If you would like to adjust, access, remove or opt-out your personal data at any time, please emails your request to us at firstname.lastname@example.org.
This Policy covers your access to our Services and to this Site. The Policy does not cover the “content” that is distributed within our Services (including with respect to personal information included in such content). This Policy also does not cover other websites, such as those relating to our third-party sponsors, advertisers, and other partners. Further, if this Site is available through any third-party platform, or if we provide links from this Site to any third-party platform, then we do not accept responsibility for any content or practices of such third parties.
Our Services are not intended for anyone under 18 years of age, and by using our Services and this Site, you represent to us that you are at least 18 years of age. We do not target children and do not knowingly collect or use any personal information from anyone under the age of 18.
We provide or Services and operate this Site from our offices within the United States. We do not represent that our Services or this Site are appropriate or available for use in other locations, and access to our Services or this Site from territories where our Services or Site are illegal or this Policy is unenforceable or prohibited. If you choose to access our Services or this Site from locations outside the United States, you are solely responsible for compliance with applicable laws.
- WHAT SORT OF INFORMATION DO YOU COLLECT AND USE?
The type of personal information we collect depends on how you are specifically interacting with us and which Services you are using.
Generally, we collect the following categories of personal information:
- Contact information, such as name, alias, address, phone number, email address, and similar contact data.
- Account information, such as security-related information (including user names and passwords, authentication methods, and roles), service-related information (including purchase history and account profiles), billing-related information (including payment, shipping, and billing information), and similar data.
- Log data, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
- Usage information, such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information,), content interactions (including searches, views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction, and similar data.
- Location data, such as the location of your device, your household, and similar location data.
- Financial information, such as billing address, credit card information, billing contact details, and similar data.
- WHERE DO WE GET THE INFORMATION YOU COLLECT?
We collect personal information about you either directly from you or from certain third parties.
You provide personal information to us when you:
- Search for, subscribe to, or purchase our Services.
- Use our Services or otherwise interact with us.
- Create or maintain a profile or account with us.
- Purchase, use, or otherwise interact with content, products, or services from third-party providers who have a relationship with us.
- Request or sign up for information.
- Communicate with us by phone, email, chat, in person, or otherwise.
- Complete a questionnaire, survey, support ticket, or other information request form.
We collect personal information automatically when you:
- Search for, visit, interact with, or use our Services.
- Access, use, or download content from us.
- Open emails or click on links in emails or advertisements from us.
- Otherwise interact or communicate with us.
We also collect personal information about you from third parties, such as:
- Third parties and affiliates who resell or integrate with our Services.
- Service providers and business partners who work with us in relation to our Services and that we may utilize to deliver certain content, products, or services or to enhance your experience.
- HOW DO WE USE AND SHARE YOUR INFORMATION?
Our primary goal in collecting, using, and sharing your information is to enhance and improve our Services. We will not use or share your user information without a valid legal basis to do so, and, except as required by law or legal process, we will only share your information to third parties in an anonymous, aggregated form that does not identify you.
We use your information for the following purposes:
- To provide, deliver, analyze, and administer our Services.
- For internal research and development purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our current Services.
- Process transactions related to our Services and administer accounts or profiles related to you or your organization (including registrations, subscriptions, purchases, billing events, royalty calculations, and payments).
- Personalize and make recommendations related to our Services and other offerings.
- Contact and communicate with you in connection with our Services or other notifications, programs, events, or updates that you may have registered for.
- Send you offers, advertising, and marketing materials, including to provide personalized advertising to you.
- Comply with your instructions or to fulfill other specified purposes for which you have given your consent. For example, if you share your name and contact information to ask a question about our Services, we will use that personal information to respond to your inquiry.
- Detect and prevent fraud and abuse to ensure the security and protection of all customers and others, as well as to identify and authenticate your access to our Service or to identify and authenticate you before we provide you with certain information.
Comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or government authority.
- Effectuate the sale, merger, acquisition, or other disposition of our assets or business (including in connection with any bankruptcy or similar proceedings).
We share your information with the following categories of recipients:
- Our business partners, in order to jointly offer, provide, deliver, analyze, administer, improve, and personalize products or services (including our Services) or to host events.
- Third-party content providers to perform tasks on our behalf and to assist us in providing, delivering, analyzing, administering, improving, and personalizing the content that is delivered as part of our Services.
- Our third-party service providers to perform tasks on our behalf and to assist us in offering, providing, delivering, analyzing, administering, improving, and personalizing our Services. For example, service providers who assist us in performing, delivering, or enhancing certain products and services related to our delivery and operation of our Services, who provide technical and/or customer support on our behalf, who provide application or software development and quality assurance, who provide tracking and reporting functions, research on user demographics, interests, and behavior, and other products or services.
- A third party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control (such as the result of a bankruptcy proceeding).
- Third parties if we reasonably believe that disclosure of such information is helpful or reasonably necessary to comply with any applicable law or regulation, to comply with or respond to a legal process or law enforcement or governmental request.
We use the following types of cookies :
- Strictly Necessary. These cookies are essential for our Services to perform their basic functions. These include cookies that are required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” for e-commerce functionality.
- Analytics and Performance. Performance cookies collect information on how users interact with our Services, including what pages are visited most, as well as other analytical data. We use these details to improve how our Services function and to understand how users interact with our Services.
- Functionality. These cookies are used to store preferences set by users such as account name and language
- Security. We use these cookies to help identify and prevent potential security risks.
- Advertising. These cookies are used to display relevant advertising to users who use our Services, as well as to understand and report on the efficacy of ads served on our Services. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build user profiles, including showing you ads based on products or services you’ve viewed or acts you have taken.
