Privacy Policy

This Privacy Policy outlines how CocoaDreams collects, uses, shares, and protects your personal information when you use our websites, services, and products (collectively referred to as our "Services"). In this policy, "CocoaDreams" refers to Glowworm Enterprises Ltd, operating under the brand name CocoaDreams.

If you're based in the U.S., please consult our Consumer Health Data Privacy Policy for further information regarding how we handle consumer health data and your rights under applicable data privacy legislation.

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Information We Collect

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1. Information You Provide Directly

When you interact with CocoaDreams, you may provide us with personal details, including:

• Contact details: Your name, email address, phone number, postal address.
• Account information: Login credentials such as your username and password, should you choose to make a purchase, an account is created to manage your subscription and orders.
• Communication data: Any information shared with us during interactions—this may include messages via WhatsApp, support inquiries, feedback, or other forms of direct communication.
• Order & purchase history: Details regarding past orders and interactions with our checkout or subscription process.
• Payment data: Your shipping address and limited payment information. Please note: all payments are securely processed via third-party providers (e.g., Stripe). CocoaDreams does not store your full payment card details.
• Survey responses: Data from surveys or interviews (voice/video) shared with our marketing team.
• Marketing preferences: Your choices related to receiving promotional content and your engagement with our marketing communications.

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2. Information from Third Parties

We may enhance our records by combining the personal information you provide with data gathered from trusted external sources, including:

• Social media platforms: When you sign in or connect with platforms like Facebook, certain information may be shared with us based on your privacy settings.
• Data vendors: This includes licensed data providers, cooperatives, or analytics services.
• Public platforms: Including content or activity available through public sources like social media.
• Marketing affiliates: Brands or partners we collaborate with through joint marketing activities.

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3. Automatically Collected Data

When you visit cocoadreams.co.uk or use our services, we may automatically collect data through cookies and similar tracking technologies. This includes:

• Device data: Your operating system, browser type, screen resolution, IP address, mobile carrier, device identifiers (including for ads), and general geographic location (e.g., city or region).
• Usage and browsing behavior: Information such as which pages you view, time spent on pages, how you arrived at our site, your navigation flow, timestamps of visits, and interactions with emails (e.g., whether links were clicked).

To learn more about how we use cookies, please refer to our Cookie Policy.

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How We Use Personal Information

We use your personal information for a range of business and legal purposes, outlined below. Where required by data protection laws, we’ve included the relevant legal basis for each type of processing.

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To Fulfil Our Contractual Obligations

We process your personal information to carry out the contract between you and CocoaDreams under our Terms of Use. This includes:

• Delivering and improving our Services, products, and operations;
• Processing transactions and payments securely;
• Communicating with you about your orders, account, and service updates, including administrative and support messages, security notifications, and announcements.

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For Our Legitimate Business Interests

We may also process your data where it supports our legitimate interests in running and improving our Services, including:

Improving and Safeguarding Our Services

• Understanding how customers use CocoaDreams to personalize your experience and offer relevant content;
• Conducting feedback surveys, user interviews, and occasionally recording video/audio chats (e.g., via WhatsApp or website chat);
• Performing diagnostics, bug fixes, testing, and analytics to maintain platform stability and security;
• Preventing and investigating fraud, abuse, unauthorized access, or other potentially harmful activity.

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Research and Development

• Analyzing user trends to enhance our product offerings and overall business strategy;
• Creating anonymized or aggregated data for internal insight, which does not identify you personally.

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For Marketing and Advertising

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Direct Marketing

• We may send marketing emails, newsletters, or WhatsApp messages where you’ve opted in or where we have an existing relationship and are legally permitted to do so.
• You can adjust your preferences or opt-out at any time—see the "Opt-Out of Marketing" section below for more info.

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Interest-Based Advertising

• We work with third-party advertising partners to display ads for CocoaDreams across other platforms. To do this, we may share anonymized or pseudonymized user data to help display more relevant ads.
• Where required by law, we will only use this data for interest-based advertising with your consent. See our Cookie Policy for more on how to manage these settings.

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To Comply With Legal Obligations

We may also need to process or share your personal information in order to:

• Comply with consumer protection laws and other applicable regulations;
• Respond to lawful requests from authorities (e.g., subpoenas or legal notices);
• Conduct internal audits or assessments to ensure legal compliance;
• Investigate and prevent fraud, cyber threats, or identity theft;
• Enforce our policies, including Terms and Conditions;
• Defend our legal rights, or protect the safety, privacy, and rights of you, us, or others.

