Cophi privacy policy

(Updated November 2022)

This Privacy Policy is applicable for all the products, services, websites and applications managed and offered by Network Development Lab Ltd (“Cophi”).

Products, services, websites and apps are collectively referred to as the “Services” in this policy. 

"we", "us", "our" or “cophi’ refer to Network Development Lab Ltd

Your personal data - Web Visitor, Prospect, Employee, Customer, Partner

Contact information - This may include name, email address, contact telephone or address.
Account information - This may include account identifiers that are unique to you including account name, creation date, usage data relating to your account.
Third party data - This may include where you visited our site from for the purposes of marketing attribution
Transaction data - This may include any such information that would allow us to facilitate any transaction with you such as product related information or financial data.
Usage data - IP address, geographic location, operating system and other specific meta-data relating to your visit or usage.

Controller vs Processor relationship

Where we engage with you as a Customer, Cophi is acting as a Data Processor and you, the Customer are the Data Controller.

Purposes and legal bases of processing

Functioning - We may process all types of your data for the regular functioning and operation of our website, to provide our services or to ensure improvements to our ongoing relationship. The legal basis for this processing is either for the proper running of our website in the normal course of business or for the delivery of products or services that you have engaged with or procured.

Publications - We may process all types of your data for the normal delivery of our publications or other published marketing activities. The legal basis for this processing is  for the proper running of our relationship with you and ongoing and regular useful updates.

Relationships - We may process contact data to communicate with you by email or telephone. The legal basis for this processing is our legitimate interest to provide you with the relevant communications for the purposes of building a relationship.

Marketing - We may process data where applicable to market to you through direct channels, this may include email, telephone, address or other relevant media. The legal basis is legitimate interest.

Research - We may process data relating to your usage of our website or products for the purpose of improving our website and services. This process is for our legitimate interest.

Legal - We may process your data for the establishment of record keeping associated with claims or representations. The legal basis for this processing is our legitimate interest.

Providing your personal data to others

We may disclose your data for insurers, professional advisers, payment services providers if it is necessary for the purposes of running our products and operations.

International transfers of your personal data

We may transfer your data from the European Economic Area (EEA) to the UK and process that personal data in the UK, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; 

We may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy

Where data is transferred to countries outside of the EEA we determine that the data laws that any other jurisdictions are subject to are at least as adequate as the relevant UK or EEA laws. Transfers to any of these geographies will be protected by appropriate safeguards, including the appropriate wording to ensure full compliance of all relevant laws

Retaining or deleting data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We may retain your personal data where retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your or relevant others vital interests

Your rights

Your principal rights under data protection law are: the right to access your data; the right to rectification of your data; the right to erasure of your data; the right to restrict processing of your personal data; the right to object to processing of your personal data; the right to data portability of your personal data; the right to complain to a supervisory authority; the right to withdraw consent providing the legal basis is consent.

You may exercise any of your rights in relation to your personal data by written notice to us.

About cookies

Cookies are text files with small pieces of data — like a username and password — that are used to identify your computer as you use a computer network. Specific cookies known as HTTP cookies are used to identify specific users and improve your web browsing experience.

There are 2 main types of cookie:

Session cookies are used only while navigating a website. They are stored in random access memory and are never written to the hard drive.

Persistent cookies remain on a computer indefinitely, although many include an expiration date and are automatically removed when that date is reached.

Persistent cookies are used for two primary purposes:

Authentication. These cookies track whether a user is logged in and under what name. They also streamline login information, so users don't have to remember site passwords.

Tracking. These cookies track multiple visits to the same site over time. Some online merchants, for example, use cookies to track visits from particular users, including the pages and products viewed. The information they gain allows them to suggest other items that might interest visitors. Gradually, a profile is built based on a user's browsing history on that site.

If you allow cookies, it will streamline your surfing. For some users, no cookies security risk is more important than a convenient internet experience.

Cookies on our site

Cookie Consent - stored to remember if you have consented to our cookie policy

Authentication and security - Stored to remember if you are properly authenticated to use our services or products

Personalisation - To ensure your experience is relevant to you as an individual

Advertising - To help display relevant information relating to advertisements

Data - To ensure we can analyse your data for the purposes of improving our services and products

Managing cookies

Most browsers will allow you to manage your cookies in the browser settings.

Data protection officer

Our data protection officer's contact details are: Jamie Thomas