
Depending on how you interact with our Platform, we’ll process your personal data for the following purposes:
1. To manage your sign-up as a user of the Platform
In case you decide to sign up as a user of our Platform, we need to process your data to identify you as a user of it and give you access to its different features, products and services that are available to you as a registered user. You may cancel your registered user account by contacting us through Customer Service.
We hereby inform you that the data we collect about your activity, obtained through the different channels of the Platform, and which includes your purchases, will remain linked to your account so that all information may be accessed at once.
2. For the performance of the contract of sale or service that you’ve entered into with Us on the Platform
This purpose includes the processing of your data to mainly:
● Get in touch with you in relation to updates or informative communications related to features, products or services engaged, including sending quality surveys about products or services provided.
● Manage payment for products you buy, regardless of the payment method used. For example:
○ If, upon buying any of our products through the Website, you choose the option to save your payment details and your shipping address for future purchases (in case this feature is available), we need to process the specified data to activate and implement this feature. Consent for the activation of this feature autofills your payment details in subsequent purchases so there’s no need for you to enter them again for each new process. They will be understood to be valid and in force for subsequent purchases. You may modify or delete your payment details at any time through the section corresponding to payment information from your registered user account on the Website.
● Enable the necessary mechanisms in order to prevent and detect any misuse of the Platform, such as during the purchase and return process, as well as any potential fraud against you and/or against Us. If we believe that the transaction may be fraudulent or we detect abnormal behavior with signs of any fraudulent use of our features, products and services, such processing may give rise to consequences such as blocking the transaction or canceling your user account.
● Manage possible exchanges or returns once you’ve made a purchase and manage information requests about the availability or reserving of products through the Platform, depending on whether such options are available at any given time.
● For billing purposes and providing you with the receipts and invoices for the purchases you’ve made on the Platform.
● Ensure that you can use other features or services as they become available, such as purchasing, receiving, managing and using Gift Cards, as well as to enable you to access and use the Wi-Fi we have available for our customers at our Brick-and-Mortar Stores.
3. To deal with the requests you make through the Customer Service channels
We only process the personal data strictly necessary to manage or respond to your request.
If you use the telephone, the call may be recorded to deal with your request to ensure the quality of the service delivered.
4. For marketing purposes
This purpose includes the processing of your data to mainly:
● Customize the services we offer you and make recommendations according to your interaction with us on the Platform and the analysis of your user profile (e.g., based on your purchase and browsing history).
● If you subscribe to our Newsletter, we will process your personal data to manage your subscription, including the sending of customized information about our products or services through different means (such as email, WhatsApp or SMS). Likewise, we can send you this information through push notifications if you’ve activated them on your device.
● Therefore, bear in mind that this data processing activity involves the analysis of your user or customer profile to ascertain your preferences, and thus, which products or services would suit your style when sending you information. For example, based on your purchase and browsing history (i.e., based on the items you’ve clicked on), we’ll make suggestions about products that we believe may be of interest to you and, if you’re a registered user, we’ll provide you with the option to “recover your basket”.
● Remember that you may opt out of the Newsletter at any time at no cost whatsoever through the “Newsletter” section of the Platform or by following the instructions we provide in each communication.
○ Show you advertisements on the Internet that you can see whenever you browse websites and apps, for example, on social media. The advertisements you see may be displayed randomly, but on other occasions they may be related to your purchase history, preferences and browsing habits.
○ In case you’re a social media user, we may provide certain information to the social media sites we work with so they can show you advertisements from our brand and, in general, show you or other similar users advertisements that consider your profile on such social media sites. If you want more information on how your data are used and how advertising works on these social media sites, we recommend that you check the information on your privacy on the social media sites that you use.
