This Privacy Policy explains the manner in which the team that runs the Cocodum website (the "Website") – "Cocodum", "we", "us" or "our" – collects and processes your personal data when you use the Website, together with the rights available to you in respect of that data.

Cocodum acts as the data controller in respect of the personal data described herein. Any question relating to privacy may be addressed to contact@cocodum.com.

Cocodum processes personal data in accordance with the UK GDPR and the Data Protection Act 2018.

Cocodum collects the following categories of personal data:

• Account data – your first name and surname, title, email address, telephone number, year of birth, preferred language, password (stored in hashed form), account type (Private or Trader), how you heard about Cocodum (where you tell us) and your email preferences.
• Business data (Traders) – company name, business number and business unit, VAT number, website, industry, the name of the authorised signatory, your job title, trade references, the name of your bank, and the addresses of the registered office, of the bank and of the company. Cocodum uses this data to review your application for a Trader account.
• Profile data – your profile picture and, in the case of Traders, the background image and "about" description that you elect to provide.
• Listings data – the content of your Ads and Events, including titles, descriptions, prices, photographs, categories and location (the city and, for Events, the full address or an indication that the Event is held online).
• Messages – the content of the messages that you exchange with other Users through the Website.
• Favourites – the Ads and Events that you save.
• Account history – the date of your last login and the IP address used, the changes to the status of your account (verification, suspension, closure) and, where you close your account, the reason that you elect to give.
• Emails – a copy of the emails that Cocodum sends you, together with their delivery status.
• Usage and technical data – your IP address, device and browser information, and data concerning your use of the Website, collected in part by means of the session cookie described in Section 6.
• Reports and correspondence – the information that you provide when you report content, contact Cocodum or complete our contact form.

The Website is intended for persons aged 18 or over; Cocodum does not knowingly collect the personal data of any person under 18 years of age.

Cocodum processes your personal data for the following purposes, on the legal bases indicated:

• to create and administer your account, and to publish and display your Ads, Events and profile (our legitimate interests);
• to check, by means of your year of birth, that you meet the minimum age set out in our Terms of Use (our legitimate interests);
• to operate the messaging, favourites, reporting and related features (our legitimate interests);
• to review applications for a Trader account and check the business details provided (our legitimate interests);
• to keep a record of the changes to the status of accounts and of the reasons given for closing them (our legitimate interests);
• to maintain the safety of the Website, prevent fraud and misuse, moderate content and comply with our legal obligations (our legitimate interests / compliance with a legal obligation);
• to respond to your reports, enquiries and complaints (our legitimate interests);
• to send service communications and, where you have opted in, newsletters or marketing communications (your consent, which may be withdrawn at any time; service communications rely on our legitimate interests);
• to improve and secure the Website and to maintain our records (our legitimate interests);
• to comply with our legal and regulatory obligations (compliance with a legal obligation).

You may manage your marketing and alert preferences at any time within your account settings.

Cocodum does not sell your personal data. Cocodum discloses it only where necessary, namely to:

• Other Users and visitors – your public profile and your listings are visible to anyone who visits the Website; your messages are visible only to the User with whom you exchange them. A Private profile displays your first name, your profile picture and the date on which you joined. A Trader profile also displays the company name, the registered office address, the VAT number, the telephone number, the website and the first name of the account manager. Your surname is never displayed. You should not include sensitive personal data in any listing or message.
• Service providers – hosting, email-delivery and similar providers who process data on Cocodum's behalf and on its instructions (processors).
• Authorities – law enforcement agencies, regulators or courts where Cocodum is required by law to disclose, or where disclosure is necessary to protect its rights, its Users or the public.

Where a User obtains the personal data of another User through the Website, that User alone is responsible for the use it makes of such data (see our Terms of Use).

Cocodum retains personal data only for as long as is necessary for the purposes set out above:

• Account, listings and messages – retained for as long as your account remains open. When an account is closed, Cocodum applies a soft deletion: the account, its Ads and its Events are no longer displayed on the Website, but the data is retained, without a set end date, for legal, security, fraud-prevention and record-keeping purposes. For the same reasons, the email address of a closed account cannot be used to open a new account.
• Reports, messages sent to Cocodum and the history of account statuses – retained without a set end date, for the same purposes.
• Emails – the copy of an email is retained for 90 days, then moved to an archive which is kept for one year and then deleted.
• Single-use links (such as account confirmation and password reset) – deleted 30 days after they expire.
• Session – the session data is deleted after one day without use.

Cocodum uses a single cookie: the session cookie, which keeps you signed in and allows the Website to work properly (for example, to count a visit to an Ad only once). It is strictly necessary, it expires when you close your browser, and Cocodum uses no advertising or analytics cookie. You may block cookies through your browser settings, but you will then be unable to sign in.

Under applicable data protection law, you have the right to: obtain access to your personal data; obtain the rectification of inaccurate data; obtain the erasure of your data in certain circumstances; restrict or object to certain processing; data portability; and withdraw your consent at any time where processing is based on consent. To exercise any of these rights, please contact contact@cocodum.com. Cocodum will respond within the period required by law.

Should you be dissatisfied with the manner in which Cocodum handles your data, you are entitled to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk, although Cocodum would welcome the opportunity to address your concern in the first instance.

Cocodum implements appropriate technical and organisational measures to protect your personal data, including the hashing of passwords and the server-side validation and re-encoding of uploaded images. As no system can be rendered entirely secure, Cocodum cannot guarantee absolute security; you are requested to keep your login credentials confidential and to use a strong and unique password.

Cocodum may amend this Policy from time to time; the version published on the Website is the version in force from time to time, and Cocodum will take reasonable steps to notify you of any material change. This Policy is furnished in English and in French, and the English version shall prevail in the event of any inconsistency. Effective date: 20 October 2026. Enquiries may be addressed to contact@cocodum.com.