Privacy Notice

​

This Privacy Notice sets out how we, col+Lab™ a company incorporated under Cayman Islands law (col+Lab™), collect, store and use information about you when you use or interact with our mobile app (the "App") where we otherwise obtain or collect information about you. This Privacy Notice is effective from 1st October 2022.

 

1. Summary

This section summarizes how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Notice.

• Data controller: col+Lab™

• How we collect or obtain information about you:

  • when you provide it to us (e.g., by contacting us or requesting information).

  • from your use of our App, using cookies and analytics, and occasionally, from third parties.

• Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g., device and browser type), information about how you use our App (e.g., which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our App (based on your IP address), company name or business name (if applicable).

 

• How we use your information: for administrative and business purposes, to improve our business and App, to fulfil our contractual obligations, to analyze your use of our App, and in connection with our legal rights and obligations.

 

• Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.

 

• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No

 

• How long we retain your information: for no longer than necessary, taking into account any legal obligations we have, any other legal basis we have for using your information (e.g., your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled “How long we retain your information”.

 

• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.

 

• Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as google analytics on our App including essential, functional, analytical and targeting cookies.

• Transfers of your information: we will only transfer your information outside the Cayman Islands and outside of the European Economic Area if we are required to do so by law.

 

• Use of automated decision making and profiling: we do not use automated decision making and/or profiling.

 

• Your rights in relation to your information

 

• to access your information and to receive information about its use

• to have your information corrected and/or completed

• to restrict the use of your information

• to object to the use of your information

• to withdraw your consent to the use of your information

• to complain to the Ombudsman office

 

• Sensitive personal data: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal data. Please do not submit sensitive data information about you to us. For more information, please see the main section below entitled Sensitive Personal Data.

 

Our details

The data controller in respect of our App is col+Lab™. You can contact the data controller by writing to us at the above address or sending an email to info@col-x-lab.com.

Information we collect when you visit our App

We collect and use information from our App visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

​

[Web server log information-We use a third-party server provided by AWS to host our App. Our App server automatically logs the IP address you use to access our App as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our App (e.g., the App or URL (link) which referred you to our App), and your browser version and operating system.]

 

Use of App server log information for IT security purposes

We and our third-party hosting provider AWS collect(s) and store(s) server logs to ensure network and IT security and so that the server and App remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Use of App server log information to analyze App use and improve our App

We use the information collected by our App server logs to analyze how our App users interact with our App and features. For example, we analyze the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our App. For example, we use the information gathered to change the information, content and structure of our App and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our App.]

​

Cookies and similar technologies

Cookies are data files which are sent from our App to a browser to record information about users for various purposes. We use cookies and similar technologies on our App, including essential, functional, analytical, web beacon cookies.

You can reject some or all of the cookies we use on or via our App by changing your browser settings but doing so can impair your ability to use our App or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled “Disclosure and additional uses of your information.”

​

Email

When you send an email to the email address displayed on our App we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

We use a third party email provider to store emails you send us. Our third party email provider is located in the Cayman Islands.

​

Contact form

When you contact us using our contact form, we collect name, contact details, reason for enquiry, and email address. We also collect any other information you provide to us when you complete the contact form.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Messages you send us via our contact form will be stored within the European Economic Area on our third party hosting and email provider’s servers within the European Economic Area.

​

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.

We can record phone calls.

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider which is located in the European Economic Area.

​

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Information we collect when you interact with our App

We collect and use information from individuals who interact with particular features of our App in accordance with this section and the section entitled “Disclosure and additional uses of your information.”

Information we collect when you place an order on our App

We collect and use information from individuals who place an order on our App in accordance with this section and the section entitled Disclosure and additional uses of your information.

Optional information

We also collect optional information from you. We may ask you if you would like to receive marketing communications from us AND/OR third parties. For further information, see ‘Marketing communications’ in this section below.

​

Marketing communications

You will have the option of receiving marketing communications from us.You can opt-out from receiving marketing communications in relation to our services by following the opt out instructions.

We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them. We use a third party service to administer our mailing list. Information you submit will be stored within the European Economic Area on our third party mailing list provider’s servers.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates and which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

​

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you may generally include credit reference agencies. It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both Cayman and non-Cayman, such as the electoral register, online customer databases, business directories, media publications, social media, and our App (including your own webApp if you have one).

 

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services, which are necessary to run our business or to assist us with running our business.

These include, telephone providers, email providers, IT service providers, web developers and hosting developers.

Our third party service providers are located in the Cayman Islands or in the European Economic Area.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our App or ordering goods and services from us.

We do not display the identities of our service providers publicly by name. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

​

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

[Providing information to third parties such as Google Inc.

Google collects information through our use of Google Analytics on our App. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners.

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this Privacy Notice below entitled Transfers of your information outside the European Economic Area.]

​

Accountants

We share information with our accountants. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

​

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their webApp, for example. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.

​

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

​

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.

​

Disclosure and use of your information for legal reasons

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

​

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

​

Retention periods

Server log information: we retain information on our server logs.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further month(s), after which point we will delete your information.

 

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);

• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);

• whether we have any legal basis to continue to process your information (such as your consent);

• any relevant agreed industry practices on how long information should be retained;

• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

 

How we secure your information

We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;

• using secure servers to store your information;

• verifying the identity of any individual who requests access to information prior to granting them access to information;

• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our App and any payment transactions you make on or via our App; and

• only transferring your information via closed system or encrypted data transfers.

 

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our App or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

​

Transfers of your information outside the Cayman Islands and the European Economic Area

Your information may be transferred and stored outside the Cayman Islands and the European Economic Area (EEA) but limited to the companies within the col+Lab™and Google. We will also transfer your information outside the EEA or to an international organization in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to info@col-x-lab.com

• to request access to your information and information related to our use and processing of your information;

• to request the correction of your information;

• to request that we restrict our use of your information;

• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);

• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and

• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

• ​

You also have the right to lodge a complaint with a supervisory authority, the Ombudsman Office: https://ombudsman.ky/.

​

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the Ombudsman office App: https://ombudsman.ky/data-protection .

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.

 

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

 

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to col+Lab™ or by sending an email to info@col-x-lab.com 

• to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behavior based on your information) based on any of these purposes; and

• to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

• You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

• sending an email to email asking that we stop sending you marketing communications or by including the words “OPT OUT”.

 

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information. We will use and process your sensitive personal information for the purposes of deleting it.

 

Changes to our Privacy Notice

We update and amend our Privacy Notice from time to time.

Minor changes to our Privacy Notice

Where we make minor changes to our Privacy Notice, we will update our Privacy Notice with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Notice from its effective date onwards.

Major changes to our Privacy Notice or the purposes for which we process your information

Where we make major changes to our Privacy Notice or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our App.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

 

Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to webApp requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the App. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our App.