○ Additionally, we use your data to perform measurement and segment analyses for the advertisements we show to users on some of our partners’ platforms. To do this, we collaborate with these third parties who provide us with the necessary technology (e.g., through cookies, pixels, SDKs) to use these services. Bear in mind that, although we do not provide any identifying data to these partners, we do share a unique identifier (e.g. identifier for advertisers linked to the device, cookie ID, etc.) with them. If you want more information in this regard, please read our Cookies Policy.
● Data enrichment: When we obtain your personal data from different sources, we may combine it under certain circumstances to improve our understanding of your needs and preferences in relation to our products and services (including for the purposes of analytics, user profile generation, marketing studies, quality surveys and improving interaction with our customers). We are referring, for example, to how we combine your information if you have a registered account and, using the same email address linked to your account, you make purchases as a guest; or to automatically collected information (such as IP addresses, MAC addresses or metadata) that we may link to any information you’ve directly provided us with through your activity on the Platform or at any of our stores (e.g., information related to your purchases, whether in brick-and-mortar stores or the online shop, your preferences).
5. Usability and quality analyses to improve our services
If you access our Platform, we hereby inform you that we will process your browsing data for analytics and statistical purposes, that is, to understand the way users interact with our Platform and the actions we may carry out on other websites and apps, and thus be able to make improvements.
Likewise, from time to time, we may carry out quality actions and surveys intended to determine the level of satisfaction of our customers and users and detect our areas for improvement.
- WHAT IS THE LAWFUL BASIS FOR THE PROCESSING OF YOUR DATA?
1. Management of your sign-up as a user of the Platform
The processing of your data is necessary for the enforcement of the terms governing the use of the Platform. In other words, we need to process your personal data so that you can sign up as a user of the Platform, as otherwise we wouldn’t be able to manage your sign-up.
We therefore consider that we have a legitimate interest to link your purchases and the data we collect about your activity through the different channels of the Platform to your account.
2. Performance of the contract of sale or service
The processing of your data is necessary for the performance of the contract of sale or service that binds us to you.
Some data processing activities associated with the purchase process may only be enabled if you’ve asked or authorized us to do so, such as storing your payment details for future purchases or informing you of the availability of our products (in case this option is available). In these cases, the lawful basis for processing your data is your own consent. In addition, we process your location data when you give us your consent, in order to offer you specific services at our Brick-and-Mortar Stores.
We therefore consider that we have a legitimate interest to perform the necessary checks to detect and prevent any possible fraud or fraudulent uses when you use the Platform, such as when you make a purchase or return. We understand that the processing of this data is good for all parties: for you, as it enables us to put measures in place to protect you against any attempted fraud by third parties; for Us, as it lets us forestall any inappropriate use of the Platform; for all our customers and society at large, as it also protects their interests by ensuring that fraudulent activities are discouraged and detected when they occur.
3. Customer Service
We therefore consider that we have a legitimate interest to deal with any inquiries you make through the different contact methods that exist. We understand that the processing of this data is also beneficial for you as it enables us to attend to you in a suitable manner and answer any questions you’ve asked.
Whenever you get in touch with us, particularly to handle incidents related to your order or the product/service purchased through the Platform, processing is necessary for the performance of the contract of sale.
When your inquiry is related to the exercise of the rights that we inform you of below or claims related to our products or services, the lawful basis for processing your data is our compliance with legal obligations.
The lawful basis to process your data for marketing purposes is your consent, for example: when you agree to receive customized information through different means, when you authorize us to send push notifications to your device, when you give us your consent through the cookies or privacy settings on your device, or when you accept the legal terms and conditions to take part in a promotional action or to publish your photos on the Platform or on our social media channels.
To offer you customized services or show you customized information, whether on our Platform or that of third parties, as well as perform data enrichment, we consider that we have a legitimate interest to carry out profiling using the information we have about you (such as your browsing habits, preferences or purchase history) and the personal data you’ve provided us with such as age range or language, as we understand that the processing of this data is also beneficial for you as it improves your user experience and enables you to access information in line with your preferences.
