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Privacy Policy

Albacore Accounting Ltd trade as Cobia Accounting Ltd. Cobia Accounting (”We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company, its subsidiaries and our associated companies as defined in section 1159 of the UK Companies Act 2006.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course. Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is Cobia Accounting Ltd, 724 Capability Green, Luton, LU1 3LU.

1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website (including your email address);
(c) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters and/or whitepapers and other documents available for download from our website (including your name and email address);
(d) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication) and including Olark chat; and
(e) any other personal information that you choose to send to us.

3. Using personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) send statements, invoices and payment reminders to you, and collect payments from you;
(e) send you non-marketing commercial communications;
(f) send you email notifications that you have specifically requested;
(g) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(h) enable you to download information/white papers/documents you have requested;
(i) send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(j) deal with enquiries and complaints made by or about you relating to our website;
(k) keep our website secure and prevent fraud; and
(l) verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
3.3 We will not supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.4 Except as provided in this policy, we will not provide your personal information to third parties.

5. International data transfers
5.1 Information that we collect may be processed in the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: Pakistan and United States of America. Pakistan is for the purposes of sub-processing to enable us to provide the best possible service and at the best price, our sub-processor is ISO 27001 certified. The online software we use to administer your account may be based in the USA, wherever possible we strive to use sub-processors who operate within the EU-US privacy shield.
5.2 You expressly agree to the transfers of personal information described in this Section 5.

6. Retaining personal information
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Without prejudice to Section 6.2, we will usually delete personal data falling within 1 month.
6.4 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

7. Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password and firewall-protected) servers.
7.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. We routinely use secure file transfer services and recommend their use.
7.4 You are responsible for keeping the password you use for accessing your details on any accountancy online platforms up-to-date.

8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We will endeavour to email you when we make amendments to our privacy policy.

9. Your rights
9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport or driving licence certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
9.4 To exercise your rights please send an email to dpo@cobia-uk.com

10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. Data protection registration
12.1 We are registered as a data controller with the UK Information Commissioner’s Office.
12.2 Our data protection registration number is Z1865951.

13. Our details
13.1 This website is owned and operated by Cobia Accounting Ltd.
13.2 We are registered in England and Wales under registration number 06957928, and our registered office is at 724 Capability Green, Luton, LU1 3LU.
13.4 You can contact us:
(a) by post, using the UK postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using the email address published on our website.

14. Online privacy statement

Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
This privacy notice tells you how we, Cobia Ltd, will collect and use your personal data:
Session Cookies
We use a session cookie to remember what you’ve been viewing and the actions you have taken. If these are disabled, various functionalities of the site will be unavailable and you may not achieve the objective of your visit. More information on session cookies and what they are used for at www.allaboutcookies.org
Persistent Cookies (Google Analytics)
We use Google Analytics, a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us to analyse how users use the site. It counts the number of visitors and tells us things about their behaviour overall – such as the typical length of stay on the site or the average number of pages a user views.
The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google undertakes not to associate your IP address with any other data held by Google. You can find out more about Google’s position on privacy as regards its analytics service at www.google.co.uk/intl/en/analytics/privacyoverview.html
Complaints
In order for Cobia to process and respond to complaints we need to record name and email address.
Contact Forms
If you wish to engage us for our services we will need to record name, email address and contact telephone number.

For any privacy related queries or concerns, you may contact Cobia Accounting Protection Officer at dpo@cobia-uk.com