Privacy Policy

PRIVACY POLICY

Introduction

Cogoport respects your privacy and has provided this privacy policy to familiarise you with the types of personal data that we may collect and process about you. It also explains the purposes for which we collect your personal data, how we’ll store and handle that data, when and why we share your data with third-party service providers, and how the law protects you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

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Controller

Cogo Freight Pvt. Ltd (trading as Cogoport) is the controller and responsible for your personal data (collectively referred to as ‘we’, ‘us’ and ‘our’ in this privacy policy).

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Contact Details

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below.

Our full details are:  

Full name of legal entity:  Cogo Freight Pvt. Ltd

Email address:  support@cogopport.com

Postal address:  Cogoport, 7th floor, Pinnacle Business Park

Mahakali Caves Road, Andheri East

Mumbai,

India - 400093

You have the right to make a complaint at any time to the Dutch Data Protection Authority (https://autoriteitpersoonsgegevens.nl/). We would, however, appreciate the chance to deal with your concerns before you approach the Dutch Data Protection Authority so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on July 29th, 2020 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or use of your personal data. When you leave our website, we encourage you to read the privacy notice of every website you visit.

What personal data do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, business contact information (such as job title, department and organization name) and Government-issued identification documents.
  

• Contact Data including postal address, email address, telephone numbers, fax numbers.
  

• Transaction Data including bank account information, credit card, debit card or other payment instrument details, details about payments to you and from you and other details of products and services you have purchased from us.
  

• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
  

• Profile Data including your username and password to access our website, purchases or orders made by you, your interests, preferences, feedback and survey responses, and any content uploaded onto our website by you such as photos, articles or comments.
  

• Usage Data including information about how you use our website, products and services.
  

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Cogoport may obtain and aggregate technical and other data about your use of our site and services that is non-personally identifiable with respect to you (Aggregated Anonymous Data). Cogoport may use the Aggregated Anonymous Data to improve, support and operate the services which we provide. Aggregated Anonymous Data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any data about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.  In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

When do we collect your personal data?

We collect personal data when you:

• Access our website
  

• Register yourself or a corporate subscriber as a user or seller on our website.
  

• Use the services offered on the website, such as making an offer for sale, online purchase.
  

• Post user reviews on the items available on our website.
  

• Participate in an online survey or contest organized by us.
  

• Request marketing to be sent to you or a corporate entity.
  

• Communicate with our customer service team.

We also collect personal data in the following ways:

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
  

• Third parties. We may receive personal data about you from various third parties as set out below:
  

How we use your personal data

• We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  

• Where we need to perform the contract, we are about to enter into or have entered into with you.
  

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  

• Where we need to comply with a legal or regulatory obligation.
  

• Generally, we do not rely on consent as a legal basis for processing your personal data. Where we rely on consent, you have the right to withdraw consent at any time by contacting us.

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Purposes for which we will use your personal data

• We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
  

• Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• The following companies within the Cogoport group:

• Cogoport Europe B.V.
  

• Third party service providers who process personal data under our instructions.
  

• Payment service providers.
  

• Law enforcement or governmental agencies, judicial, quasi-judicial or any other statutory or constitutional authority
  

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within our company. This will involve transferring your data outside the European Economic Area (EEA).

Some of the third parties with which we may share your personal data are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented or that one of the conditions set out in Article 49 of the GDPR is met:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.  
  

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  

• Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  

If you wish to exercise any of the rights set out above, please contact us at:

Email address:  support@cogopport.com

Postal address:  7th Floor, Pinnacle Business Park

Mahakali Caves Road, Andheri East

Mumbai - 400093

India