5. Usability and quality analyses
We therefore consider that we have a legitimate interest to analyze the usability of the Platform and the users’ level of satisfaction, as we understand that the processing of this data is also beneficial for you because the purpose is to improve the user experience and provider better quality services.
- HOW LONG WILL WE RETAIN YOUR DATA?
The retention period for your data will depend on the purposes for which we process it, as explained below:
1. Management of your sign-up as a user of the Platform
We will process your data for as long as you remain a registered user (i.e., until you decide to cancel).
2. Performance of the contract of sale or service
We will process your data for as long as necessary to manage the purchase of the products or services you’ve acquired, including any possible returns, complaints or claims associated with the purchase of that product or service in particular.
On some occasions, we will only process the data for as long as you want us to, such as the case of payment details you’ve asked us to store for any possible future purchases (in case this option is available).
3. Customer Service
We will process your data for as long as necessary to deal with your request.
We will process your data until you opt out or unsubscribe from the newsletter.
Likewise, we’ll show you customized advertisements until you change your device, browser or your cookie settings, which will withdraw such consent.
If you take part in promotions, we will keep your data for six (6) months after the end of the action.
5. Usability and quality analyses
We will process your data on occasion when we carry out an action or specific quality survey or until we anonymize your browsing data.
Regardless of the fact that we’ll process your data for the time strictly necessary to fulfill the relevant purpose, we’ll keep it duly stored and protected for as long as any liabilities arising from such processing may arise, in compliance with the regulations in force at any given time. Once the statute of limitations has passed for any possible actions in each case, we will delete your personal data.
- WILL WE SHARE YOUR DATA WITH THIRD PARTIES?
In order to fulfill the purposes specified in this Privacy and Cookies Policy, it is necessary for us to give COCUNAT SL and the third parties we work with access to your personal data, namely:
- financial institutions,
- fraud detection and prevention agencies,
- technology and analytics service providers,
- logistics, transport and delivery service providers and partners or their associated establishments,
- customer service providers,
- marketing and advertising service providers such as advertising agencies, advertising partners or social media that, in certain cases, may act as joint controllers.
For service efficiency, some of the aforementioned providers are located in countries outside the European Economic Area which do not provide data protection levels similar to those of the European Union. In such cases, we hereby inform you that we transfer your data with the appropriate safeguards while always maintaining the security of your data, as we use the most suitable tools for international data transfers, such as the Standard Contractual Clauses or any other relevant supplementary measure. You can read the contents of the Standard Contractual Clauses at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
Furthermore, if you decide to use the Platform in different markets (i.e., creating registered user accounts in different markets using the same email address), we may need to disclose or transfer the information linked to your account or your activity to the companies of the brand operating in such markets, to the extent that they are directly involved in achieving any of the objectives described in Section 2. We consider this necessary to satisfy our mutual interests and preferences.
- WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?
We undertake to respect the confidentiality of your personal data and to ensure that you can exercise your rights. The Joint Controllers have agreed that you may exercise them at no cost whatsoever by sending us an email to a single email address [email protected], stating the reason for your request and the right you wish to exercise Should we deem it necessary to identify you, we may ask you for a copy of a document verifying your identity.
Likewise, we may offer you the possibility to exercise your rights and configure your privacy preferences when using some of our services or making specific channels on our Platform available to you.
In particular, regardless of the purpose or lawful basis by virtue of which we process your data, you have the right to:
- Request access to the data we have on you. We would like to remind you that if you’re a registered user of the Platform, you may also view this information in the section corresponding to your personal data.
- Ask us to rectify any data that we already have. Remember that if you’re a registered user of the Platform, you may also access the section corresponding to the personal data in your account to modify or update your personal data. In any case, bear in mind that, by actively providing us with your personal data through any means, you guarantee that they are true and accurate and you undertake to notify us of any change or modification to them. Users shall be solely liable for any loss or damage caused to the Platform or the owner of the Platform or any third party as a result of providing any wrong, inaccurate or incomplete information in the sign-up forms. Please remember that, as a general rule, you should only provide us with your own personal data and not those of third parties, except as permitted in this Privacy and Cookies Policy.
