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Coegil Operations LLC

Last modified: 15 January 2024

 

Introduction

Coegil is committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy describes how Coegil Holdings, Inc. and its affiliates, including Coegil Operations LLC (“OpCo”) and Coegil Solutions LLC (“SolnCo”) (collectively, “Coegil,” “we,” “us,” or “our”), collect, use, share, and protect personal information of users of our Platform (as defined in our Terms of Use). If you have concerns about our privacy practices, please contact us at privacy@coegil.com.

What We Collect

We collect several types of information on our Platform including PI, which is information that can be used to identify you individually, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing information. We also collect anonymous information, which is information that is not associated with or linked to your PI and which, by itself, does not permit the identification of individual persons, including, for example, site visits and page views. The information we collect depends on what services you use on our Platform.

Information You Provide to Us

We may collect PI from you, such as your first and last name, email address and password for our Platform, phone numbers, company name, title, work and home address and contact information for other members of your company when you create an account on our Platform (“Account”). When you post certain content on our Platform, the information contained in your posting will be stored in our servers and other users of our Platform may be able to see it, along with any other information that you choose to make public through your profile (“Profile”). We retain information on your behalf, such as files, messages, data and chats that you store using your Account. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. When you participate in one of our surveys, we may collect additional PI. When you post messages and chats through our Platform and/or comment on content available through our Platform, the information contained in your posting and/or comment will be stored on our servers and other users will be able to see it. We may collect additional PI to validate your identity, such as your date of birth, place of birth or taxpayer identification number. We may request documents to verify this information, such as a copy of your government-issued identification or photo, and we may authenticate it against third party databases. We may collect samples of the Research Assets you submit to our Platform. We also collect other types of PI that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for our Platform. We may collect information regarding and in connection with the purchase by a Buyer of a Seller’s Asset (a “Transaction”), including, but not limited to, the Seller’s applicable terms and conditions and communications between Buyers and Sellers. If you participate in a contest, sweepstakes or other promotion, we will collect any data you provide in connection with that promotion. We may collect information you provide to us in connection with a dispute regarding a Transaction. We may also obtain information from other sources and combine that with information we collect on our Platform. We may also collect PI at other points in our Platform that state that PI is being collected.

Information Collected via Technology

Information Collected by Our Servers. To make our Platform more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

Log Files. We gather certain information automatically and store it in log files, including IP addresses, browser type, Internet service provider (ISP), referring/exit pages, pages visited on our site, operating system, date/time stamp, and clickstream data. We use this information to improve the content of our Platform, market research purposes, to communicate information to visitors and to better tailor our Platform to our users’ needs.

Cookies. We may log information using “Cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Platform. This type of information is collected to make our Platform more useful to you and to tailor the experience with us to meet your special interests and needs.

Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users but are embedded invisibly in Web pages.

Analytics. We use analytics services (including, but not limited to, Google Analytics) to help analyze how users use our Platform. Analytics services use Cookies and other technologies to collect information such as how often users visit our Platform and we use the information to improve our Platform. The analytics services’ ability to use and share information collected by them is restricted by their terms of use and privacy policy, which you should refer to for more information about how these entities use this information.

Product Improvement. We may use anonymized and aggregated usage data, performance metrics, and user interaction patterns to improve and develop our Platform features, including improvements to automation systems, user interface design, workflow optimization, and other product enhancements. This aggregated data does not identify individual users and is used solely to enhance the quality and functionality of our Platform. We do not use customer data to train or build AI models for sale or distribution to third parties.

Information Collected from You About Others. If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third-party’s names and e-mail addresses as required above. You or the third party may contact us at privacy@coegil.com to request the removal of this information from our database.

