Privacy Policy
How and why we use your data

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PRIVACY POLICY


Last updated March 01, 2021


This privacy notice for UKCOA LTD. (doing business as Zethora) ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

• Visit our website at ukcoa.co.uk, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? 
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

If you still have any questions or concerns, please contact us at [email protected].



SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?
We do not process sensitive personal information.

Do we receive any information from third parties?
We do not receive any information from third parties.

How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
Learn more about how we process your information.

In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties.
Learn more about when and with whom we share your personal information.

How do we keep your information safe?
We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Learn more about how we keep your information safe.

What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
Learn more about your privacy rights

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. LINKS TO OTHER WEBSITES AND THIRD PARTIES
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. ANALYTICAL BEHAVIOR TRACKING
11. CONTACT FORMS AND LIVE CHAT
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW TO CONTACT US ABOUT THIS NOTICE
15. COOKIES POLICY


1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us
In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:



Sensitive Information.
We do not process sensitive information.

Payment Data.
We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe and PayPal.
You may find their privacy notice link(s) here: stripe.com and paypal.com.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To deliver and facilitate delivery of services to the user.  We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.

To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. 

We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a Contract.

We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests.

We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:



Legal Obligations.

We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests.

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information in specific situations described in this section and/or with the following third parties. We may need to share your personal information in the following situations:

Business Transfers.

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. LINKS TO THIRD PARTIES

We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organisational and technical security measures.We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age.We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

9. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying 'STOP' or 'UNSUBSCRIBE' to the SMS messages that we send, or by contacting us using the details provided in the section 'HOW TO CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies:

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at [email protected].

10. ANALYTICAL BEHAVIOUR TRACKING

We use the following services to track your visits to our site and your interactions with the website so we can improve the usability of the site and quickly identify any issues.

Google Analytics
We use Google Analytics, a service that transmits website traffic data to Google servers located in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in accordance with Google's Privacy Policy. You have the option to opt out of Google Analytics by disabling or refusing the cookie, disabling JavaScript, or utilizing the opt-out service provided by Google.

Hotjar Website Heatmaps
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. See the Hotjar privacy policy here: hotjar.com/legal/policies/privacy

Cloudflare Insights
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

The way Cloudflare is integrated means that it filters all the traffic through this website, i.e., communication between this website and the User's browser, while also allowing analytical data from this website to be collected. You can find Cloudflare's privacy policy here: cloudflare.com/privacypolicy

11. CONTACT FORMS AND LIVE CHAT

Jotform Contact Forms
We use JotForms on this website for the contact and application forms. Our website links to JotForms or uses plugins from the jotform.com site operated by JotForm Inc. The operator of the site is JotForm Inc, 111 Pine St. Suite 1815, San Francisco, CA 94111, USA. When you enter text and click the SEND button in the corresponding form box, this data is transmitted to JotForms and stored on the European servers of JotForm Inc. When you visit one of our pages equipped with a Jotform plugin, a connection is established to the servers of JotForm Inc. In doing so, the JotForm server is informed which of our pages you have visited. See Jotforms privacy policy here: jotform.com/privacy

Tawk.to Live Chat
Data recorded via live chat is held on the live chat platform provided by Tawk.to. This is their privacy policy. Tawk.to makes use of cloud hosting provided by Google. Tawk.to complies with Google’s terms and model contract clauses that cover compliance with UK and EU data protection law.

We will process personal information you provide via live chat in line with our Data Protection Policies and in line with your rights under the EU General Data Protection Regulations currently applicable in the UK.

To enable us to assist it may on occasion be helpful to have name and contact details. Our preference is that you do not share sensitive or personal information via live chat. We retain a copy of the transcript for training and reporting purposes only, for a duration of up to 2 years except upon explicit request for deletion; if used in this way all information is anonymised.

Only specified live chat operators working within UKCOA can see your live chat communication. We do not share any information from your live chat communication with anyone outside UKCOA.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. HOW TO CONTACT US ABOUT THIS NOTICE?

If you have questions regarding this notice, contact us by post at:

UKCOA LTD.
Unit A, 82 James Carter Road
Mildenhall, Suffolk IP28 7DE
United Kingdom



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15. COOKIES POLICY

We use cookies and other tracking technologies to collect and store your information.

In this Cookie Policy we will provide you with detailed information on how UKCOA (hereinafter - the "we" or "our"), shall undertake to ensure the security of personal information and the protection of rights of the visitors and users of the websites (hereinafter - the "Visitors", "You") while you use our websites including but not limited to ukcoa.co.uk, ukcoa.com and zethora.com (hereinafter - the "Site") and the content on it.

1. What is a cookie?
A cookie is a small file placed onto your device that enables our Site features and functionality. For example, cookies can enable us to identify your device and secure your access to the Site. Cookies also allow the Site to remember information about your browsing on the Site for a while and to recognize you the next time you visit the Site. All this allows us to give you the opportunity to use the Site comfortably and to make the Site even more user-friendly.

2. Why do we use cookies?
We use cookies for the following main purposes:

• To ensure efficient and safe functioning of the Site. We use cookies to enable and support our security features, and to help us detect malicious activity on our Site.

• To analyse your habits so that the functioning of the Site would be convenient, efficient and would conform to your needs and expectations.

• To measure the flows of the information and data being sent to our Site. We use the cookies for accumulation of statistical data about the number of users of the Site and their use of the Site.

3. What cookies do we use?
Each time you visit our Site, the long-term (persistent) cookies may be created, which stay in your browser after you sign-up and will be read by us when you return to our Site and not deleted after you finish browsing our Site, and the short-term (session) cookies, which expire or are deleted after you finish browsing our Site (i.e. they usually last during the current visit to our Site or browsing session).

Cookies used by the Company:

• Strictly required or necessary cookies. These cookies are required for the operation of our Site. They include, for example, cookies that enable storage of information filled by you during the browsing session, enable you to log into secure areas of our Site. Without these cookies operation of the Site would be impossible or its functioning may be severely affected.

• Analytics and Statistics. These cookies show us if the Visitor has visited our Site before. The analytic cookies allow us to recognize and count the number of users of our website and see how such users navigate through our Site. We also use cookies to understand, improve, and research products, features, and services. For instance, analytical cookies may show us, which websites are visited more frequently, help us to record dysfunctionalities of the Site, etc.

• Third-party cookies:
Other third-party cookies - in some web pages of our Site, the other entities (for example, social networks) may also use their own anonymous cookies designed so that the programs or applications developed by them would suit your needs. Due to the specific features of the functioning of the cookies, our Site does not have access to the information transmitted by these cookies, likewise other entities do not have access to the information collected by the cookies set by us.

4. How to refuse or block cookies?
Many web browsers are set so that they would automatically accept all cookies. You may refuse and make a preference which cookies you allow by choosing it in our Cookie Consent Banner. Also all the cookies will be set if you accept all by clicking "Accept" on our Cookie Consent Banner. The Visitors may, at their discretion, manage, block or delete cookies, if the settings of their browser or device enable them to do so. Nevertheless, if you refuse or block the cookies or other similar technologies, some functions of the Site may be inaccessible to you or they may operate not properly. We draw your attention that necessary cookies are critical for functioning of our Site, and in case of your objections, some features of the Site may not work or may not work properly. You may require that we delete all the data about you, as collected and processed with the help of the cookies, by contacting the email address [email protected].

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