March 2020
Introduction
At Cucaracha we are committed to ensuring that your personal data is protected and never misused.
By sharing your personal data with us, and by continuing to use our websites you confirm that you have read and understood the terms of this privacy policy. We take responsibility for the personal data we collect about you, and we aim to be transparent about how we handle it, and give you control over it.
Our privacy policy explains what personal data we collect, why we collect it, how we use it, the control you have over your personal data and the procedures we have in place to protect your personal data. It applies to personal data we collect through our website and offline while we are providing you our services.
If you have any questions, comments or concerns about any aspect of this privacy policy or how we handles your information, please email us at
Privacy principles
Privacy policies can be complicated. We have tried to make ours as clear and as accessible as possible. To help, we have also summarised how we handle your personal data in our privacy principles below.
We:
Will only ask for or collect the personal data we need to provide and improve the service.
Give you control over the personal data we hold about you to ensure it is accurate and reflects your preferences.
Make sure your personal data is always secure and protected.
Are fair and transparent about how we use the personal data we hold.
Only ever use your personal data for the purpose that you trusted us to use it for.
Will never sell your personal data and only share it as outlined in our privacy policy or when you ask us to.
Respect your choices and will inform you if there are important changes that affect your personal data or how we use it.
Take responsibility for the personal data that we hold about you.
What personal data do we collect?
We are not interested in collecting every personal detail about you. Our main reason for collecting your personal data is to provide and improve the service.
Personal data is defined slightly differently across the world. To guarantee your privacy and the protection of your information, we define it as any information that could be used to identify you or another individual.
We collect personal data about you in a number of different ways. In this section, we explain the different ways we collect personal data about you and the ways in which that information will be used. For more detail on how we use your personal data, please see the section titled "How do we use your personal data?".
Information you share with us
We collect personal data that you share with us when you contact us or interact with us through our website, email, phone, in person during meetings, stands and events, or otherwise.
Through these interactions you may share with us: your name, address, e-mail address, contact number and payment information.
You can also ask us to delete it at any time by contacting us by e-mail at support@cucarachaagency.com.
If you share details of other people with us (for example, your employee or partner), then you will need to check with that person that they are happy for you to share their personal data with us, and for us to use it in accordance with this privacy policy.
Email Communications
As a user of our services, we will send you support communications by e-mail. As long as you are happy for us to do so, we would also like to keep you posted on anything that's happening at Cucaracha which we think you might like to know about; You can find out how to update or change whether you would like to hear from us, or stop us contacting you, in the section below titled 'How can you change the way that we contact you?'
We use that information by itself and in combination with your customer record (the information you share with us) to make sure that we stop sending you support or marketing communications when you ask us to. We also use it to make our e-mails as interesting as possible by providing you with content and experiences that we think you will be interested in based on how you have engaged with our previous e-mails; you have the right to object to our use of your information for this purpose (see the section below titled 'Your controls and choices').
How do we use your personal data?
Our main reason for collecting and using your personal data is to provide and improve the service.
Information you share with us
We use the personal data you share with us in the following ways:
To provide you our services; To respond to your queries and requests;
To communicate with you;
To send you our advertising;
To comply with our legal obligations ;
For profiling and statistical analysis;
To provide updates to you about any changes to our policies, terms and conditions and any other matters which we may need to tell you;
As long as you are happy for us to do so, to tell you about our other services;
You have the right to object to the processing of personal data in this way. For more information on how to exercise your right to object, see the section below titled 'Your controls and choices'.
What is our justification for handling your personal data in this way?
Data protection and privacy laws in some countries require us to have what's called a "legal basis" or "lawful ground" for handling personal data. Broadly, that means that we have to have a legal justification for handling your personal data. For the most part, we need to handle your personal data to be able to:
provide you with the services that you have asked for; and
for our websites to be able to work properly and to do all the things that you expect from it.
Sometimes, our use of your personal data is not strictly necessary for us to be able to provide you with our services. In those circumstances, we have what's called a "legitimate interest" in handling your personal data; our "legitimate interest" may be to:
keep our website and IT systems secure;
ensure that our own processes, procedures and systems are as efficient as possible;
analyse and enhance the information that we collect;
determine the effectiveness of our promotional campaigns and advertising; and
customise and improve the way that you engage with us in future.
You can ask us to delete that information at any time by contacting us at support@cucarachaagency.com.
Finally, in some, relatively limited circumstances we will need to handle your personal data in a certain way to be able to comply with our legal obligations; for example, if we are requested to disclose your personal data to regulatory bodies or law enforcement authorities.
Contact promise
We love to keep you posted, whether it's on our new services, special offers or upcoming events. We will also occasionally provide you with information about our company and services.
