Privacy

We treat your information with the utmost care

Privacy Policy

This Privacy Policy reflects our commitment to protect personal data and the choices we offer you regarding how your data is used. We welcome you to read more about how we keep your information safe, as well as how you can exercise your rights. In addition, our Privacy policy covers our treatment of data that may be personal to you.

  • ‍We will review, update, and amend these policies from time to time consistent with our business needs and technology. Your continued use of the service makes up your acceptance of any change to this Privacy Policy. We are the data controller of your information. We handle and process all data on behalf of our customers.
  • This Privacy Policy (« Privacy Policy »)describes how Vinkka Trading Company. Will gather, use, and maintain your Personal Information on cocdocs.com. It will also explain your legal rights with respect to that information.
  • By using the website or services, you confirm that you have read and understood this Privacy Policy and our Terms (together referred to herein as the « Agreement »). The Agreement governs the use of com. We Company will collect, use, and maintain information consistent with the Agreement.
What private data do we collect from the people who visit our website?

When enlisting on our site or buying Products, as suitable, you could be approached to type in your name, email, address, payment information, or different subtleties to assist you with your experience.

  • Personal Data: Personal Data is information that can be used to identify you specifically, including your name, email address, telephone number, company name, VAT-Number or demographic information like your hometown. You consent to give us this information by providing it to us voluntarily on our website. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from purchasing services from the website.
  • Financial Data: Financial data is related to your payment methods, such as credit card or bank transfer details. We collect financial data to allow you to purchase, order, return or exchange products or services from our website. We store limited financial data. Most financial data is transferred to our payment processor, Stripe, and you should review these processors’ Privacy Policy to determine how they use, disclose, and protect your financial data. Stripe Privacy Policy can be found here.
  • Vehicle information: Vehicle Registration country, Registration Documents, and Photo of the manufacturer Plate.
Minors’ Data

We do not knowingly collect data from or market to children under 13 years of age.

By using the Website, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 13 years of age has been collected, We will take reasonable measures to promptly delete such data from our records. If you become aware of any data, we may have collected from children under age 13, please contact us.

Automatically collected information about your use of our Services

This information is registered automatically with the visit by own configuration or manual of each tool on the website

  • When you visit, connect with, or utilize our service, we may gather, record, or create specific specialized data about you. We do so either autonomously or with the assistance of third gathering Service Providers, including using « cookies » and other following innovations.
  • We automatically collect certain information when you visit, use, or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website and for our internal analytics and reporting purposes.
How do we use your details?

We process personal data to operate, improve, understand, and personalize our services. We use personal data for the following purposes:

  • To meet or fulfill the reason you provided the information to us.
  • To validate, confirm, verify, deliver, and track your order (including processing payment card transactions, speeding up the registration of your imported vehicle, handling refunds, maintaining a record of the purchases you make, and contact you about your orders, including by telephone) or to service products you purchased from us.
  • To communicate with you about the Services, including Service announcements, updates, or offers.
  • Correspond with you; and
  • Compile anonymous statistical data for our own use or for a third party’s use; and
  • Assist law enforcement as necessary; and
  • To fulfill or meet the reason you provided the information (e.g., to help provide our Site services to you).
  • To provide you with support, to communicate with you and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To prevent illegal activity, fraud, and abuse.
  • To improve our site to serve you better.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us with the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our services. If you do not want to receive communications from us, please indicate your preference by emailing us at [email protected].

Do Not Track

Currently, various browsers — such as Internet Explorer, Firefox, and Safari — offer a « do not track » or « DNT » option that relies on a technology known as a DNT header, which sends a signal to Web sites visited by the user about the user’s browser DNT preference setting. Cocdocs.com does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web sites, in part because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators including no consistent standard of interpreting user intent. Cocdocs.com takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

How we use cookies

We use cookies and similar technologies for several purposes, depending on the context or service, including: 

  • Keep track of your specified preferences. This allows us to honor your likes and dislikes, such as your language and configuration preferences.
  • Detecting and preventing fraudulent activity and improving security.
  • Conducting research and diagnostics to improve our offerings.
  • Reporting, which allows us to measure and analyze the performance of our offerings.
First-party cookies
  1. Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are often set in response to actions made by you, which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.
  2. Functional cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by third-party providers whose services we have added to our pages or by us.
  3. Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
  4. Targeting cookies: These cookies may be set through our site and may be used to build a profile of your interests and show you relevant adverts on other sites.
What are your choices regarding cookies?

