Coubonga Privacy Policy
At Coubonga, we take data protection seriously. Privacy and security are at the heart of Coubonga. This Privacy Policy describes the key principles and practices we follow to ensure that your privacy is respected when you use our services.
Coubonga Ltd, the local country-specific Coubonga companies ("Coubonga", "we") belonging to the same group of companies, process personal data of users of the Coubonga app ("Coubonga app") for purchases and offers made through the Coubonga app ("Coubonga app"), users of other Coubonga products and services and visitors to the website Coubonga.com ("Website").
In this Privacy Policy, the term "Coubonga Services" refers collectively to the Website and the Coubonga App and other services provided by Coubonga to its users. In this Privacy Policy, the term "User" or "you" refers collectively to our and our group companies' customers, Coubonga users, agents and other authorised users of our customer organisations, potential customers and users of the Coubonga Services. Our Privacy Policy explains, for example, the types of personal data we process, how we process personal data and how you can exercise your rights as a data subject (for example, the right to object and the right to inspect).
Some of our services may also be accompanied by a separate privacy policy. If a separate privacy policy applies to a particular service, we will publish it in connection with that service.
This Privacy Policy may be updated from time to time to reflect changes in our data processing practices or other changes. You can find the current version on the website. We will not make material changes to this Privacy Policy or reduce users' rights under this Privacy Policy without notice.
This Privacy Policy applies to the processing of personal data by Coubonga. This Privacy Policy applies only to the processing of personal data where Coubonga is the controller.
Coubonga Ltd has been appointed to respond on behalf of the local joint controllers to all data subjects' requests and questions relating to the processing of personal data by the Coubonga Group.
Coubonga Oy
Business ID: 3341721-6
E-mail address: info@coubonga.com
Data Protection Officer: Coubonga has appointed a Data Protection Officer who can be contacted via the contact details above or by sending an email to info@Coubonga.com.
We process personal data only to the extent necessary and appropriate for the specific purpose of the processing. The personal data we collect and process can be divided into two general categories: user data and usage data.
User information
User Data is personal data collected on a case-by-case basis either directly from you or from our customer organization on whose behalf you use Coubonga services ("Customer Organization"). We may collect User Data from our Users and Client Organizations in a variety of ways, including after entering into a service contract with a Client Organization or when Users register for the Coubonga Service, subscribe to a newsletter or fill out a form. Please also note that we also collect information about transactions and payments you make through the Coubonga Services.
User data necessary to use the Coubonga services
The following personal data we collect and process is necessary for the proper performance of the contract between you and us and for our legitimate interests in fulfilling our contractual obligations to our customer organisations and to comply with our legal obligations.
When you register with Coubonga and create a user account, you must provide us with the following information:
full name
phone number
e-mail address
location details
date of birth
User data that you voluntarily provide to us when using the Coubonga services
Sex
To improve your user or customer experience, you can provide us with the following information:
Additional account details:
photo, location,
when ordering age-restricted goods: age, and any other information you provide either when you create an account or later when you edit your account profile.
Other information. We may also process other information you voluntarily provide, such as:
Information relating to orders you place with Coubonga or through the Coubonga Services (for example, products purchased, special instructions, date and time of order, total amount of the order and other order history), information you provide when submitting a review, comments or when responding to inquiries, favorite merchants and other preferences, marketing consents and opt-outs, and information you provide by telephone, email or chat correspondence with us, including call recordings of your calls with our customer service team.
In addition to the User Data we collect from you and the Customer Organisation, we process certain personal data that third party service providers provide about you. For example, for business customers, we may process information about the company's contact person to enable communication and marketing with the company and to manage the customer relationship. Such information is primarily obtained from public sources, such as local business registers, companies providing such information services, or directly from the companies themselves.
If your order includes products or services that may refer to your health or other sensitive personal data (belonging to special categories of personal data), Coubonga needs to process this data in order to provide you with Coubonga services. Coubonga complies with specific safeguards that may apply in accordance with applicable laws and regulations governing the processing of such personal data. Where required by applicable laws, Coubonga will seek your separate consent to process such personal data and you may withdraw your consent at any time by contacting Coubonga support at info@coubonga.com.
If you connect or sign in to your account via Facebook, Facebook will share your personal information with us, such as your profile picture, a sample of your Facebook friends and your Facebook ID. Where Coubonga operates a page on Facebook, both Coubonga and Facebook are joint controllers of your personal data in this respect. For more information on the processing of personal data on Facebook, please see Meta's Privacy Policy.
Usage data and analytics
Usage data is generated from the User's interaction with Coubonga services. Although we do not generally use Usage Data to identify you as an individual, in certain circumstances you may be identified from it, either individually or in combination with or linked to User Data. In such circumstances, Usage Data may also be considered Personal Data under applicable laws, and we will treat such information as Personal Data.