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How We Disclose Personal Information

We may share personal information with the following categories of recipients, where appropriate:

• Affiliates. Within CocoaDreams (including affiliated entities of Glowworm Enterprises Ltd) for purposes aligned with this Privacy Policy.
• Service Providers. Trusted third-party providers who support our operations and services, such as hosting platforms, IT providers, customer support partners, AI-powered chat agents, email delivery services, WhatsApp business solutions, survey platforms, and website analytics companies.
• Payment Processors. When you make a purchase on cocoadreams.co.uk, your payment information is collected and processed directly by our third-party payment processors (e.g., Stripe). We do not store or have access to your card or bank details. These processors handle your data in line with their own privacy policies.
• Third Parties for Advertising. We may share certain personal information with advertising networks, data providers, and marketing partners for interest-based advertising and related promotional purposes. These third parties may also use the data for their own marketing purposes. To learn how to manage these preferences, please see the “Privacy Rights and Choices” section below.
• Professional Advisors. We may share information with advisors such as lawyers, auditors, bankers, and insurers where necessary for legitimate business functions or legal compliance.
• Authorities and Legal Recipients. We may disclose information to law enforcement agencies, government authorities, or other third parties if required by law, or if we believe such disclosure is necessary to protect our users, our legal rights, or to prevent fraud and illegal activities.
• Business Transfers. In the event of a merger, acquisition, financing, reorganization, or sale of assets involving Glowworm Enterprises Ltd or CocoaDreams, your personal data may be transferred as part of that transaction. This also applies in bankruptcy or similar proceedings.

Note: If you choose to make personal data public—such as in reviews, comments, or via our Services—others may view and use that information. We are not responsible for the reuse of publicly shared information.

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Privacy Rights and Choices

We aim to give you clear options when it comes to your personal information. Your available rights may depend on your jurisdiction and how you interact with our Services.

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Managing Your CocoaDreams Account

If you have a registered account with CocoaDreams, you can review, update, or delete certain information by logging into your account. You may also request full account deletion by contacting us.

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Marketing Communications

You can opt out of receiving marketing emails or messages by using the unsubscribe link at the bottom of our emails or replying “STOP” to WhatsApp messages. Please note that you may still receive service-related notifications (e.g., order updates or account alerts).

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Your Data Rights

Depending on your region and applicable laws, you may be entitled to:

• Know what personal data we collect and how we use it (provided in this Privacy Policy).
• Access your personal information, including a portable, machine-readable copy where applicable.
• Correct inaccurate or outdated information.
• Delete your personal data when no longer needed for services or lawful purposes.
• Opt out of the sale or sharing of personal information for interest-based advertising.
• Object or restrict certain types of data processing, including direct marketing.
• Withdraw your consent where consent was previously provided (e.g., for email marketing or cookies).

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How to Submit a Request

To exercise your data rights, you may:

• Contact us through the details in the “How to Contact Us” section below.

We may request additional verification information to confirm your identity before fulfilling your request. You may also appoint an authorized agent to act on your behalf, as allowed under applicable laws.

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Limits to Your Rights

In some cases, we may not be able to fulfill your request—for example, if doing so would violate another person’s rights, impair our ability to provide requested services, or conflict with legal obligations. Where that happens, we’ll let you know.

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Complaints

If you're unhappy with how we’ve handled your request or personal information, please contact us first so we can address your concerns. You may also have the right to file a complaint with your local data protection authority.

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Other Sites and Services

Our website and Services may include links to third-party websites and online services. These links and any embedded content are provided for your convenience and do not imply any affiliation, endorsement, or approval by Glowworm Enterprises Ltd or CocoaDreams.

We do not control and are not responsible for the privacy practices or content of any third-party websites or services. We encourage you to review the privacy policies of those third parties before providing any personal information.

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Google reCAPTCHA

To protect our Services from abuse and spam, we use Google reCAPTCHA, a service provided by Google Inc. reCAPTCHA helps us distinguish between human and automated access (e.g., bots) when you interact with our forms.

This service analyzes user behavior (such as mouse movements, time spent on site, and input patterns) along with device and browser metadata. This information is sent to Google and used in accordance with Google’s Privacy Policy and Terms of Service.

Your use of reCAPTCHA is subject to these policies.

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Security

We use a combination of technical, physical, and organizational safeguards to help protect your personal information. These may include encryption, access controls, firewalls, and secure server configurations.

While we do our best to protect your information, no security system is 100% secure, and we cannot guarantee the absolute safety of your data.

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International Data Transfers

Our website is operated in the United Kingdom, but your personal information may be stored or processed in other countries where our service providers operate, including the United States or the European Union.

When transferring personal data internationally, we implement appropriate legal safeguards such as:

• Standard Contractual Clauses approved by the European Commission or UK government,
• Adequacy decisions from regulatory bodies, or
• Other lawful mechanisms in accordance with applicable data protection laws.

For more information about international transfers and safeguards, please contact us using the details in the “How to Contact Us” section.

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Data Privacy Framework

Glowworm Enterprises Ltd participates in and complies with the principles of the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework (collectively referred to as the “Data Privacy Framework”), as established by the U.S. Department of Commerce.

