Cohley

Privacy Policy

Goldfish Social, Inc., d/b/a Cohley ("Cohley" or "We") is the controller and responsible for your personal data and respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website, https://www.cohley.com, or use any downloadable software application of ours (collectively, the "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally identifiable information' (“PII”) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What does this policy cover?

This policy applies to information we collect:

·      On this Website.

·      In email, text, and other electronic messages between you and this Website.

·      When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to information collected by:

·      us offline or through any other means, including on any other website operated by Cohley or any third party (including our affiliates and subsidiaries); or

·      any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

What personal information do we collect from the people that visit our blog, website or app?

We collect several types of information from and about users of our Website, including information:

·      by which you may be personally identified, such as PII and your name, postal address, e-mail address, telephone number, social security number, any other information the website collects that is defined as personal or personally identifiable information under any applicable law, and any other identifier by which you may be contacted online or offline ("personal information" or “personally identifiable information”);

·      that is about you but individually does not identify you;

·      about your internet connection, the equipment you use to access our website and usage details;

·      identity data, which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, including such information submitted by you for your dependents;

·      contact data, which includes billing address, delivery address, email address, and telephone numbers;

·      financial data, which includes bank account and payment card details;

·      transaction data, which includes details about payments to and from you and other details of products and services you have purchased from or rendered to Cohley or its clients;

·      technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;

·      profile data, which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

·      usage data, which includes information about how you use our website, products and services; and/or

·      marketing and communications data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

When do we collect information?

We collect information from you when you register on our site or enter information on our site, automatically as you navigate through the site, including usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies and from third parties, for example, our business partners.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

·      To personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested.

·      To improve our website in order to better serve you.

·      To allow us to better service you in responding to your customer service requests and to fulfill any other purpose for which you provide it.

·      To quickly process your transactions, answer your questions and respond to your requests.

·      To send periodic emails regarding your order or other products and services.

·      We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

How do we disclose your information?

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

·      To individuals or entities with whom you are negotiating any agreement or you have entered into an agreement.

·      To our subsidiaries and affiliates.

·      To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

·      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 our Website users is among the assets transferred.

·      To third parties to market their products or services to you if you have not opted out of these disclosures.

·      To fulfill the purpose for which you provide it. For example, if you give us an email address to use for a feature of our Website, we will transmit the contents of that email and your email address to the recipients. Alternatively, if you provide your dependent’s name, gender and date of birth, we will transmit such information to service providers.

·      For any other purpose disclosed by us when you provide the information.

·      With your consent.

We may also disclose your personal information:

·      To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·      To enforce or apply our terms of use, terms of sale and other agreements, including for billing and collection purposes.

·      If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

·      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

·      Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by contacting us at hello@cohley.com. You can also always opt-out by sending us an email stating your request to hello@cohley.com.

·      Promotional Offers from Cohley. If you do not wish to have your email address used by Cohley to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to hello@cohley.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Cohley as a result of a product purchase, warranty registration, product service experience or other transactions.

·      Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to hello@cohley.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

How do we protect visitor information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Do we use 'cookies'?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

       Understand and save user's preferences for future visits.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

If you disable cookies off, some features will be disabled It won't affect the user's experience that make your site experience more efficient and some of our services will not function properly.

However, you can still place orders.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. 

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hello@cohley.com.

According to CalOPPA we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum on the first significant page after entering our website.

Our Privacy Policy link includes the word 'Privacy' and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes:

       On our Privacy Policy Page

Users are able to change their personal information:

       By logging in to their account

How does our site handle do not track signals?

We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It's also important to note that we do not allow third-party behavioral tracking

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not specifically market to children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via email

       Within 7 business days

We will notify the users via in-site notification

       Within 7 business days

We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

FTC Regulations

All influencers and content creators on Cohley explicitly agree to abide by the Federal Trade Commission's stated policy on advertisement disclosures. Failure to do so may result in permanent expulsion from the Cohley platform, and any liability for failing to abide by these regulations falls squarely on the influencer, not the brand or agency using Cohley.

We collect your email address in order to:

       Send information, respond to inquiries, and/or other requests or questions.

       Process orders and to send information and updates pertaining to orders.

       We may also send you additional information related to your product and/or service.

       Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM we agree to the following:

       NOT use false or misleading subjects or email addresses.

       Identify the message as an advertisement in some reasonable way.

       Include the physical address of our business or site headquarters.

       Monitor third-party email marketing services for compliance, if one is used.

       Honor opt-out/unsubscribe requests quickly.

       Allow users to unsubscribe by using the link at the bottom of each email.


If at any time you would like to unsubscribe from receiving future emails, you can email us at

       Follow the instructions at the bottom of each email, and we will promptly remove you from ALL correspondence.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below.

Goldfish Social Inc.

251 W. 30th St. Floor 6

New York, New York 10001

hello@cohley.com


Last Edited on August 26, 2019