COCOO.UK – PRIVACY POLICY
Last Updated: 15 May 2025
1. Introduction
1.1. Cocoo.uk (“Cocoo”, “we”, “us”, “our”) is a Charity registered in England and Wales with Charity Number 1139020. Our registered office is at 23 Village Way, Beckenham, BR33NA
1.2. This Privacy Policy explains how we collect, use, store, share, and protect your Personal Data when you become a Member, use our website (cocoo.uk), or otherwise interact with us in relation to potential legal actions and pre-litigation settlements.
1.3. We are a “data controller” for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are registered with the Information Commissioner’s Office (ICO) under Registration reference: ZB897863
2. What Personal Data We Collect
2.1. We may collect and process the following categories of Personal Data about you:
a. Identity Data: Full name, title, date of birth.
b. Contact Data: Postal address, email address, telephone number(s).
c. Case Eligibility Data: Information you provide relating to your potential involvement in an issue we are investigating. This may include details of purchases, contracts, communications, experiences, financial loss, or other circumstances relevant to a specific Case.
d. Sensitive Data (Special Category Data): In limited circumstances, and only where strictly necessary for assessing eligibility or progressing a Case (e.g., health data if relevant to the harm suffered), we may collect Sensitive Data. We will only process Sensitive Data with your explicit consent or where otherwise permitted by law (e.g., for the establishment, exercise, or defence of legal claims).
e. Technical Data: (If applicable, e.g., from website usage) IP address, browser type, operating system, referral source, length of visit, page views. (Consider a separate Cookie Policy if extensive).
f. Communications Data: Records of your communications with us.
3. How We Collect Your Personal Data
3.1. We collect Personal Data directly from you when you:
a. Register as a Member on our website.
b. Complete forms or questionnaires related to a specific Case.
c. Communicate with us by post, phone, email, or otherwise.
d. Provide documents or evidence to support your Potential Claim.
3.2. We only seek information relevant to Cases emerging from our own investigations.
4. Lawful Basis for Processing Your Personal Data
4.1. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
a. Consent:Where you have given us explicit consent to process your Personal Data for one or more specific purposes (e.g., to become a Member, to assess your eligibility for a Case, to contact you about specific legal actions, and to process any Sensitive Data). You can withdraw your consent at any time.
b. Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and9 fundamental rights do not override those interests. Our legitimate interests include10 pursuing our charitable objectives of investigating issues and seeking collective redress.
c. Legal Obligation: Where we need to comply with a legal or regulatory obligation.
5. How We Use Your Personal Data
5.1. We use your Personal Data for the following purposes:
a. To manage your membership with Cocoo.uk.
b. To assess your eligibility to participate in a group of Affected Parties for a specific Case.
c. To communicate with you regarding your membership, relevant Cases, potential legal actions, and settlement opportunities arising from our investigations.
d. To gather evidence and information relevant to our investigations and Cases.
e. To facilitate pre-litigation settlement discussions with Opposing Parties (which may involve sharing anonymised or aggregated data initially, and identifiable data later in the process with your consent or if legally required for the claim).
f. To instruct and liaise with external legal counsel (solicitors, barristers) and experts if a Case proceeds towards formal action (your data would be shared under strict confidentiality and for the purpose of the legal action).
g. For internal record-keeping, analysis, and reporting (often using anonymised or aggregated data).
h. To comply with our legal and regulatory obligations.
6. Sharing Your Personal Data
6.1. We may share your Personal Data with the following parties for the purposes set out in this Privacy Policy:
a. External Legal Counsel & Experts: Solicitors, barristers, and other legal or technical experts instructed by Cocoo.uk to advise on or conduct a Case. This will be done under confidentiality agreements and for the specific purpose of progressing the Case.
b. Opposing Parties and their Representatives: During settlement negotiations or if legal proceedings are initiated, it will be necessary to share relevant information (which may include your Personal Data if you are part of the claimant group) with the entity/entities the claim is against and their legal advisors. We will seek to do this appropriately and, where sensitive, with your awareness or specific consent unless legally compelled otherwise.
c. Courts, Tribunals, and Regulatory Authorities: If required by law or as necessary for the conduct of legal proceedings.
d. IT Service Providers: Third-party service providers who host our website, database, and provide other IT support services (e.g., secure data storage, email systems). We have contracts in place to ensure they protect your data.
e. A designated Class Administrator if a settlement fund is court-approved
6.2. We will not sell your Personal Data to third parties.
6.3. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We only permit them to process your Personal Data for specified purposes and in accordance with11 our instructions.
7. International Data Transfers
7.1. We do not transfer data outside the UK/EEA
8. Data Security
8.1. We have put in place appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.
8.3. We limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
8.4. We have procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach16 where we are legally required to do so.
9. Data Retention
9.1. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements, and for the duration of any investigation, Case, or potential limitation periods for claims.
9.2. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9.4. In some circumstances, we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your Data Protection Rights
10.1. Under data protection law, you have rights including:
a. Your right of access – You have the right to ask us for copies of your personal information.
b. Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also19 have the right to ask us to complete information you think is incomplete.
c. Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
d. Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
e. Your right to object to processing – You have the right to object to the processing of your personal information in certain20 circumstances (e.g., where we are relying on legitimate interests).
f. Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
g. Your right to withdraw consent – Where we are relying on consent to process your Personal Data, you have the right to withdraw that21 consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
10.2. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
11. How to Exercise Your Rights & Contact Us for Data Protection Queries
11.1. If you wish to make a request to exercise any of your rights, or have any questions about this Privacy Policy or our data protection practices, please contact our Data Protection Lead : contact@cocoo.uk Data Protection Lead : Cocoo.uk. Cocoo.uk is a Charity registered in England and Wales with Charity Number 1139020. Our registered office is at 23 Village Way, Beckenham, BR33NA
Email: contact@cocoo.uk
11.2. Please provide enough information to identify yourself and clearly state the right(s) you wish to exercise. We may need to request specific information from you to help us confirm your identity.
12. Complaints
12.1. If you have any concerns about our use of your personal information, you can make a complaint to us using the contact details above.
12.2. You also have the right to complain to the ICO if you are unhappy with how we have used your data. The ICO’s contact details are:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number:24 0303 123 1113
ICO website: https://www.ico.org.uk
12.3 Cookies: Our website may use essential cookies to enhance user experience