We do this in various ways, including e-mail, post, SMS, via social media platforms and by phone, but only if you are happy for us to do so. Ultimately, we want to make sure you're happy with the communications you receive from us.
We therefore promise to:
Only send you marketing communications when you have told us it is ok to do so;
Never pass your personal data to anyone outside Cucaracha for them to use for their own marketing purposes; and
Give you the option to stop receiving support or marketing communications at any time.
How can you change the way that we contact you about our services?
Changing your preferences
If you have previously said that you would like us to contact you ("opted-in") but would like to change or update the way that we do so, you can update your preferences by contacting us by email and stating that you would like to change or update the way that we contact you;
What personal information does we share with third parties?
Most importantly, we never sell your personal data to anyone and only share it as outlined in this privacy policy or when you ask us to.
Third party service providers
We share your personal data with certain third party service providers. They only have access to the personal data they need to perform those services.
We want to make sure that our advertising and marketing is relevant and interesting to you and our other customers. That means that we work with third parties to help us to understand how well our online advertising works, or to reach people who are more interested in our services.
Other third parties
We will also share your personal data if we are required to do so by law, including in response to a legal process, such as a court order or subpoena, or to comply with other national, state, provincial or local laws.
If you would like more information on how we share your personal data, please email us at support@cucarachaagency.com.
How long do we keep your personal data?
We only keep your personal data for as long as we need to, to be able to use it for the reasons given in this privacy policy, and for as long as we are required to keep it by law. The actual period for which we store your personal data will vary depending on the type of personal data and how it is used.
Your controls and choices
Where possible, we give you control over the personal data we collect about you, to ensure it is accurate and reflects your preferences. You have the right to access, update and amend personal data that we hold about you; If you would like to change the way that we contact you please email us at support@cucarachaagency.com.
In certain circumstances, you can also:
Object to our use of your personal data for certain purposes;
Ask us to limit or restrict our use of your personal data;
Ask us to correct, remove or delete personal data about you; or
Ask us to provide your personal data to a third party provider of services.
Please note that those rights do not always apply and there are certain exceptions to them. We will also need to confirm identity before acting on certain requests.
If the law in your country allows us to impose a fee for giving you access to your personal data, or to exercise any of your other rights in relation to your personal data, we will let you know. You will not be discriminated against for exercising any of the rights that apply to you.
If you would like to exercise any of your rights in relation to your personal data, please email us at support@cucarachaagency.com. We may request that you provide further information related to your request.
How do we protect your personal data?
We are committed to protecting your personal data. We use appropriate technical and organisational measures, to protect your personal data and privacy, and review those regularly. We protect your personal data using a combination of physical and IT security controls, including access controls that restrict and manage the way in which your personal data and data is processed, managed and handled. We also ensure that our staff are adequately trained in protecting your personal data. Our procedures mean that we may occasionally request proof of identity before we share your personal data with you.
In the unlikely event that we do suffer a security breach which compromises our protection of your personal data and we need to let you know about it, we will do so.
Data transfers, storage and the global handling of your personal data
We, and those third parties that we share your personal data with, then host, store and otherwise handle that information in the Switzerland and UK, in the countries within the European Economic Area (EEA) or in any country outside of the EEA.
We will make sure that any transfers of your personal data from one country to another comply with those data protection and privacy laws which apply to us. European data protection laws, in particular, include specific rules on transferring personal data outside the EEA.
When transferring personal data outside the EEA, we will:
include standard data protection clauses approved by the European Commission for transferring personal data outside the EEA into our contracts with those third parties (these are the clauses approved under Article 46.2 of the General Data Protection Regulation (GDPR)); or
ensure that the country in which your personal data will be handled has been deemed "adequate" by the European Commission under Article 45 of the GDPR.
In any case, our transfer, storage and handling of your personal data will continue to be governed by this privacy policy. If you would like further information about the global handling of your personal data, please contact us at support@cucarachaagency.com.
Changes to this privacy policy
We will review and update this privacy policy and will note the date it was last updated below.
If we change our privacy policy, we will post the details of the changes below. If we have your e-mail address, we may also e-mail you with information on those changes. If we need to, we will also ask you to confirm that you are happy with those changes.
This privacy policy was last reviewed and updated in March 2020
This privacy policy has been translated from English into other languages. We have done this to make sure that the policy is clear and accessible to all users of our website and services.
If there are any conflicts or inconsistencies between the translated versions of this privacy policy, the English version will prevail.
Contact us
If you would like to receive this information in another format or have any questions, comments or concerns about how we use the personal data we hold about you, please contact us.
You can also contact the relevant regulator or authority in your country that is responsible for handling complaints about the use of personal data.
You can contact us at any time by email at support@cucarachaagency.com.
We will get back to you as soon as possible.