Cookie Preferences on Cocdocs.com website: Our cookies allow you to take advantage of some essential and useful features. Blocking some types of cookies may impact your experience of our sites.

Browser settings: You can also manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to remove cookies from your device, prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. Check the support site for your browser to understand the privacy settings available to you. If you block or reject some of our cookies through your browser’s settings, you might not be able to use certain features and services.

Google Analytics Cookies

We use Google Analytics to investigate the utilization of our site of users and visitors. Google Analytics assembles data about site use through cookies. The data assembled identifying with our site is utilized to make reports about the utilization of our site.

Name of cookie

Expiry period

Purpose

Company

_ga

Persistent – 2 years

Analytics

Google Analytics, Google LLC

_ga_JMDY11H0YJ

Persistent – 2 years

Analytics

Google Analytics, Google LLC

_gat

Persistent – 2 years

Analytics

Google Analytics, Google LLC

_gid

Persistent – 1 day

Analytics

Google Analytics, Google LLC

_sp_root_domain_test_* (x 1535)

Session cookie

Analytics

 cocdocs.com

gaVisitorTypeLong

Persistent – 2 years

Analytics

Google Analytics, Google LLC

gaVisitorTypeShort

Persistent – 30 minutes

Analytics

Google Analytics, Google LLC

GDPR-Customer data processing appendix

Customer Data » means any personal data that Vinkka Trading Company processes on behalf of Customer via the Services, as more particularly described in this DPA.

« Data Protection Laws » means all data protection laws and regulations applicable to a party’s processing of Customer Data under the Agreement, including, where applicable, EU Data Protection Law and Non-EU Data Protection Laws.

GDPR-EU data protection law 

« EU Data Protection Law » means all data protection laws and regulations applicable to Europe, including (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) (« GDPR « ); (ii) Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector; (iii) applicable national implementations of (i) and (ii); and (iv) in respect of the United Kingdom (« UK « ) any applicable national legislation that replaces or converts in domestic law the GDPR or any other law relating to data and privacy as a consequence of the UK leaving the European Union.

« Europe » means, for the purposes of this DPA, the European Union, the European Economic Area and/or their member states, Switzerland, and the United Kingdom.

« SCCs » means the standard contractual clauses for processors as approved by the European Commission or Swiss Federal Data Protection Authority (as applicable), which shall be applied only to transfers of Customer Data from the European Union.

« Sensitive Data » means (a) social security number, passport number, driver’s license number, or similar identifier (or any portion thereof); (b) credit or debit card number (other than the truncated (last four digits) of a credit or debit card); (c) employment, financial, genetic, biometric or health information; (d) racial, ethnic, political or religious affiliation, trade union membership, or information about sexual life or sexual orientation; (e) account passwords; or (f) other information that falls within the definition of « special categories of data » under applicable Data Protection Laws.

« Services Data » means any data relating to the Customer’s use, support, and/or operation of the Services, including information relating to volumes, activity logs, frequencies, bounce rates, or other information regarding emails and other communications Customer generates and sends using the Services.