- Ask us to delete your data when they are no longer necessary for the purpose for which we needed to process them as we’ve informed you above, or when we no longer have a lawful basis to do so.
- Ask us to restrict the processing of your data, which involves asking us to temporarily suspend the processing of your data or keep them longer than necessary in certain cases when you need us to.
If you’ve given us your consent to process your data for any purpose, you also have the right to withdraw this consent at any time. Some of the ways you can withdraw your consent are explained in Section 2, where we explain the purposes for which we process your data.
Whenever the lawful basis for our processing of your data is your consent or the performance of a contract, as explained in Section 3, you have the right to request the portability of your personal data. This means that you have the right to receive the personal data you’ve provided us with in a structured, commonly used, machine-readable format, in order to directly transfer them to another controller, whenever it is technically possible.
Furthermore, whenever the lawful basis for the processing of your data is our legitimate interest, you’ll also have the right to object to the processing of your data.
Lastly, we hereby inform you of your right to file a claim with the competent supervisory authority for data protection matters, which, in this case, is the Spanish Data Protection Agency (https://www.agpd.es/portalwebAGPD/index-ides-idphp.php).
- WHAT HAPPENS IF YOU PROVIDE US WITH THIRD-PARTY DATA OR A THIRD PARTY HAS PROVIDED US WITH YOUR DATA?
We provide features or services that require us to process third-party data that you as a user or customer provide us with, such as the activation and delivery of a Gift Card (in case this option is available), or when you authorize a third party to collect an order from our stores or partner establishments. If you provide us with third-party personal data or if it is necessary for you to provide us with them for a third party to collect an order on your behalf, you hereby warrant that you have duly informed them of the purposes and the manner in which we need to process their personal data.
If a third party has provided us with your data or you yourself have provided them as a result of a feature or service requested by one of our users, we will use them to manage the feature or service involved in each case, for the purposes described in this Privacy and Cookies Policy, whose link we normally include in our communications.
- CHANGES TO THE PRIVACY AND COOKIES POLICY
We may modify the information contained in this Privacy and Cookies Policy whenever we deem it necessary. Should we do this, we will notify you of it through different means over the Platform (e.g., through a banner, pop-up or push notification), or we may even send you an email when the change in question is significant in terms of your privacy, so that you can review the changes, have a think and, as the case may be, object to them or opt out of a service or feature. In any case, we suggest that you review this Privacy and Cookies Policy from time to time in case there are any minor changes or we introduce any interactive improvements, as it serves as an ongoing source of information on our Website.
- INFORMATION ON COOKIES
BEFORE WE START…
INFORMATION ON COOKIES
What is a cookie?
A cookie is a small text file that a website, app or other platform stores on your computer, tablet, smartphone or any other similar device, with information on your browsing or usage, as a tag that identifies your device. Cookies are necessary to make browsing easier and to learn about the way users interact with platforms in order to improve them. They are also very useful in order to show advertisements according to the user’s preferences, as well as other purposes that will be described below. Cookies do not harm your computer or device.
When we talk about “cookies”, we’re also referring to other similar technologies that are installed and/or collect information on or about your device (such as flash cookies, web beacons or bugs, pixels, HTML5 (local storage), and SDK technologies for app formats. The term “cookies” is also applicable to the use of fingerprinting techniques, i.e., techniques combining information that help us to identify your device. From time to time, these technologies work with cookies to collect and store information, either to provide you with certain features or services on our Platform or to show you advertisements on third-party platforms, bearing in mind your browsing habits.
This explanation is a general idea of what we mean by cookies and is for information purposes only.
What types of cookies are there?
Please read this section as it provides you with an overview of the types of cookies that may be used in an online environment.
