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PRIVACY POLICY

Introductory provisions

Coconut Matter Limited (hereinafter "Service", “we” or “us”) treats everything that is related to personal data with respect and integrity. We are committed to safeguarding the privacy of our website, of our services as data protection is of a particularly high priority for the management of our company.

It is very important for us to accurately inform the users of this website about our Privacy Policy, so in the following, we provide you with precise information on what kind of data we collect from you, how we use it, for what purpose we use it and what your rights are, in this context.

First, we need to define, and it is important for you to understand, the expression: "Personal Data". It generically represents any kind of information about a physical person, whose particularities can lead, directly or indirectly, to its identification. Here you have, by way of example, but not limited to: name and surname, geographical address, any identification number, political orientation, sexual orientation, email address, any location information and any other online identifier such as the device used to access the Internet, IP address, or cookie information.

With regards of your agreement regardingthe collection and use of personal data, we have taken all the necessary technical measures to provide you with this detailed agreement, so you can have a crisp clear experience, from the first to the last interaction with our website or our services.

Visitors and Users agree and accept that the use of our website is not possible without any indication of personal data.

Definitions

Our data protection policy should be legible and understandable for the general public, as well as for our Users and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

  • Data Subject or Data Principal - is any identified or identifiable natural person, whose personal data is collected and processed by us.
  • Processing - is any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, etc.
  • Restriction of processing - is the marking of stored personal data with the aim of limiting their processing in the future.
  • Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person.
  • Data Controller or Data Fiduciary - is the natural or legal person, public authority, agency or other body, which determines the purposes and means of the processing of personal data;
  • Processor - is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  • Recipient - is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed. The processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
  • Third party - is a natural or legal person, public authority, agency or body other than the ones above, who, under the direct authority of the controller or processor, are authorized to process personal data.
  • Consent - is any freely given, specific, informed and unambiguous indication of data subject’s acceptance to the processing of their personal data.

Compliance

The processing of personal data will be in line with these main international legislations:

  • Hong Kong’s Personal Data (Privacy) Ordinance (PCPD)
  • General Data Protection Regulation (GDPR), applicable in Europe;
  • California Consumer Privacy Act (2018) and Privacy Act U.S.C. 552a (Privacy Act of USA);
  • Australian Privacy Principles contained in the Privacy Act 1988;
  • Indian Personal Data Protection Bill (2018)
  • Privacy Acts in Latin America;
  • Any other country-specific data protection regulations are applicable.

 

We sell our products and services worldwide. For the purpose of avoiding any compliance conflict with any terminology used by any particular legislation, in this document: ”Users” are the ”data subjects” or the ”data principals” and CoccontMatter Limited is the ”data controller” or ”data fiduciary” 

By this Privacy Policy we clearly explain:

  1. What Personal Data we collect and why we collect it;
  2. How we use Personal Data;
  3. Who we share Personal Data with;
  4. The choices we offer, including how to access, update, and remove Personal Data;

 

By means of this data protection declaration, our company would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. This document describes the protection of our users and Users personal data.

Coconut Matter Limited collects, stores, uses and discloses certain information when the visitors use our website.As a data controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website.

Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you will not receive direct marketing communications and will limit the publication of your information.

In your relationship with us through the website, controller, for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection, is:

Coconut Matter Limited, Room C6, 4/F, E-Tat Factory Building, 4 Hueng Yip Road, Wang Chuk Hang, Aberdeen, Hong Kong

This Policy does not apply to other companies’ or organizations’ sites to which we may link to or may link to us. You should carefully review the privacy policies of those sites in order to determine how they treat your personal information.

If you do not agree to this Privacy Policy, please exit, and do not access or use our website.

We have kept this simple for your understanding, but if you’re not familiar with terms like “cookies” or “IP addresses,” feel free to contact us. Your privacy is really important to us, so whether you’re new to Coconut Matter Limited or a long-time user, please take the time to get to know our practices.

