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.
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).
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:
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:
We also collect personal data in the following ways:
How we use your personal data
Purposes for which we will use your personal data
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register your account or a corporate customer's account
(a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Marketing and communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to perform a contract with a corporate customer)
To manage your account or a corporate customer's account, including purchases or orders made through that account
(a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Usage
(f) Marketing and communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to perform a contract with a corporate customer)
To send you or a corporate customer important information regarding the website, changes to this privacy policy, changes in terms and conditions, user agreements, and policies and/or other administrative information;
(a) Identity
(b) Contact
(c) Marketing and communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated)
To send you or a corporate customer relevant information about products and services available on our website, and marketing communications that Cogoport believes may be of interest to you or a corporate customer.
(a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Marketing and communications
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To respond to legal, judicial, quasi-judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law;
(a) Identity
(b) Contact
(c) Transaction
(d) Profile
(e) Usage
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to manage legal proceedings in which we are involved)
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.
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:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
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.
Your legal rights
You have the right to:
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