Privacy policy
Our Privacy Policy explains who we are, how we process your personal data and what rights you have. Kooky (a trading name and registered trademark of I am Kooky Ltd) takes your privacy seriously and we work to ensure that your privacy is protected.
This privacy policy (the ‘Privacy Policy’) together with our website’s terms and conditions describes how and why we obtain, store and process data which can identify you. By visiting www.iamkooky.com (the ‘Site’) you are accepting and consenting to the practices described in this Privacy Policy. We may update this Privacy Policy from time to time and shall indicate on the Site when changes have been made.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
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We are responsible for your personal data
Kooky (registered trademark of I am Kooky Ltd) registered in The UK under company number 12327256 with its registered office at Heath Lodge, 4 St Albans Road, London NW5 1RD is the data controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise) and responsible for your personal data under applicable data protection law. We operate the Site. This privacy policy covers the use of our website and our business generally.
This website is not intended for children and we do not knowingly collect data relating to children.
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The personal data 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 as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, number of children and gender.
- Contact Data includes billing address, delivery address, email address, user ID on social media and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes 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.
We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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 information about criminal convictions and offences.
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How we collect personal data
Whether you are a customer of ours (or you work for a customer of ours) or you have registered to join our online community and to receive our newsletter or mail, or you just browse our website, we collect the following types of information about you when you:
- register an account with us (when we will collect Identity Data, Contact Data, Profile Data and Marketing and Communications Data);
- visit the Site (when we will collect Technical Data, and Usage Data);
- place an order with us (when we will collect Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data);
- correspond with us (when we will collect Identity Data, Contact Data and Marketing and Communications Data); and
- contribute to or use some of the advanced features on the Site (when we will collect Identity Data, Contact Data and Technical Data).
The information we collect when you register or place an order is clearly set out on the web page on which we collect it. We may collect information on your visits to our website and how you move around different sections of our website for analytical purposes to understand how people use our website. We may keep a record of the content on our website that you have clicked on.
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What we use personal data for
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; and
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw your consent to receive marketing materials at any time by contacting us.
The following is a description of all the ways we plan to use your personal data, the legal bases we rely on to do so and the legitimate interests that we are protecting by processing the data, where appropriate:
Purpose/activity
Types of data used, collected and/or processed
Lawful basis for processing including our legitimate interests
To register you as a new customer or to create a customer account
Identity Data, Contact Data, Profile Data and Marketing and Communications Data
To allow us to perform our contract with you.
To process and deliver your order including:
(a) manage payments, fees and charges;
(b) collect and recover money owed to us; and
(c) to communicate with you about your order
Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data
(a) To allow us to perform our contract with you.
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
Identity Data, Contact Data, Profile Data and Marketing and Communications Data
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, keeping the Site safe and secure, reporting and hosting of data)
Identity Data, Contact Data and Technical Data
(a) Necessary for our legitimate interests (for running the Site, 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data and Marketing and Communications Data
Necessary for our legitimate interests (to study how customers use our products/services and the Site, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve the Site, products/services, marketing, advertising, customer relationships and experiences
Usage Data and Technical Data
Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Identity Data, Contact Data, Profile Data, Usage Data, Technical Data and Marketing and Communications Data
Necessary for our legitimate interests (to develop our products/services and grow our business)
To personalise your use of the Site
Identity Data, Profile Data, Usage Data and Technical Data
Necessary for our legitimate interests (to develop our products/services and grow our business and to make our site more engaging for our users)
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.
Our marketing communications may involve the use of cookies, which is explained below under our cookie policy.
If you are an existing customer, we will only contact you by electronic means (e-mail, social media account or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or if you do not want us to pass your details on to third parties for marketing purposes, please ensure that you do not opt in to these services on the form on which we collect your data. You can always opt-out in your user area or by selecting ‘unsubscribe’ in any email communication sent to you.
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.
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Non-provision of 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 (for example, to provide you with goods or services). 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.
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How long we keep your personal data
We process and keep your personal data only for so long as is necessary for the purpose(s) for which it was originally collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
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, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see ‘Your rights’ below for further information. 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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Who we disclose it to
In certain circumstances we may need to disclose information about you if you breach this Privacy Policy or if you breach the terms and conditions of the Site. We may also disclose your personal data to appropriate third parties who reasonably need to know including:
- our business partners, customers, suppliers and subcontractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- our auditors, legal advisors and other professional advisors or service providers;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy; and
- the prospective buyer or seller of our business in the event that we sell or buy any business assets, in which case we may disclose your personal data to of such business or assets subject to the terms of 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.
We may, in certain circumstances, be under a duty to disclose or share your personal data in order to comply with a legal obligation, or in order to enforce or apply our terms of supply and other agreements with you or the person that you work for or to protect the rights, property, or safety of our business or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, or credit risk reduction.
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Where we store your personal information
The data that we collect from you will be transferred to and stored in the UK and in the European Economic Area ("EEA"). It will also be processed by staff operating in the UK and in the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Any such transfer of your personal data will be carried out in compliance with applicable laws.
We do not transfer your personal data outside the European Economic Area (EEA).
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Security
Keeping information about you secure is very important to us and certain sections of the Site may encrypt data using SSL or a comparable standard. However, no data transmission over the Internet can be guaranteed to be totally secure. As a result, whilst we strive to protect your personal information, we cannot ensure or warrant the security of any information which you send to us, and you do so at your own risk.
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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Your rights
You have the right to request information about the personal data we hold on you at any time. If your data is incorrect, incomplete or irrelevant, you can ask to have the information corrected or removed. We are not obliged to remove your data when there is a legal storage requirement, such as bookkeeping rules or when there are other legitimate grounds to keep the data, such as unsettled debts. You can withdraw your consent to us using the data for marketing purposes at any time. You can contact us by sending an email to info@iamkooky.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions or complaints relating to this Privacy Policy or how we use the personal information we have about you, please contact info@iamkooky.com. We will do our upmost to respond to you promptly.
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Other Links
The Site may contain links to other sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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Updates to this Policy
Any changes we make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.
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Cookies
A cookie is a small amount of data sent from our server and stored on your computer's hard drive if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use Google Analytics cookies on the Site. These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited.
You can choose to disable or manage cookies. Most internet browsers are automatically set up to accept cookies, but you can set your browser to refuse a cookie or ask your browser to show you where a cookie has been set up. Certain services are only activated by the presence of a cookie and, if you choose to refuse cookies, particular features of our Site may not be available to you. Find out how to disable/enable cookies on the following link http://www.allaboutcookies.org.
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Contact Us
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: I Am Kooky Ltd
Email address: info@iamkooky.com
Postal address: Office 39052, PO Box 6945, London, W1A 6US
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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Date of this policy
We keep our privacy policy under regular review. This policy was last updated on 28 June 2021.