In this policy, the following terms shall have the following meanings:

“Cookie” means a small file placed on your computer or device by our site when you visit certain parts of our site and/or when you use certain features of our site;

“Cookie law” means the relevant parts of the privacy and electronic communications (EC directive) regulations 2003 and of EU regulation 2016/679 general data protection regulation;

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by EU regulation 2016/679 general data protection regulation; and

“We/us/our” means Sokito, a limited company registered in England and Wales under company number 11349611, whose registered address is Nucleus House, 2nd Floor, 2 Lower Mortlake Road, Richmond, United Kingdom, TW9 2JA.

2.1 Our Site is owned and operated by Sokito, a limited company registered in England and Wales under company number 11349611, whose registered address is Nucleus House, 2nd Floor, 2 Lower Mortlake Road, Richmond, United Kingdom, TW9 2JA.

2.2 Our VAT number is 324104060.

2.3 Our Data protection officer is Jake Hardy, and can be contacted by email at ciao@sokito.com, or by post at Sokito, Nucleus House, 2nd Floor, 2 Lower Mortlake Road, Richmond, United Kingdom, TW9 2JA.

3.1 This privacy policy applies only to your use of our site. Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4.1 As a data subject, you have the following rights under the GDPR, which this policy and our use of personal data have been designed to uphold:

4.1.2 The right to be informed about our collection and use of personal data;

4.1.3 The right of access to the personal data we hold about you (see section 12);

4.1.4 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);

4.1.5 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);

4.1.6 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.7 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.8 The right to object to us using your personal data for particular purposes; and

4.1.9 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the information commissioner’s office.

4.3 For further information about your rights, please contact the information commissioner’s office or your local citizens advice bureau.

Depending upon your use of our site, we may collect some or all of the following personal and non-personal data (please also see section 13 on our use of cookies and similar technologies):

5.1 Name;

5.2 Date of birth;

5.3 Gender;

5.4 Business/company name

5.5 Job title;

5.6 Profession;

5.7 Contact information such as email addresses and telephone numbers;

5.8 Demographic information such as postcode, preferences, and interests;

5.9 Financial information such as credit and debit card numbers;

5.10 IP address;

5.11 Web browser type and version;

5.12 Operating system;

5.13 A list of URLs starting with a referring site, your activity on our site, and the site you exit to;

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

6.2.1 Providing and managing your account;

6.2.2 Providing and managing your access to our site;

6.2.3 Personalising and tailoring your experience on our site;

6.2.4 Supplying our products and/or services to you (please note that we require your personal data in order to enter into a contract with you);

6.2.5 Personalising and tailoring our products and/or services for you;

6.2.6 Replying to emails from you;

6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing ciao@sokito.com);

6.2.8 Market research;

6.2.9 Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience;

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on our products and services. If you would like to opt-out of marketing messaging, you may do so before checkout when entering your contact information by ticking the statement box. You can also click the unsubscribe button at the bottom of our emails, or contact our customer support to be removed from our mailing list at ciao@sokito.com. We fully protect your rights and comply with our obligations under the GDPR and the privacy and electronic communications regulations 2003.

6.4 Third parties whose content appears on our site may use third party cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.5 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

7.2 Some or all of your data may be stored outside of the European economic area. (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our site and submitting information to us. If we do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our site.

8.1 We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

8.2 We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.3 We may sometimes use third party data processors that are located outside of the European Economic Area. (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

8.4 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.

9.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our site, you may be given options to restrict our use of your data. In particular, We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your account).

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service, the Corporate Telephone Preference Service, and the Mailing Preference Service. These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11.1 You may access certain areas of our site without providing any data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict our use of cookies. For more information, see section 13.

12.1 You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact Us for more details at ciao@sokito.com, or using the contact details below in section 14.

13.1 Our site may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our site and to provide and improve our products and services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.2 By using our site you may also receive certain third party cookies on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than Us. Third party cookies are used on our site for:

(a) Authentication – we use cookies to identify you when you visit our website and as you navigate our website;

(b) Status – to help us to determine if you are logged into our website;

(c) Personalisation – to store information about your preferences and to personalise the website for you;

(d) Security – as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e) Interest-based advertising – to help us to display advertisements that will be relevant to you;

(f) Analytics- we use cookies to help us to analyse the use and performance of our website and services;

(g) Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally;

13.3 All Cookies used by and on our site are used in accordance with current cookie law. We may use some or all of the following types of cookie:

13.3.1 Strictly necessary cookies:

A cookie falls into this category if it is essential to the operation of our site, supporting functions such as logging in, your shopping basket, and payment transactions.

13.3.2 Analytics cookies:

It is important for us to understand how you use our site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics cookies enable us to gather this information, helping us to improve our site and your experience of it.

13.3.3 Functionality cookies:

Functionality cookies enable us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality cookies may also be strictly necessary cookies, but not all necessarily fall into that category.

13.3.4 Targeting cookies:

It is important for us to know when and how often you visit our site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics cookies, this information helps us to better understand you and, in turn, to make our site and advertising more relevant to your interests. Some information gathered by targeting cookies may also be shared with third parties.

13.3.5 Third party cookies:

Third party cookies are not placed by us; instead, they are placed by third parties that provide services to us and/or to you. Third party cookies may be used by advertising services to serve up tailored advertising to you on our site, or by third parties providing analytics services to us (these cookies will work in the same way as analytics cookies described above).

13.3.6 Persistent cookies:

Any of the above types of cookie may be a persistent cookie. Persistent cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit our site.

13.3.7 Session cookies:

Any of the above types of cookie may be a session cookie. Session cookies are temporary and only remain on your computer or device from the point at which you visit our site until you close your browser. Session cookies are deleted when you close your browser.

13.4 Cookies on our site will expire.

13.5 For more details of the personal data that we collect and use, the measures we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our privacy policy.

13.6 For more specific details of the cookies that we use, please refer to the table below.

13.7 Certain features of our site depend on cookies to function. Cookie law deems these cookies to be “strictly necessary”. These cookies are shown below in section.

13.8. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these cookies by changing your internet browser’s settings as detailed below in section.

13.9. but please be aware that our site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

14.1 You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

14.2 The links below provide instructions on how to control cookies in all mainstream browsers:

14.2.1 Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB

14.2.2 Microsoft Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

14.2.3 Microsoft Edge: https://support.microsoft.com/en-gb/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)

14.2.4 Safari(macOS): https://support.apple.com/is-is/guide/safari/sfri11471/17.0/mac/14.0

14.2.5 Safari(iOS): https://support.apple.com/en-gb/105082

14.2.6 Mozilla Firefox: https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox

14.2.7 Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)

15.1 We may change this privacy policy from time to time (for example, if the law changes). Any changes will be immediately posted on our site and you will be deemed to have accepted the terms of the privacy policy on your first use of our site following the alterations. We recommend that you check this page regularly to keep up-to-date.

16.1 If you have any questions about our site or this privacy policy, please contact us at ciao@sokito.com, or by post at Sokito, Nucleus House, 2nd Floor, 2 Lower Mortlake Road, Richmond, United Kingdom, TW9 2JA. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).