  • Parties’ roles: If EU Data Protection Law or the LGPD applies to either party’s processing of Customer Data, the parties acknowledge and agree that concerning the processing of Customer Data, Customer is the controller and is a processor acting on behalf of Customer, as further described in Annex A (Details of Data Processing) of this DPA.
  • Purpose limitation: Vinkka Trading Company shall process Customer Data only following Customer’s documented lawful instructions as outlined in this DPA, as necessary to comply with applicable law, or as otherwise agreed in writing (« Permitted Purposes »). The parties agree that the agreement sets out the Customer’s complete and final instructions to Vinkka Trading Company concerning the processing of Customer Data, and processing outside the scope of these instructions (if any) shall require a prior written agreement between the parties.
  • Prohibited data. Customer will not provide (or cause to be provided) any Sensitive Data to Vinkka Trading Company for processing under the Agreement, and Vinkka Trading Company will have no liability whatsoever for Sensitive Data, whether in connection with a Security Incident or otherwise. For the avoidance of doubt, this DPA will not apply to Sensitive Data.
  • Customer compliance: Customer represents and warrants that (I) it has complied, and will continue to comply, with all applicable laws, including Data Protection Laws, in respect of its processing of Customer Data and any processing instructions it issues to Vinkka Trading Company; and (II) it has provided, and will continue to provide, all notice and has obtained, and will continue to obtain, all consents and rights necessary under Data Protection Laws for Vinkka Trading Company to process Customer Data for the purposes described in the agreement. Customer shall have sole responsibility for the accuracy, quality, and legality of Customer Data and how Customer acquired Customer data. Without prejudice to the generality of the foregoing, Customer agrees that it shall be responsible for complying with all laws (including Data Protection Laws) applicable to any emails or other content created, sent, or managed through the service, including those relating to obtaining consents (where required) to send emails, the content of the emails and its email deployment practices.
  • The lawfulness of Customer’s instructions: Customer will ensure that United Kingdom processing of the Customer Data by Customer’s instructions will not cause Vinkka Trading Company to violate any applicable law, regulation, or rule, including, without limitation, Data Protection Laws. Vinkka Trading Company shall promptly notify Customer in writing unless prohibited from doing so under EU Data Protection Laws if it becomes aware or believes that any data processing instruction from Customer violates the GDPR or any UK implementation of the GDPR.
Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You may have the following rights: 
  1. Request access to your personal data (commonly known as a « data subject access request »). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  3. Request deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    1. If you want us to establish the data’s accuracy.
    2. Where our use of the data is unlawful, but you do not want us to erase it.
    3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
    4. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you.
How do we protect your data?
  • We have implemented industry-accepted administrative, physical, and technology-based security measures to protect against the loss, misuse, unauthorized access, and alteration of personal information in our systems. We ensure that any employee, contractor, corporation, organization, or vendor who has access to personal information in our systems are subject to legal and professional obligations to safeguard that personal information.
  • We do not use vulnerability scanning and/or scanning to PCI specifications.
  • We use regular Malware Scanning.
  • Your individual information is comprised behind secured systems and is merely accessible by a restricted number of employees who have special access privileges to such systems and must keep the information confidential carefully. Furthermore, all very sensitive/payment information you resource is encrypted via Secure Socket Layer (SSL) technology.
  • We implement several security measures whenever a user gets into, submits, or accesses their information to keep up the protection of your individual information.
  • While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or form of electronic storage is 100 percent secure. Therefore, we cannot guarantee its absolute security.
  • Vinkka Trading Company prohibits unauthorized access or use of personal information stored on our servers. Such access is a violation of law, and we will fully investigate and press charges against any party that has illegally accessed the information within our systems.
Limitation of liability
  • Some jurisdictions do not allow the limitation or exclusion of liability for incidental or consequential damages, so some of the above limitations may not apply to you.
  • You may access the website from outside The Netherlands at your own risk and initiative and must bear all responsibility for compliance with applicable foreign laws.
Indemnification

Upon visiting this website, you agree to release, indemnify, defend and hold harmless Vinkka Trading Company and any of its contractors, agents, employees, officers, directors, shareholders, affiliates and assigns from all liabilities, claims, damages, costs, and expenses, including reasonable attorneys’ fees and expenses, of third parties relating to or arising out of your use of the website content; your use of the products; your violation of any provision of these terms; any unauthorized information or data you supplied to us. You will have sole responsibility to defend us against any claim, but you must receive our prior written consent regarding any related settlement.

Governing Law and Jurisdiction

This website originates from The The laws of The Netherlands, without regard to its conflict of law principles, will govern these terms to the contrary. You hereby agree that all disputes arising out of or in connection with these terms shall be submitted to the exclusive jurisdiction of the Netherlands. By using this website, you consent to the jurisdiction and venue of such courts in connection with any action, suit, proceeding, or claim arising under or by reason of these terms.

Changes to this privacy notice

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all the changes. The use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contacting us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the Contact form.

Vinkka Trading Company
Vidarstraat 6
1363WK Almere
The Netherlands

This document was last updated on January 26, 2022