Last updated 1 August 2023
Who we are and what we do
We are Cuckoo Internet Limited (“Cuckoo”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 11926742 and we have our registered office at 6th Floor 33 Holborn, London, England, EC1N 2HT. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number ZA787344.
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.
The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to Contact Us’ section.
Who this privacy notice applies to
This privacy notice applies to you if:
- You visit our website
- You login and use "My Account" on our website
- You purchase goods or services from us
- You enquire about our products and/or services
- You sign up to receive newsletters and/or other promotional communications from us
What Personal Data is
‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation. Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
Personal Data we collect
The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes for which we use personal data and the legal bases’.
How we collect your Personal Data
We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website.
However, we may also collect your Personal Data from third parties such as:
- reputable companies who provide lead generation contact lists
- others to whom you have provided consent
- publicly available sources such as social media platforms
- sub-contractors in technical, payment and delivery services
- advertising networks;
- analytics providers; and
- search information providers
Purposes for which we use personal data and the legal bases
We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:
Lawful Basis for Processing
Responding to correspondence from you
It is in our legitimate interest to respond to enquiries made via our website, by email, through our social channels or any other means
Sending you information such as product information which may be of interest
If you are an existing customer or have expressed an interest in our products or services, we will rely on legitimate interests to contact you for marketing purposes. You may object to the processing for this purpose by emailing email@example.com. If we have captured your consent for the purposes of marketing, that consent may be withdrawn at any time by emailing firstname.lastname@example.org or using the unsubscribe option.
Provision of our services
Processing is necessary for performance of the contract between us
Business management, forecasting and statistical purposes
It is our legitimate interest to identify areas for managing current business relationships, develop new products and services, and for managing our business
Improving our websites and the overall website visitor and user experience
It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our websites
Improving our websites and the overall website visitor and user experience.
Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.
Sharing your Personal Data
We may also disclose your information to third parties in connection with other purposes set out in this privacy notice. These third parties may include:
- business partners, suppliers and sub-contractors who may process information on our behalf
- advertisers, social media platforms, and advertising networks
- analytics and search engine providers
- IT service providers
Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors, and/or, where we consider necessary to protect the rights, property or safety of Cuckoo, its personnel, users or others.
Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.
We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:
- Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation) or
- We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found at ico.org.uk)
How long we keep your data
We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.
At the end of the retention period, your personal data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.
How we protect your data
We implement appropriate technical and organisational measures to protect data against unauthorised or unlawful processing and against accidental loss, destruction or damage.
In addition to the technical and organisational measures we have put in place, there are simple things you can do to in order to further protect your personal information, such as:
- Never share One Time Passcodes (OTPs).
- Never enter your details after clicking on a link in an email or text message.
- Always send confidential information by encrypted email to reduce risk of interception.
- If you’re logged into any online service do not leave your computer unattended.
- Close down your internet browser once you’ve logged off.
- Never download software or let anyone log on to your computer or devices remotely, during or after a cold call.
- You can easily identify secure websites by looking at the address in the top of your browser which will begin https:// rather than http://.
Your data protection rights
You have certain rights in relation to the processing of your Personal Data, including to:
Right to be informed
Individuals have the right to be informed about the collection and use of their personal data.
Right of access
Individuals have the right to receive a copy of their personal data, and other supplementary information.
Right to rectification
Individuals have the right to have inaccurate personal data rectified or completed if it is incomplete.
Right to erasure (the ‘right to be forgotten’)
Individuals have the right to request their personal information to be erased, in certain circumstances.
Right to restrict processing
Individuals have the right to request the restriction or suppression of their personal data, in certain circumstances, in particular: - if your data is not accurate; - if your data has been used unlawfully but you do not want us to delete it; - if your data is no longer needed, but you want us to keep it for use in legal claims; or - if you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.
Right to data portability
Individuals have the right to obtain and reuse their personal data, in a machine-readable format, for their own purposes across different services, in certain circumstances.
Right to object
Individuals have the right to object to the processing of their personal data, in certain circumstances. Where we are using your personal data because it is in our legitimate interests to do so, you can object to us using it this way. Where we are using your personal data for direct marketing, including profiling for direct marketing purposes, you have an absolute right to ask us to stop doing so.
Rights with respect to automated decision-making and profiling
Individuals have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
In addition to the above, an individual also has the following rights:
Right to withdraw consent (if applicable)
Where we are using your personal data based on your consent, you can withdraw your consent at any time.
Right to lodge a complaint with a supervisory authority
You have the right to raise a complaint about how we handle your personal information with the Information Commissioner’s Office by calling 0303 123 1113 or visiting https://ico.org.uk/make-a-complaint/.
Exercising your data protection rights
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We do not offer our products and services to children, and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If you are under 18 years of age, you must not use our services. If we learn that a child has provided us with their Personal Data we will securely and permanently delete it, in accordance with applicable law.
How to contact us
If you would like to exercise your statutory data protection rights, or if you have any concerns or questions about how we handle personal data, please contact us using the details below:
Cuckoo Internet Limited
6th Floor 33 Holborn
London, EC1N 2HT
Our telephone number is +44 (0) 203 389 7211
Alternatively, you can email us at email@example.com.
We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian Limited and can be contacted as follows:
Using the above email or postal address, please send your communication clearly indicating ‘FAO the ‘Data Protection Officer’, your message will be passed directly to Evalian Limited for attention.
How To Complain
You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at https://ico.org.uk/make-a-complaint/ or by telephone on 0303 123 1113.
Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.