This Privacy Policy describes how www.tokoney.com and app.tokoney.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Collecting Personal Information

TOKONEY collects a certain amount of personal data about you on the Website and in the course of exchanges. Personal data is collected for the purposes of following up your requests for quotes or subscriptions, as well as for statistical and advertising purposes.

This personal information will be used and kept in accordance with the provisions of European Regulation 2016/679 of the Parliament and European Council (called “GDPR”), Users and Customers have a right to access, request, modify and delete information which concerns them, which them can exercise at any time with TOKONEY either by mail or by email at the following address: [email protected].

For security reasons and to avoid any fraudulent requests, this request must be accompanied by a proof of identity. This proof of identity will be destroyed upon request.

The information collected may be communicated to third parties linked to TOKONEY by contract. If you do not wish your personal information to be communicated to third parties, you can send an email to the following address: [email protected].

This information may be disclosed pursuant to a law, regulation or by a decision of a competent regulatory or judicial authority or, if necessary, by TOKONEY in order to preserve its rights and interests.

When certain information is mandatory in order to access specific features of the Website, TOKONEY will indicate this mandatory character at the data entry phase.

You are likely to receive commercial offers from TOKONEY or its partners. If you do not wish to receive such commercial offers, you can send an email to the following address: [email protected].

If, during the consultation of the Website, you gain access to any personal data, you must refrain from any collection, any unauthorized use and any act that may constitute an invasion of privacy or reputation of individuals. The Publisher declines all liability in this regard.

The person responsible for the processing of user data collected via the Websites is TOKONEY Ltd, Registered Company No. 12245258.

TOKONEY may transfer information about a Customer to its financiers, who:

1. may store and process, use, analyse and assess information about the Customer, including the nature of the transactions, and exchange such information with other members of their group of companies and other credit or financial assessment, market research, statistical analysis, insurance claim, underwriting and training purposes and in making payments and servicing their agreement with TOKONEY.
2. From time to time, may make searches of Customer’s record at credit reference agencies where the Customer’s record with such agencies may include searches made and information given by other businesses; details of their searches will be kept by such agencies but will not be seen by other organisations that may make searches; on their computers, the computers of any associated companies used by them and in any other way. This will be used by them for credit and financial assessments, in making payments, in recovering debts, for training purposes and preparing statistics. They may also use such information to prevent bad debts, fraud and money laundering;
3. From time to time may make searches of the Customer’s record at their credit reference agency where the Customer’s record with such agency may include searches made and information given by other businesses; details of these searches will be kept by such agency but will not be seen by other organisations that make searches with that agency;
4. May give information about the customer and its indebtedness to the following, for the purposes stated:
   1. Any associated company of theirs – to make credit or financial decisions and for statistical analysis;
   2. TOKONEY or their insurers for underwriting and claims purposes – to quote for and issue policy or to deal with claims;

• Any guarantor or indemnifier of the Customer’s or TOKONEY’s obligations to enable them – to assess such obligations;

1. Their bankers or any advisers acting on their behalf – to carry out our services to them;
2. Any business to whom the Customer’s indebtedness or TOKONEY’s arrangements with its financiers may be transferred – to facilitate such transfer;

1. May monitor and/or record any phone calls the Customer may have with them, for training and/or security purposes;
2. May make decisions about the Customer solely using automated decision-making process, such as credit scoring.

TOKONEY will provide the Customer with details of third parties referred to above from whom they obtain, and to whom they may give, information about the Customer. The Customer may apply in writing to receive a copy of the information held about the Customer. However, a fee may apply.

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared with our processor Shopify.

Order information

• Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
• Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
• Source of collection: collected from you.
• Disclosure for a business purpose: shared with our processor Shopify and our shipping partners.

Customer support information

• Purpose of collection: to provide customer support.
• Source of collection: collected from you.
• Disclosure for a business purpose: To our shipping partners
• If you request a password reset, your IP address will be included in the reset email.

 

Minors

The Site is not intended for individuals under the age of 16. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

• We use WordPress to power our online site. You can read more about how WordPress uses your personal information here: https://en-gb.wordpress.org/about/privacy/
• We use Bubble to power our online platform. You can read more about how Bubble uses your personal information here: https://bubble.io/privacy
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

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 example:

• We 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://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

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:

• 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]

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

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;
• Compliance with our legal obligations;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username or email). Website administrators can also see and edit that information.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.

 

Your rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

 

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:

TOKONEY Ltd, 85 Great Portland Street, London, W1W 7LT, United Kingdom

Last updated: 14/12/2022

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://ico.org.uk/make-a-complaint/]