Last updated March 1, 2020

WWW.COCOTRADE.IO  is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, WWW.COCOTRADE.IO  is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected online.

Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Privacy Statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the PII that we have obtained.


  1. Collection and use of personal information

1.1. What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to WWW.COCOTRADE.IO  (if, for example, you are a former employee). If you choose to register or login to a WWW.COCOTRADE.IO  web site using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with WWW.COCOTRADE.IO , we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

When you register or submit personal information to WWW.COCOTRADE.IO  we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a WWW.COCOTRADE.IO  web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other WWW.COCOTRADE.IO  sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with WWW.COCOTRADE.IO , we will use the information that you provide to match you with available WWW.COCOTRADE.IO  job opportunities.

In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.2 The legal grounds we have to use your personal information

WWW.COCOTRADE.IO  generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

The law in Europe allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

  • Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
  • Legal obligation:this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
  • Legitimate interests:we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
  • Your consent:in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting COCOTRADE.IO  at [email protected]

Examples of the ‘legitimate interests’ referred to above are:

  • To offer information and/or services to individuals who visit our web site or offer information about employment opportunities.
  • To prevent fraud or criminal activity and to safeguard our IT systems.
  • To customize individuals’ online experience and improve the performance, usability and effectiveness of COCOTRADE.IO’s online presence.
  • To conduct, and to analyze, our marketing activities.
  • To meet our corporate and social responsibility obligations.
  • To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.

In some cases, the personal data that we collect will also include special categories of data, such as payment details to make an order possible.


1.3 Automatic collection of personal information

In some instances, WWW.COCOTRADE.IO and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of WWW.COCOTRADE.IO’s online presence, and to measure the effectiveness of our marketing activities. To allow us collecting this data, our Privacy-by-design allows you to admit those in our Cookie-Policy which will be in a off-position by  default.


1.4 Social media widgets and applications

WWW.COCOTRADE.IO web sites may include functionality to enable sharing via third party social media applications, such as the Facebook and Twitter widget. These social media applications may collect and use information regarding your use of WWW.COCOTRADE.IO web sites (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, WWW.COCOTRADE.IO web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any WWW.COCOTRADE.IO social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.


1.5 Children

WWW.COCOTRADE.IO understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13.


  1. Sharing and transfer of personal information

2.1 Transfer within the network of WWW.COCOTRADE.IO firms

We share information about you with other member firms of the WWW.COCOTRADE.IO network as part of international engagements, and with WWW.COCOTRADE.IO International and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the WWW.COCOTRADE.IO network are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run WWW.COCOTRADE.IO’s business.


2.2 Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. For more information on such third parties, please see here;

  • Our service providers: we transfer your personal information to our third party service providers, such as our (IT) systems providers, our hosting providers, our payroll providers, consultants (such as legal advisers) and other goods and services providers. works with such providers so they can process your personal information on our behalf.  will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
  • If we are reorganized or sold to another organization: will typically also disclose personal information in connection with the sale, assignment, or other transfer of any element of  business to which the personal information relates.
  • Courts, tribunals, law enforcement or regulatory bodies: will disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government or professional regulations.
  • Audits: disclosures of personal information will also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
  • Insurers: our professional rules and our business requirements mean that we carry significant insurance cover in respect of business activities (our ‘insurance programme’). This is required to assist each member firm of the cocotrade network in covering the costs associated with claims which may arise in the event that it is alleged that something has gone wrong during the course of providing services to its clients. In order to make the insurance programme work effectively, the insurance programme involves a number of different participants in the insurance market (e.g. brokers, insurers and reinsurers, as well as their professional advisors and other third parties involved should there be a claim). Some of these insurance market participants will require that we disclose personal information about you to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance programme, where there is a claim that you are relevant to and to allow the insurance market participants to comply with their legal and regulatory obligations. Some of these insurance market participants will handle this information on our behalf (like our service providers described above), but others will want to process information about you independent of us.

In addition, WWW.COCOTRADE.IO will transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. WWW.COCOTRADE.IO will NOT store personal information outside of the EEA. We typically send personal information to the buyers or sellers. If we do this your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission.

WWW.COCOTRADE.IO will not transfer the personal information you provide to any third parties for their own direct marketing use.


  1. Choices

In general, you are not required to submit any PII to WWW.COCOTRADE.IO online, but we may require you to provide certain PII in order for you to receive additional information about our services and events. WWW.COCOTRADE.IO may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.


  1. Your rights

If WWW.COCOTRADE.IO processes personal information about you, you have the following rights:

  • Access and correction:you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we

hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the    personal information.

  • Object to processing:you have the right to object to us processing your personal information if we are not entitled to use it any more.
  • Other Rights:in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting WWW.COCOTRADE.IO at [email protected]  and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.


  1. Data security and integrity

WWW.COCOTRADE.IO has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite WWW.COCOTRADE.IO’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual’s request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained for more than 2 years. For Taks legislation we are hold to retain certain information during 7 years after last contact.

5.1 Technical and orgnizational measures:

  • The computers on which data are processed are protected as standard with a user name and a complex password.
  • All computers are equipped with a Small Office Security solution, which of course is always kept “up-to-date” and automatically performs multiple scans. All Windows installations are automatically updated. The installation is checked at least once a month and possibly started manually.
  • The data is stored on a part of the disk that is set up as a “data safe.”

This is encrypted and can only be accessed after starting up the computers + Windows logon + opening the safe using Kaspersky and a long and complex password.

  • To prevent data loss in the event of loss of computers, we back up daily to an encrypted cloud environment.
  • The data is first compressed, then encrypted with at least AES256 bit key and this form is stored at the off-site location. The responsible for the backups cannot read data in this way as the encryption key is only known by us and stored in a special “password manager”.
  • All passwords are managed by Kaspersky password manager and stored in the cloud environment.
  • Our employees are fully informed about the safe handling of your personal data and are held to confidentiality by their employment contract.
  • No data is kept on paper due to the possibility of online registration and is not accessible to unauthorized persons.
  • The past teaches us that no risk is completely avoided and if we are aware of unauthorized access to our IT systems or unauthorized modification, damage or possible loss of your data, we will immediately take all necessary measures to reduce this risk to a minimum and to avoid in the future. As a result, the possible damage for you will remain very limited:


  1. Links to other sites

Please be aware that WWW.COCOTRADE.IO web sites will typically contain links to other sites, including sites maintained by other WWW.COCOTRADE.IO member firms that are not governed by this Privacy Statement, but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each web site visited before disclosing any personal information.

By registering on any WWW.COCOTRADE.IO web site and then navigating to another WWW.COCOTRADE.IO web site while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the WWW.COCOTRADE.IO web site you are visiting.


  1. Changes to this statement

WWW.COCOTRADE.IO may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.


  1. Policy questions and enforcement

WWW.COCOTRADE.IO is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at [email protected] . You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

If you are not satisfied with the response you receive, you may escalate your concern to the Global Privacy Officer by sending an email to [email protected] . We will acknowledge your email within 30 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.

In any event, you always have the right to lodge a complaint with the Belgian regulator in charge of protecting personal information, the Belgian Data Protection Authority / Gegevensbeschermingsautoriteit or GBA via at B – 1000 Brussels, Drukpersstraat 35 or by mail to [email protected] or by phone 0032/(0)2/274.48.00

1 “WWW.COCOTRADE.IO,” “we,” “our,” and “us” refers to WWW.COCOTRADE.IO International Auction.”