Privacy Statement, Security & Cookies Policy
This Privacy Statement for COCULU Products and Services (“Privacy Statement”) describes information that COCULU company and its subsidiaries and affiliates (collectively, “COCULU”) collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).
This document focuses on information related to contractual services for the provision by COCULU of COCULU products and services to businesses and organisations through their respective representatives. In this Privacy Statement, the expression “COCULU Products” also includes our Web Apps, Mobile Apps, and Subscription Services as defined in our Terms of Use.
Our Pledge:
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We will be transparent about the different types of information we collect and how we use them.
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We will ask your permission before sharing your personal information with third parties for purposes other than at your request or to provide COCULU Products, and to do so only when we think they will provide you with a welcome additional service.
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We will use best-in-class data security tools to keep your data safe and protect the COCULU connected Products from unauthorised access.
Your Permission: Permission for data collection and processing. By using COCULU Products, you agree to allow us to collect and process information as described in this Privacy Statement.
International data transfers. Your personal information may be collected, processed and stored by COCULU or its service providers in the United Kingdom and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using COCULU Products in the European Economic Area or other regions with laws governing data collection and use that may differ from UK law, you agree to the transfer of your personal data to the United Kingdom and other countries where COCULU operates.
What information might COCULU collect?
Setup information you provide and COCULU records: When we install an COCULU device (the “device”), we’ll use a few pieces of information to create an initial device profile and program of settings that will keep your space optimally scented. For example, we’ll enter the time zone of the installation location, as well as where the device is located.
Usage information: Every time your system turns on and off, COCULU records the time and duration during which your system was on in order to offer you features such as usage history and otherwise optimise your scenting experience.
Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with the COCULU device, we record the model and serial number, software version, and technical information about the device’s performance.
How does COCULU use the information it collects?
We use information to provide, develop and improve COCULU Products and services, including to make assessments and recommendations about products and their performance. We may use your contact details to send you this information, or to ask you to participate in surveys about your COCULU use, and to send you other communications from COCULU.
We may also use this information in a non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we may use aggregated user information about the number of active COCULU users in a particular area, or the number of scent diffusion devices per user location.
We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.
We use industry-standard methods to keep this information safe and secure while it is transmitted over your network and through broadband networks or the Internet to our servers. Depending on your location and type of data, COCULU may process your personal information on servers that are not in your home country.
In general for purposes of applicable law (e.g., GDPR), COCULU is a controller of the information collected in connection with the Products and Services.
Our legal bases for processing information
If European data protection law applies to the processing of your information, we process your information for the purposes described in this Privacy Statement, based on the following legal grounds:
When we’re providing a product or service...
We process your data to provide and support a product or service you’ve asked for under a contract, including but not limited to delivering our Terms of Service.
When we’re pursuing legitimate interests…
We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:
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offering and improving COCULU Products and services
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developing new products and features
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understanding how people use our products and services
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performing research that improves our services for our users and benefits the public
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sending you direct marketing and other communications from COCULU
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protecting against harm to the rights, property, and safety of COCULU, our users, and the public
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detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services
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maintaining and improving the integrity of our computing systems, and protecting our users’ data security
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enforcing legal claims, including investigation of potential violations of applicable Terms of Service
When we’re complying with legal obligations…
We process your data when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.
We ask for your consent to process your information for certain specific purposes and give you the right to withdraw that consent at anytime.
In what circumstances does COCULU share my information?
Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of COCULU Products and services without asking you first. We do not rent or sell our customer lists. The following are the limited situations where we may share personal information:
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With your permission: We may share personal information when we have your permission. One example of this would be if you invite another user to access the Products on your account as an additional authorised user.
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For external processing: We have service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers for technical problems. These technicians (as well as COCULU employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non COCULU purposes.
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As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.
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For legal reasons: We will share personal information with third parties if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process or enforceable government request; (ii) enforce COCULU policies or contracts, including investigation of potential violations; (iii) detect, prevent or otherwise address fraud, security or technical issues; (iv) protect against harm to the rights, property or safety of EcoScent, our users or the public as required or permitted by law.
We may share non-personal information (for example, aggregated or anonymised customer data) publicly and with our partners. For example, we may publish trends about fragrance oil useage and scent diffusion levels in the spaces our Products are used. This information may also be shared with other users to help them better understand their fragrance oil usage compared to others in the COCULU community, or help us generally improve our system. We may also share non-personal information with our partners. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.
What choices do I have and how can I delete my personal information?
COCULU generally stores your personal information on COCULU's servers until you delete or edit it, or for as long as you remain a COCULU customer in order to provide you with COCULU Products. In addition, COCULU may store your personal information for a reasonable period of time after you are a COCULU customer to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.
As described above, some information is processed and stored directly on the COCULU device. This does not include personal information.
COCULU customers can also request their COCULU data by by emailing coculu@gmail.com.
Individual Rights in the European Economic Area.
If you are located in the European Economic Area, you may seek confirmation regarding whether COCULU is processing personal information about you, request access to your personal information and ask that we correct, amend or delete your personal information. In addition, you may object to COCULU's processing of your personal information at any time. However doing so may impact your use of the Products and Services.
If applicable law provides you the right to request access to, (receive) port, object to or restrict processing, seek rectification or request erasure of personal information held about you by COCULU, you may do so, as applicable, through controls in the COCULU application or by contacting COCULU. To protect your privacy, COCULU will endeavor to take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
Minors
Only individuals aged 18 and older are permitted to act as Owners or Authorized Users of COCULU Accounts. COCULU Products and Services do not knowingly collect or store any personal information from anyone under the age of 18.
Can the Privacy Statement be changed?
Please note that this Privacy Statement may change from time to time. We will provide notice of any changes on the website or by contacting you.
Use of Cookies
This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.
Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors. Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.