Use Cases

Please take a moment to understand which use case(s) set out in this Privacy Policy apply to you:

  • Website Visitor

You are a “Website Visitor” by definition when you visit our websitehttps://cocconutmatter.com and any other eventual subdomains associated with our principal domain.As a website visitor, we use your information for our own purposes,primarily for improving the use of our website and to provide you with more relevant content.

  • User

You become a “User” if you create an account on our website in order to buy one of our products or services. If you are a User, our primary purpose of using your personal data is for providing the service and the services to you. We retain your personal information for a limited time and for limited purposes, such as to make it easier for you to re-join our service in the future or to wish you offers for services that we think you may be interested in.

What Personal Data we collect and how do we collect it

In this Section we have set out:

  • the general categories of personal data that we may process;
  • in the case of personal data that we did not obtain directly from our Users, the source and specific categories of that data;
  • the purposes for which we may process personal data;
  • the legal bases of the processing.

 

All Personal Data that is collected through the use of the website is stored on secure servers provided by Shopify, as service providers. For more information about the way information is stored and secured by our service providers, please visit https://www.shopify.com/legal/privacy.

Upon acquisition of our services, we will ask for your full name and a valid e-mail address, which will be included in our mailing list, for future maintenance, updates, and eventual marketing promotions. In addition, we will ask you to provide us with secure payment data, which will be used for processing the order. This particular set of data will be legally processed by our payment processor, and will not be stored by us.

We may process data about your use of our website and services, or the User’s website ("usage data"). The usage data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services.

We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

We may process information contained in any inquiry you submit to us regarding services and/or services ("inquiry data"). The inquiry data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

We may process information relating to our User relationships, including User contact information ("User relationship data"). The User relationship data may include your name, your employer, your job title or role, all your contact details, and information contained in communications between us and you or your employer. The User relationship data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our services ("transaction data"). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

“Automatically Collected" Information: The website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files, and it is collected regardless of your quality: Website Visitor or User.

Note: no personal information is collected through the service (plugin) itself. Coconut Matter Limitedonly collects purchase codes, website URL, plugin version and WordPress version strictly for providing services.

Collected may be:

  • the ISP,
  • the operating system used by the accessing system
  • the website from which an accessing system reaches our website (so-called referrers)
  • the sub-website
  • the date and time of access to the website
  • an Internet Protocol address (IP address)
  • screen Resolution
  • locale Preferences
  • web page visited before you came to our website
  • information you search for on our website
  • date and time stamps associated with transactions
  • system configuration information and other interactions with the website.
  • social networking information (if we are provided with access to your account on social network connection services);
  • any other similar data and information that may be used in the event of attacks on our information technology systems.

 

When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to:

  • deliver the content of our website correctly;
  • optimize the content of our website as well as its advertisement;
  • ensure the long-term viability of our information technology systems and website technology;
  • provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack;

 

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

Obviously, the access to our website for website visitors is free; however, we inform you that for the use of the website via mobile device the charges and the standard tariffs provided in the service contract that you have stipulated with them will still be applied by the telephone operators.

How we use your personal information

We use the Order Information that we collect generally to fulfill any orders placed through the website (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). 

Additionally, we use theinformation:

  • to screen our orders for potential risk or fraud;
  • when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services;
  • communicate with you about our Services, including to tell you about products and services that may be of interest to you
  • respond to your requests, inquiries, comments, and suggestions;
  • facilitate your engagement with the Services, including to enable you to post comments and reviews;
  • offer contests, sweepstakes, or other promotions;
  • conduct or administer surveys and other market research;
  • protect against, identify, investigate, and respond to fraud or other illegal activity.

 We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our website (for example, by generating analytics about how our customers browse and interact with the website, and to assess the success of our marketing and advertising campaigns).