Use of Personal Information

We use PI collected through our Platform for purposes described in this Privacy Policy or disclosed to you in connection with our Platform. For example, we may use your information to:

  • Provide the service to you, such as to: identify you as a user in our system; provide and deliver products and services you request; operate, maintain, and improve our sites, products, and services; facilitate Transactions and resolve disputes between users; facilitate the creation of and secure your Account on our network; and process and deliver orders, whether through Stripe (as described below) or otherwise.
  • Communicate with you, such as to: send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; inform you about promotions, upcoming events, and other news about products and services offered by us and our selected partners; process and deliver promotions, contest entries and rewards; and respond to your comments and questions and provide customer service.
  • Understand your needs, such as to: link or combine user information with other PI we get from third parties, to help understand your needs and provide you with better service; and develop and improve marketing and advertising for our Platform and partner services. Secure the marketplace, such as to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • Sharing with Affiliates. We may share your personal information among our affiliated entities, including Coegil Operations LLC (OpCo) and Coegil Solutions LLC (SolnCo), for the purposes of providing Platform Services and Solution Services, billing and payment processing, customer support, and other business operations necessary to deliver our services to you. All affiliated entities are required to handle your personal information in accordance with this Privacy Policy.
  • We store and process PI in the United States. We may also create anonymous and/or deidentified information from your PI by excluding information (such as your name) and other elements that, when combined, makes the data personally identifiable to you. We use this anonymous information to enhance the content of our Platform and improve our Platform. We reserve the right to use anonymous information for any purpose and disclose anonymous data to third parties in our sole discretion.
  • We may get information about you from other sources. We may add this to information we get from our Platform.

User Testimonials and Feedback

We may receive testimonials and comments from users who have had positive experiences with our Platform. We may publish such content. When we publish this content, we may identify our users by their first and last name. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and one other relevant piece of information (e.g. industry or title). If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting your name with your feedback.

Use of Customer Name and Logo for Marketing

By using Coegil’s products and services, you grant us the right to disclose your use of our platform for marketing and promotional purposes. This includes, but is not limited to, the inclusion of your name, logo, and a brief description of your use of Coegil in our marketing materials, press releases, case studies, and on our website. We will ensure that the use of your name and logo is consistent with any brand guidelines you provide. If you wish to opt out of this use, you may do so by providing written notice to us at privacy@coegil.com. However, such opt-out will not apply to any materials already in circulation at the time of your notice.

Sharing of Personal Information

Information You Share. Our Platform allows you to connect and share content and information. Please be mindful of your own privacy needs as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public on our Platform. Content you submit to public areas of the Platform are posted in public areas and are not subject to the restrictions set forth in this Privacy Policy. If you share information about others, we suggest you get consent for any information you may share about them.

Information We Share. We may disclose aggregated information about our users and information that does not identify any individual without restriction. In addition, we may disclose PI that we collect, or you provide: to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, or with your consent; to third parties designated by you; with our subsidiaries and affiliates; in connection with facilitating a Transaction and resolving a dispute between users; with contractors, service providers and other third parties we use to support our business; with third parties to help process and deliver orders; to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users is among the assets transferred; and to comply with any court order, law or legal process, including responding to any government or regulatory request; to enforce our rights arising from any contracts entered into between you and us; and/or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Coegil, our customers or others.

Public Profile. Certain portions of the information you provide to us may also be displayed in your Profile. You can see which elements of your Profile are public or private and may adjust these settings. Content you post to the Site may be displayed on our Platform depending on whether the item is shown as “draft” or “published” and the location of the posting. Once publicly displayed, that information can be collected and used by others. We cannot control who reads your posting or what other users may do with the information that you voluntarily post, so it is very important that you do not put PI in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the Platform, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others (e.g., search engines).

Credit Card Information. Coegil does not collect, store or otherwise maintain any credit card information from individuals who make payments through the Platform. Payments, including information associated with your credit card, are collected and processed by our partners, including Stripe. Stripe is a payments processor that handles payments between buyer and seller. Payments will appear on the user’s credit card statement under the name of the Seller from whom they purchased Assets. All payments made through Stripe go directly from the Buyer to the Seller’s Stripe merchant account. All information associated with your use of Stripe will be handled in accordance with the terms of the Stripe Privacy Policy. When you make payments through the Platform and use Stripe to process your payment, you agree to the Stripe Terms of Use.

Information Choices and Changes

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about PI to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and review, update, correct, or delete your PI. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.

Third-Party Websites

Our Site may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

Information Security

We are committed to protecting the security of your PI. We use a variety of industry-standard security technologies and procedures to help protect your PI from loss, misuse and unauthorized access, use, disclosure, alteration, and destruction.