We may automatically collect the following usage information when you visit or interact with Coubonga services:
We use Firebase Analytics to collect and analyse analytics data. Firebase Analytics helps us understand how users interact with the Coubonga app and how we can improve the service.
Firebase Analytics collects information such as events related to app usage, device information, app version, and estimated location information. This processing is based on our legitimate interest in developing and improving the service.
Cookies and other technologies
We use various technologies, including cookies, website data storage and the use of network and application telemetry, to collect and store usage data and other information when Users visit the Coubonga Services.
Cookies and other website data stored on your device allow us to identify visitors to Coubonga services and facilitate your use of Coubonga services, and to create aggregate information about our visitors. This helps us to improve the Coubonga Services and better serve our Users. Cookies and other website data will not harm your device or your files. We use cookies and other website data to tailor the Coubonga services and information we provide to the individual interests of our Users. Please note that the different cookies have a limited retention period, ranging from less than one minute to permanent or until an individual cookie is deleted.
Users can choose to set their web browser to refuse cookies.
Please note that some parts of the Coubonga service may not function properly if cookies are disabled.
Coubonga services use pseudonymous identifiers to track and predict the use and preferences of your application and services. Coubonga also uses session-specific third-party tracking technologies to confirm and report on transactions initiated by its advertising partners.
You can manage your cookie settings through the cookie banner on our websites.
Coubonga uses various third-party analytics and telemetry providers, marketing and collaboration partners and other services integrated with our client software.
We process personal data only to the extent necessary and appropriate for the specific purposes for which it is processed. Please note that one or more of the following processing purposes and legal grounds may apply.
First, Coubonga processes your personal data to fulfil its contractual obligations towards you or the Customer Organization, for example, to the extent necessary:
Secondly, we may process your personal data where there is a relevant and legitimate interest (i.e. a legitimate interest) to do so in order to operate, maintain and develop our business or to establish and maintain customer relationships. When we decide to process your data on the basis of our legitimate interests, we will weigh our own interests against your privacy interests, for example, providing you with an easy way to opt-out of our marketing communications and using pseudonymised or non-personally identifiable information where possible. You have the right to object to the processing of your personal data on the basis of a legitimate interest. However, Coubonga may refuse such objection in accordance with applicable law, for example if the processing is necessary for the preparation, exercise or defence of legal claims.
We process your personal data to the extent necessary and based on legitimate interests, for example:
When we process your personal data to provide the Coubonga service to you and for the other purposes mentioned above, we may use automated means of processing, which may include automated decision-making.
In addition, we may process your personal data to administer and fulfil our legal obligations. This includes data processed to comply with our accounting obligations and to provide information to relevant authorities, such as tax authorities or law enforcement agencies, in accordance with mandatory legal obligations.
In some parts of the Coubonga Services, you may be asked to give your consent to the processing of your personal data. If the processing of your personal data is based on your consent, you can withdraw it at any time by contacting us or by changing the relevant consent setting, for example in the Coubonga app.
Please note that certain technical analytics data may always be active and processed on the basis of a legitimate interest to improve the service. You can manage marketing-related consent for push notifications in the Coubonga app in the app settings.
Coubonga stores your personal data primarily within the European Economic Area. However, we have service providers, operations and group companies in several geographical areas. Therefore, we and our service providers may transfer or process your personal data in countries outside the European Economic Area or the User's country of residence.
One of the services we use is Firebase Analytics, provided by Google LLC in the United States. This may mean that certain usage data, such as event identifiers related to the use of the application, may be transferred to countries outside Europe to Google's infrastructure, such as the United States. However, this information will not be linked to direct personal data and will not be used for individual user profiling or third party advertising. Google LLC is certified under the EU-US Data Privacy Framework (DPF), which allows for data transfers in compliance with the GDPR.
We take appropriate steps to ensure that Users' personal data is adequately protected. We ensure appropriate and adequate protection for transfers of personal data to countries outside the European Economic Area through agreements with our service providers based on standard contractual clauses or other appropriate safeguards.
For more information about transfers of personal data, please contact us at any of the above addresses.
We will only share your personal data within the Coubonga organisation if and to the extent reasonably necessary for the purposes of this Privacy Policy.
We will not share your personal data with third parties outside the Coubonga organisation unless one of the following conditions is met:
For the purposes set out in this Privacy Policy and to authorised service providers.
To the extent that third parties (such as restaurants, merchants or retailers preparing your order, our courier partners delivering your order and any customer organisation paying for your order) need access to your personal data in order to provide Coubonga services or for other lawful purposes, we will disclose your data to such third parties. For example, we may share your telephone number with the Partner preparing your order if necessary, for example, to ask you whether you agree to a replacement product in the order, or to notify you that your order is missing a product, or to obtain specific clarification otherwise.