We are committed to adhering to the Data Privacy Framework Principles for all personal information received from the EU, UK, and Switzerland in reliance on the Framework. If there is any conflict between this Privacy Policy and the Principles, the Principles shall govern.

To view our certification or learn more, visit the official Data Privacy Framework website.

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Handling Complaints and Dispute Resolution

If you are located in the EU, UK, or Switzerland and have questions or concerns about our handling of your personal data under the Data Privacy Framework, please contact us at supporrt@cocoadreams.co.uk.

We have committed to refer unresolved complaints to JAMS, an alternative dispute resolution provider located in the United States. You may file a complaint free of charge by visiting:
👉 https://www.jamsadr.com/DPF-Dispute-Resolution

If your concern is not resolved by either us or JAMS, you may have the option to pursue binding arbitration through the Data Privacy Framework Panel. More details can be found here.

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Government and Legal Disclosures

We may be required to disclose your personal information in response to lawful requests by public authorities, including for national security or law enforcement purposes.

Our commitments under the Data Privacy Framework are subject to the investigatory and enforcement powers of the UK Information Commissioner’s Office (ICO) and the U.S. Federal Trade Commission (FTC).

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Children

Our Services are not directed to or intended for use by children under the age of 16. We do not knowingly collect personal information from children under 16 without parental or guardian consent as required by applicable law.

If we become aware that we have collected personal information from a child without the necessary consent, we will take steps to delete it promptly.

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Job Applicants

If you submit a job application to Glowworm Enterprises Ltd via our website or any recruitment platform, we may collect personal data such as:

• Contact information
• Work history, education, skills, and certifications
• Any details included in your CV or cover letter
• Voluntary diversity data (where applicable)

This information is used solely for recruitment-related purposes, including:

• Evaluating your application and qualifications
• Conducting interviews or follow-ups
• Complying with legal obligations
• Managing hiring statistics and reports

We may also use this data to protect our rights and comply with laws where necessary, including cooperating with investigations or legal requests.

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Retention of Personal Information

We retain your personal information only for as long as necessary to:

• Fulfil the purposes for which it was collected
• Comply with legal, regulatory, and tax obligations
• Maintain records for audits, compliance, or dispute resolution

To determine appropriate retention periods, we consider the type of data, its sensitivity, the potential risks of unauthorized use, legal requirements, and whether the original purpose can still be met in another way.

Once retention is no longer necessary, we securely delete or anonymize the data.

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Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If changes are significant, we will:

• Update the “Last Updated” date at the top of the page
• Post the revised version to this page
• Notify you in a prominent way (e.g., email or banner notification) if legally required

Your continued use of the Services after changes become effective constitutes your agreement to the updated policy.

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How to Contact Us

Glowworm Enterprises Ltd is the data controller responsible for handling your personal information.

For questions, concerns, or data protection matters, contact us at:

📧 Email: support@cocoadreams.co.uk
🏢 Postal Address:
White Lodge, Light Alders Lane, Stockport, United Kingdom, SK12 2LW

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Privacy Snapshot

Here’s a simplified overview of the key data we collect and how it’s used. For full details, please refer to the complete Privacy Policy.

1. Identifiers (e.g. name, email address, IP address)

How we collect it: When you provide it during checkout, sign-up, or interact with our Services.
Why we collect it: To process orders, verify your identity, support your account, and send relevant updates or offers.
Who we share it with: Trusted service providers (cannot be limited) and select third parties for marketing (you can opt out).

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2. Contact and Account Information

How we collect it: Through forms, subscriptions, customer support, and account creation.
Why we collect it: To communicate with you, provide support, ship products, and manage your account.
Who we share it with: Service providers for fulfillment and communication. Marketing partners only with your consent.

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3. Purchase & Commercial Data (e.g. product orders, transaction history)

How we collect it: From your interactions with our website and your purchases.
Why we collect it: To fulfill orders, manage subscriptions, track preferences, and personalize your experience.
Who we share it with: Payment processors and logistics partners (not limitable); marketing services (can be limited).

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4. Device and Browsing Data (e.g. cookies, IP, browser type)

How we collect it: Automatically when you browse our site.
Why we collect it: To analyze site performance, improve user experience, and personalize offers.
Who we share it with: Analytics platforms and advertising services.

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5. Inferred Data (e.g. preferences, interest profiles)

How we collect it: Based on your activity across our website and marketing interactions.
Why we collect it: To tailor content, optimize marketing, and improve product offerings.
Who we share it with: Service providers and third-party marketing tools (you can opt out).

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6. Geolocation Data (approximate location)

How we collect it: Based on your device, IP address, or browser settings.
Why we collect it: To tailor experiences based on your region and prevent fraud.
Who we share it with: Fraud protection systems and analytics services.

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