Data Breach Notification

In the event of a data breach that affects your personal information, we will notify you and any applicable regulatory authorities as required by applicable law. We will provide notice of the breach, the types of information involved, the steps we are taking to address the breach, and steps you can take to protect yourself. Notification will be provided without undue delay and, where feasible, within 72 hours of our becoming aware of the breach, as required by applicable data protection laws. We will notify affected users via email to the address associated with their account, and may also provide notice through our Platform or website.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

  • Account Information: For the duration of your relationship with us, plus three (3) years after account closure or termination for business records and legal compliance purposes.
  • Transaction and Billing Data: Seven (7) years after the transaction date to comply with tax, accounting, and legal requirements.
  • Customer Data: Until you request deletion or your account is terminated. Following account termination and payment of all amounts owed, we will delete Customer Data within thirty (30) days unless you request migration services or we are required to retain it by law.
  • Usage and Analytics Data: Aggregated and anonymized usage data may be retained indefinitely for product improvement and business analytics purposes.
  • Marketing Communications: Until you opt out or unsubscribe, after which we will cease sending marketing communications but may retain your contact information to honor your opt-out preferences.

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with applicable law.

Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

  • Right to Access: You may request access to the personal information we hold about you and receive a copy of such information.
  • Right to Correction: You may request that we correct inaccurate or incomplete personal information about you.
  • Right to Deletion: You may request that we delete your personal information, subject to certain exceptions (such as where we are required to retain information by law or for legitimate business purposes).
  • Right to Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format.
  • Right to Opt-Out: You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions in our emails or contacting us directly.
  • Right to Object: You may object to certain processing of your personal information, including processing for direct marketing purposes.
  • Right to Restrict Processing: You may request that we restrict processing of your personal information in certain circumstances.
  • California Residents: If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, use, disclose, and sell (if applicable), and the right to request deletion of your personal information. California residents may exercise these rights by contacting us as described below.
  • European Economic Area and UK Residents: If you are located in the EEA or UK, you have rights under the General Data Protection Regulation (GDPR), including those described above. You also have the right to lodge a complaint with your local data protection authority.

To exercise any of these rights, please contact us at privacy@coegil.com. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.

Do Not Sell My Personal Information

Coegil does not sell your personal information to third parties. We do not and will not sell your personal information for monetary or other valuable consideration. If our practices change, we will update this Privacy Policy and provide you with the ability to opt out of such sales as required by applicable law.

For California residents: You have the right under the California Consumer Privacy Act to opt out of the sale of your personal information. Because we do not sell personal information, there is no need to opt out. If you have questions about our data practices, please contact us at privacy@coegil.com.

How We Respond to Do Not Track Signals

We do not currently support technology to actively integrate “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site; however, users may email us directly to be removed from any tracking.

A Note About Children

We do not intentionally gather PI from users who are under the age of 13. If a child under 13 submits PI to Coegil and we learn that the PI is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any PI from a child under 13, please contact us at privacy@coegil.com.

International Users and Data Transfers

The Platform is available to users in the United States, European Union, and United Kingdom. By using our Platform, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. Your personal information may be transferred to, stored, and processed in the United States and other countries where Coegil or its service providers operate. The data protection laws in these countries may differ from the laws in your country. By using our Platform, you consent to such transfers. For users in the European Economic Area and United Kingdom, we implement appropriate safeguards for international data transfers as required by applicable law.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

Intellectual Property Rights

While using Coegil and having fully paid any due charges, you retain ownership of all rights, titles, and interests in and to the data you provide or generate while using our services, including any intellectual property rights therein. Coegil retains all rights, title, and interest in and to our platform, software, and services, including any enhancements, modifications, or derivatives thereof, as well as any associated intellectual property rights. You agree to the intellectual property terms as specified in our Terms of Use.

Contact Information

If you have a question or comment about this Privacy Policy or our privacy practices, please email us at privacy@coegil.com.

Changes to This Privacy Policy

We may change this Privacy Policy from time to time for any reason. If we make any changes, we will change the Last Updated date above and post the new Privacy Policy here: coegil.com/privacy-policy. You should consult this Privacy Policy regularly for any changes.