In addition, we may provide your personal data to our group companies or authorised service providers who perform services for us (including data storage, accounting, analytics, sales and marketing and payment fraud prevention) to process it on our behalf and to payment service providers to process payments you make to us.
Where third parties process information on Coubonga's behalf, Coubonga has taken appropriate contractual and administrative measures to ensure that your information is processed solely for the purposes set out in this Privacy Policy and in accordance with all applicable laws and regulations, our instructions and appropriate confidentiality and security obligations.
Please remember that if you disclose personal data directly to a third party, for example through a link on the Coubonga Services, the processing will typically be based on the terms and conditions of that third party.
With partners to implement Coubonga services
To the extent that third parties need access to your personal information in order to perform Coubonga services, we will provide your information to such third parties.
On legal grounds and legal processes
We may share your Personal Information with third parties outside of Coubonga if we determine that access to and use of the Personal Information is reasonably necessary to: (i) comply with any applicable law, regulation and/or court order; (ii) detect, prevent or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, property or safety of Coubonga, Users or others to the extent permitted by law. Where possible, we will notify you of such processing.
Other justified reasons
If Coubonga is involved in a merger, acquisition or asset sale, we may transfer your personal data to a third party. However, we will continue to ensure the confidentiality of all personal data. We will inform all relevant users when personal data is transferred in this way to another company or is subject to a different privacy policy.
With your explicit consent
We may share your personal data with third parties outside Coubonga with your consent. You have the right to withdraw this consent at any time, free of charge, for example by contacting us.
Coubonga will not retain your personal data for longer than is permitted by law and necessary for the provision of the Coubonga service or essential elements thereof. The retention period depends on the nature of the data and the purposes of the processing. The maximum period may therefore vary depending on the purpose of use.
Once a User has deleted their account, personal data may only be retained for as long as required by law or reasonably necessary for our legal obligations or legitimate interests, such as claims processing, accounting, internal reporting and reconciliation. We regularly review the retention period of personal data to ensure that it is kept only for the necessary period.
Right of access to data
You have the right to access and obtain information about the personal data we process about you. You have the option to view certain information directly through your Coubonga Services account or to request a copy of your personal data by contacting us.
Right to withdraw consent
If the processing is based on the User's consent, the User may withdraw his/her consent at any time free of charge. Withdrawal of consent may lead to a reduction in access to the Coubonga services. Withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of consent prior to its withdrawal.
Right to rectification
You have the right to have any inaccurate or incomplete personal data we hold about you corrected or completed by contacting us. You can correct or update some of your personal data directly through your Coubonga Services account.
Right to erasure
You can also ask us to delete your personal data from our systems. We will comply with such a request unless we have a legitimate reason not to.
Right to object to processing
You may have the right to object to certain uses of your personal data where these data are processed for purposes other than the provision of the Coubonga service or to comply with a legal obligation. If you object to further processing of your personal data, this may result in reduced access to the Coubonga Services.
Right to restriction of processing
You can ask us to restrict the processing of your personal data, for example, when requests for erasure, rectification or objection are pending and/or when we do not have a legitimate basis for processing your data. However, this may lead to a reduction in your access to the Coubonga services.
The right to transfer data from one system to another
You have the right to receive the personal data you provide to us in a structured and commonly used format and to independently transfer this data to a third party.
How to use your rights
The above rights can be exercised by contacting Coubonga Support or by sending us a letter or email to the addresses above, including the following information: full name, address, email address and telephone number. If you have a Coubonga account, we recommend that you contact us via Coubonga Support, as this will allow us to identify you more easily. We may ask you to provide additional information necessary to verify the identity of the User. We may refuse or charge for requests that are unreasonably repetitive, excessive or manifestly unfounded.
You have the right to object to us using your personal data for direct marketing purposes, market research and profiling for direct marketing purposes by contacting us at the above mentioned addresses or by using the Coubonga service features or the unsubscribe option provided in direct marketing messages.
If the User believes that our processing of personal data is in breach of applicable data protection laws, the User may lodge a complaint with the local data protection authority in Finland, the Data Protection Ombudsman (tietosuojavaltuutettu) (tietosuoja.fi). Alternatively, the User may lodge a complaint with any other local and competent supervisory data protection authority.
We use administrative, organisational, technical and physical safeguards to protect the personal data we collect and process. These measures include, where appropriate, encryption, pseudonymisation, firewalls, secure facilities and access control systems. Our security controls are designed to maintain appropriate data confidentiality, integrity, availability, resilience and recoverability. We regularly test Coubonga's services, systems and other assets for security vulnerabilities. In addition, Coubonga's employees have limited access to personal information and access and processing of information is only necessary for the performance of the employee's job duties.