Use and Disclosure of personal data to others

We do not rent or sell your information to third parties outside of Coconut Matter Limited without your consent. We may share your information, as well as information from tools such as cookies or similar, with third-party organizations that help us provide you with the services, but only as far as is reasonably necessary.

Compliance with Laws and Law Enforcement Requests: We may disclose to parties outside Coconut Matter Limited, files stored in our database and personal data about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; or (b) to protect Coconut Matter Limited’s intellectual property rights. If we provide your Files to a law enforcement agency as set forth above, we will remove Coconut Matter Limited’s encryption from the files before providing them to law enforcement.

Business Transfers: In case we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction, but we will notify you and/or your organization (for example, via email and/or a prominent notice on our website) of any change in control or use of your personal data or Files, or if either become subject to a different Privacy Policy.

In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We share your Personal Information with third parties to help us use your Personal Information, as described above.  For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.  We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here:https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

We can access your information as well as store and share it in response to a request when the law requires us to do so. In addition, we may access your information, as well as store and share it, if we believe in good faith that this is necessary to: detect, prevent and manage fraud and other illegal activities; protect ourselves, you and other people, even in the context of any investigations; prevent events that could cause imminent physical damage or death

Behavioural advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by visiting the following links depending upon the service(s) you are using:

    FACEBOOK - https://www.facebook.com/settings/?tab=ads

    GOOGLE - https://www.google.com/settings/ads/anonymous

    BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

For information on how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit:http://optout.aboutads.info/.

European users may opt out of receiving targeted advertising through theEuropean Interactive Digital Advertising Alliance.

Additionally, you can opt out of some of these services by visiting the Digital AdvertisingAlliance’s opt-out portal at:  http://optout.aboutads.info/.

 

Links to Other Websites

The Platform may, from time to time, contain links to and from the Platforms of advertisers and affiliates. The fact that Coconut Matter links to a websites is not an endorsement, authorization or representation of Coconut Matter affiliation with that third party. Coconut Matter does not exercise control over third party websites. These other websites may place their own cookies or other files on the User’s device, collect data or solicit personally identifiable information from the User. If the User follows a link to any of these third party websites, he does so at his own risk, these Applications have their own privacy policies and he waives any claim against Coconut Matter for any responsibility or liability for these policies.

 Personal Data Breaches

Sub-processor will notify the Controller as soon as possible after it becomes aware of any Personal Data Breach affecting any Personal Data. At the Controller’s request, Sub-processor will promptly provide the Controller with all reasonable assistance necessary to enable the Controller to notify relevant Personal Data Breaches to competent authorities and/or affected Data Subjects, if Controller is required to do so under the Data Protection Law.

 Data Subject Requests

If it is the case, sub-processor will provide reasonable assistance, including by appropriate technical and organizational measures and taking into account the nature of the Processing, to enable Controller to respond to any request from Data Subjects seeking to exercise their rights under the Data Protection Law with respect to Personal Data (including access, rectification, restriction, deletion or portability of Personal Data, as applicable), to the extent permitted by the law. If such request is made directly to sub-processor, it will promptly inform Controller and will advise Data Subjects to submit their request to the Controller. The controller shall be solely responsible for responding to any Data Subjects’ requests. The controller shall reimburse sub-processor for any potential costs arising from this assistance.

 Privacy of minors

We do not collect or consciously request information from Users under the age of 18, nor do we consciously allow such Users to register with our services, except with parental consent. Our services and their contents are not intended for children under the age of 18.

If we learn that we have collected personal information from a child under the age of 18 without parental consent, we will delete this information as soon as possible.

If you believe we have any information about a child under the age of 18, please contact us.

Cookies and Tracking Technologies

Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which internet pages, servers or apps can be assigned to the specific app or server in which the cookie was stored.

Through the use of cookies, Coconut Matter Limited can provide the Users of this website with more User-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our websites can be optimized with the User in mind. Cookies allow us, as previously mentioned, to recognize our website Users. The purpose of this recognition is to make it easier for Users to utilize our websites. The website's User that uses cookies e.g. does not have to enter access data each time the website is accessed, because this is taken over by the websites, and the cookie is thus stored on the User's computer system.