According to the owner of the cookies, they can be classified into:
- First-party cookies: These are sent to the user’s computer or device from a computer or domain managed by the publishers themselves and from which the platform or the service requested by the user is provided.
- Third-party cookies: These are sent to the user’s computer or device from a computer or domain that is not managed by the publisher, but instead by another organization that processes the data obtained through the cookies.
According to the purpose of the cookies, they can be classified into:
- Strictly necessary cookies (technical): These cookies allow the user to browse the website, platform or application and use the different options or services that it provides, such as controlling traffic, identifying data or the session, accessing restricted-access sections or content, remembering the items comprising an order, completing the order purchase process, managing payment, controlling fraud linked to the security of the service, using security elements while browsing, completing a request to sign up or participate in an event, storing content to broadcast videos or audio, enabling dynamic content (such as animation when loading a text or image) or sharing content via social media. As they are strictly necessary, technical cookies are downloaded by default when they are allowed to show the platform or provide the service requested by the user.
- Functionality and personalization cookies: These cookies make it possible to remember information so that the user can access the service or platform with certain characteristics that may differentiate their experience from that of other users such as the language, the number of results to be shown when the user performs a search, the appearance or content of the service according to the type of browser used by the user or the region from where they’re accessing the service, etc. Choosing not to allow these cookies may lead to the website running slowly or showing ill-suited recommendations.
- Analytics cookies: These cookies make it possible to quantify the number of users, the sections visited on the platform and how they interact with it, in order to measure and perform statistical analyses on how users use the platform in order to introduce improvements based on the analysis of the usage data for the platform or service.
- Behavioral advertising cookies: These cookies store users’ behavioral data obtained by continuously observing their browsing habits, which makes it possible to generate a specific profile so that advertising can be displayed in accordance with it. These cookies make it possible to manage – in the most effective way possible – the advertising spaces that, as the case may be, the publisher has included directly or in collaboration with third parties.
Cookies are an essential part of how our Platform operates. The main purpose of our cookies is to make your browsing experience as smooth and efficient as possible. For example, they are used to remember your preferences (language, country, etc.) while browsing and on future visits. We also use our cookies to continuously improve our services and the Platform, as well as show customized advertisements according to your browsing habits.
The information collected by the cookies also allows us to improve our Platform through estimates of statistical data and usage patterns (number of visits, most visited sections, time of visit, etc.), to get statistics on how users interact with the Platform in order to improve our services, as well as adapt the Platform to your individual interests, accelerate searches, etc.
In any case, we will never store sensitive information such as passwords, credit or debit card details, etc. in the cookies we use.
You can access the cookie settings panel on our Platform at all times and obtain all the information on the cookies used by this Platform, together with the information on the purpose, duration and management (first-party or third-party) of each cookie. You can enable or disable all cookies that are not strictly necessary for the Platform to run smoothly.
Alternatively, in case you’re browsing the Internet, you may disable cookies on your browser. Here’s how you can do this on the most popular browsers:
- Google Chrome
- Internet Explorer
- Mozilla Firefox
You may opt out of using cookies at any time.
Please bear in mind that changing your cookie settings and choosing to opt out of cookies are specific to each browser you’re using. Therefore, if you choose to set cookies in a certain way on a device and you want the same thing for another device, you’ll have to enable the same option for the other device yourself.
As an additional step, with regard to third-party cookies for the purpose of showing you advertisements based on your interests, please bear in mind that certain third parties may be members of some of the self-regulatory schemes regarding online behavioral advertising, with the relevant opt-out options:
- Network Advertising Initiative (NAI) - http://www.networkadvertising.org/choices/
- Google Analytics - https://tools.google.com/dlpage/gaoptout
Who uses the information stored in cookies?
The information stored in cookies on our Platform is solely used by Us, except for those identified in Section 2 as “third-party cookies”, which are used and managed by external organizations to provide us with services intended to improve our services and the user experience when browsing our Platform. More information is available in the cookie setting panel on our Platform at all times.