- Third-Party / Embedded Content. Services hosted by us make use of different third-party applications and services to enhance the experience of our Services. As a result, cookies may be set by third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
- SECURITY AND RETENTION
We value your trust in providing us your personal information. Taking into account the nature, scope, context, and purposes of processing personal information, as well as the risks to individuals of varying likelihood and severity, we have implemented technical and organizational measures designed to protect the security of personal information. However, no method of data transmission over the Internet or method of electronic storage is foolproof. Therefore, we do not guarantee the absolute security of your information. Our security procedures also mean that we may request proof of identity before we disclose personal information to you or before we process your other requests.
We retain personal information in accordance with our enterprise records retention schedule, which varies by business function, record classes, and record types. We calculate retention periods based upon and reserve the right to retain personal information for the periods that the personal information is needed to: (a) fulfill the purposes described in this Policy, (b) meet the timelines determined or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.
- ACCESSIBILITY AND CONFLICTS
We are committed to ensuring this Policy is accessible to individuals with disabilities. If you wish to access this Policy in an alternative format, please contact us as described below.
Depending on the specific interactions you have with us, we may provide different or supplemental privacy statements that describe and govern how we use your personal information. When we do so, those different or supplemental privacy statements apply to those specific interactions you have with us.
- CALIFORNIA RESIDENTS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. For more information on, please reference our CCPA notice at the end of this document.
You have certain rights over your data, as described in this Policy, including:
- You have the right to be informed, which means that anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
- If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You have the right to receive this data in a commonly used, machine-readable format.
- You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
- You have the right to have your data amended or corrected. The process for doing that is described later in this Policy.
- You have the right to restrict or object to further processing of your data.
- You have the right to submit a complaint related to the use or collection of your information.
- CONTACT AND NOTICES
We may give notice by means of a customer notification on this Site, electronic mail to your e-mail address on record, or by written communication sent by first-class mail or pre-paid post to your address that you have provided to us. By using our Services or this Site, you agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.
You may give notice to us, or contact our Data Protection Officer, at any time by:
letter sent by e-mail to email@example.com
or by letter delivered first-class mail to
595 Pacific Ave,
4th Floor San Francisco,
All notices shall be deemed to have been given 5 days after mailing (if sent by first class mail) or 24 hours after sending by e-mail. We will respond to any request to exercise a right noted in this Policy within 30 days.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
- INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). In particular, we collect the following categories of Personal Information:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
- SOURCES OF PERSONAL INFORMATION
We collect Personal Information either directly from you or from certain third parties, including the following sources:
|A. Personal Information you provide directly||Search, subscription information, billing, and purchase information; account and profile information, information about how you interact with our content; sign up information; communications with us be phone, email, chat, or otherwise, questioner and survey information.|
|B. Personal Information you automatically provide indirectly||Information regarding your interaction with our website; download content; email interaction; device information; browser type; date and time of your requested and referral URL; your IP Address.|
|C. Personal Information from third-parties||Information from service providers and business partners who work with us in relation to our content and services.|
- USE AND SHARING OF PERSONAL INFORMATION
We will not use or share your Personal Information without a valid legal basis to do so, and we will only share you’re your Personal Information to third parties in an anonymous, aggregated form that does not identify you.
|A. Internal business purposes||Provide, deliver, analyze, and administer our content and services; internal research and development purposes; to process transactions related to our content and services; personalize and make recommendations related to our content, services, and other offerings; contact and communicate with you in connection with our services; send you offers, advertising, and marketing materials; comply with your instructions or to fulfill other specified purposes for which you have given your consent; detect and prevent fraud and abuse; comply with the law and; and effectuate the sale, merger, acquisition, or other disposition of our business.|
|B. To share aggregated and anonymized date with certain third parties||To offer, provide, deliver, analyze, administer, improve, and personalize products or services with joint business partners; to allow third-parties to perform tasks on our behalf and to assist us in providing, delivering, analyzing, administering, improving, and personalizing our content; to a third party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control; to third parties if we reasonably believe that disclosure of such information is helpful or reasonably necessary to comply with any applicable law or regulation.|
- ACCESS AND DELETION REQUEST RIGHTS
You, as a California resident, have the right to request what information we collect, use, and disclose. This right includes the right to request any or all of the following: (1) specific pieces of Personal Information that we have collected about you; (2) categories of Personal Information we have collected about you; (3) categories of sources from which the Personal Information was collected; (4) categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you; (5) categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and (6) the business or commercial purpose for collecting or, if applicable, selling Personal Information. You also have the right to request that we delete the Personal Information about you that we have collected or maintain.
To make a request to access or delete your Personal Information, you can contact us at
https://cobalt.co/about/contact/. Provide us enough information to verify your identity. We will use the information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill. You can designate an agent to make a request on your behalf by either: (1) having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or (2) by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf. Any disclosures we provide will only cover the 12-month period preceding your verifiable request.Please note, we may deny your deletion request if retaining the information is necessary for us to: (1) complete the transaction for which we collected the personal information or otherwise perform our contract with you; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; (3) debug products to identify and repair errors that impair existing intended functionality; (4) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); or (5) comply with a legal obligation.
- PERSONAL INFORMATION SALES OPT-OUT
Before selling your Personal Information to any third-party, we aggregate, deidentify, or anonymize your Personal Information, so it no longer meets the personal information definition under the CCPA. However, should we decide to sell non-aggregated Personal Information, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following link: [firstname.lastname@example.org]. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.
- SHINE THE LIGHT LAW
We do not disclose Personal Information to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
- CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this Notice at our discretion and at any time. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
We will not discriminate against California residents if they exercise any of the rights provided in this Notice. The additional rights contained in this Notice does not apply to employment-related Personal Information collected from California-based employees, job applicants, contractors, or similar individuals. We endeavor to respond to your verifiable requests within 45 days of its receipt.