We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Application.

Some web browsers may transmit “do-no-track” signals to websites with which the browser communicates.

Our website does not currently respond to these “do-not-track” signals.

Strictly necessary cookies

These cookies are essential, as they enable you to move around the Site and use its features, such as accessing secure areas. Without these cookies, some services you have asked for, such as payment submission, can’t be provided.

Performance cookies

These cookies collect information about how you use the website, for example, which pages you go to most often and if you get error messages from certain pages. These cookies don’t gather the information that identifies you. All information these cookies collect is anonymous and is only used to improve how the Site works.

Functionality cookies

These cookies allow the Site to remember choices you make (such as your user name, language or the region you’re in). For instance, the Site uses functionality cookies to remember your language preference. These cookies can also be used to remember changes you’ve made to text size, font and other parts of pages that you can customize, or any kind of form that you left in between or unsubmitted. They may also be used to provide services you’ve asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites.

Targeting cookies

These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. They remember that you have visited a website and this information may be shared with other organizations such as advertisers. This means after you have been to the Site you may see some advertisements about our services elsewhere on the Internet.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the browser or app, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time. If the user or the visitor deactivates the setting of cookies in the browser or app, then not all functions may be entirely usable.

We use automatically collected information and other information collected during the Services through cookies and similar technologies to:

(i)         personalize our Service, such as remembering a User’s or Visitor’s information or login details so that the User or Visitor will not have to re-enter it during a visit or on subsequent accessing;

(ii)        provide customized content and information;

(iii)       monitor and analyze the effectiveness of websites and third-party activities;

(iv)       monitor site usage metrics such as the number of visitors.

Data Quality

We will take reasonable steps to ensure that personal information we have about you is accurate, complete and up to date when we use it. Generally, we rely on you to assist us in keeping your personal information accurate and up to date.

Data Security

We have taken reasonable steps to keep your personal information secure at all times and in accordance with our Information Security Policies.

We also take steps to reasonably protect your personal information from misuse and loss, unauthorized access, modification or disclosure and maintained in an accurate, complete and up-to-date manner.

Openness

We will be honest and open with you about the type of personal information that we collect about you and the actual use of any such information. We will let you know at the time we collect your personal information, or soon after, how we will treat it.

If you require any details of the personal information held by us about you, then please contact us by e-mail.

Opting out from Communications

If you receive emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “Contact” section.

Please be aware that if you opt-out of receiving emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Please note that you may still receive administrative messages from us regarding our Services.

Sensitive Information

We do not believe in an intrusive collection of your personal details and will not collect information that is considered highly personal or highly sensitive about you without your prior consent.

Data Retention and Data Deletion

We only retain the personal information collected from a User for as long as the User’s email address is active on our mailing list, or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the 2-year criteria, after your relationship with us ends.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Your rights

Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

(a)        the right to access;

(b)        the right to rectification;

(c)        the right to erasure;

(d)       the right to restrict processing;

(e)        the right to object to processing;

(f)        the right to data portability;

(g)        the right to complain to a supervisory authority; and

(h)        the right to withdraw consent.

 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us.

Complaints Resolution

We are committed to providing our Users with a fair and responsive system for handling and resolving complaints concerning the handling of their personal information. You have a right to complain and to have your complaint handled efficiently if you are concerned about our handling of your personal information.

If at any time you wish to lodge a complaint in respect of the handling, use or disclosure of your personal information by us, you may do so by contacting us directly.

We aim to investigate and advise you of the outcome of the complaint promptly.

If you are not satisfied with our handling of your complaint, you may contact the Data Protection Officer at:

care@coconutmatter.com

Amendments

We may update this policy from time to time by publishing a new version on our websites.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of significant changes to this policy by email, as a website notice or through the private messaging system within our service system.