This Policy applies to processing of Personal Data collected by Cocohub in the process of:
- Receiving communications from Cocohub.
- Visiting our Website.
- The use of our Services through our Platform or any third party applications, by our Customers and our Customer’s Users.
- TYPES OF PERSONAL DATA COLLECTED BY US
A) Personal Data collected from data subjects (“Collected Data”)
- Sign-up, Account information and Billing Information.
When a Customer or a Customer User, signs-up to or uses any of our Services, Cocohub may collect its (i) contact information including name, e-mail address, phone number, mailing address, IP address, geographic location; (ii) billing information, including credit card data and billing address; and (iii) unique identifiers, such as username and password.
- Customer Data
When you use our Services, we process the Customer Data in accordance with and subject to our Data Processing Addendum [https://about.cocohub.ai/data-processing-addendum]. We may conduct analytics on such data to (i) evaluate your needs to determine or suggest our Services; (ii) send you information concerning our Services; (iii) provide response to customer requests and questions; and (iv) for products and Services improvement purposes.
- Usage Data
We collect and record audio, video, text, clicks, scrolls, conversion and drop-off on Services and Websites to render the Services in real-time. Subject to this Policy, we will use such data and Customer Data, including without limitation, to (i) evaluate your needs to determine or suggest our Services; (ii) send you information concerning our Services; (iii) provide response to customer requests and questions; and (iv) for products and Services improvement purposes, including to train our Services to better recognize human speech, interaction, and gestures.
- Cookies and equivalent technologies
Additional information collected by our Website and Services includes IP addresses, browser type, internet service provider, referring/exit pages, the content viewed on our Websites or Services, date/time stamp, and operating system. Such data may be linked to other data collected in your respect.
- Mobile Devices
When you use our Services through your mobile device, we will collect information on the type of your device, its operating system, and its identifier.
Cocohub may use mobile analytics services to better analyze the functionality of our Services and Websites on mobile devices. Such services may collect certain information such as frequency of use, aggregated usage, performance data, and the events occurring during use of our Services.
- Sign-in services
- Third party cookies and Social Media
B) Information collected from third parties
We may receive personal information from third parties like social media and other databases subject to such third parties having obtained your consent or are otherwise legally permitted or required to disclose such information to us.
Types of information obtained from third parties may include names, e-mail addresses, locations and telephone numbers and will be used by us for sales and marketing purposes, to maintain and improve our customer support and the accuracy of our records.
- OUR LEGAL BASIS FOR PERSONAL DATA PROCESSING
Personal Data is collected and processed by us for the following purposes and based upon the following basis:
- Provision of the Services, administering Customer’s or Customer User’s accounts, collecting fees and moneys due to Us, responding to service requests or questions, and evaluating your needs to determine or suggest our Services – Consent, Performance of Contract and Legitimate Interest.
- Prevention of and response to any misuse of the Services or any violations of applicable laws or our TOU – Legitimate interest.
- Performance of analytics, training of our algorithms, improving, developing, operating and supporting the Services and their availability, development of new products and services and provision of customized features and content – Consent and Legitimate interest.
- Sending promotional and marketing communications – Consent. If you do not wish to receive such communications, you can opt out by following the instructions set forth below.
- Responding to lawful requests by competent authorities, including as required under any security or law enforcement requirements and disclosure is necessary to protect our rights, comply with judicial proceedings, court orders or other legal process – Legal Requirement and Legitimate Interest.
- SHARING PERSONAL DATA WITH THIRD PARTIES
Personal Data is processed by Us and any third parties that we use, in the United States, Israel and the European Economic Area (“EEA”) and may be processed in other countries through third parties engaged by us.
Personal Data may be shared by us as follows:
- Third parties assisting Cocohub in provision of the Services (“Sub-Processors” listed in our Processors List [https://about.cocohub.ai/data-processors-list]). Sub-Processors are given access to Personal Data only as reasonably required for the provision of the Services;
- Third-party payment processors who process credit cards and other payment information for Cocohub;
- Third parties assisting Cocohub in our business activities, which may include marketing, advertising, support, technical operations, on boarding and maintaining and improving Services;
- Third parties providing services, such as analytics, anti-spamming ,anti-phishing;
- Third-party social media networks, advertising networks and websites;
- Third parties with which we may be involved in business transactions such as mergers, reorganizations, acquisitions or other fundamental corporate changes, including at the due diligence stage.
- INTERNATIONAL DATA TRANSFERS
- SECURITY MEASURES USED BY US
Our systems employ adequate technical and organizational measures for protection of Personal Data collected and processed by us. Such measures are intended to provide adequate level of security in respect of the risks involved in our processing of Personal Data.
Please note that information security risks are always evolving and cannot be completely avoided. The technical and organizational Data Protection measures employed by us are periodically examined within the scope of internal and external audits. For questions concerning the security of your Personal Data, please contact us.
- ADDITIONAL INFORMATION FOR EEA AND SWISS RESIDENTS
A) Collected Data
Individual residents of EEA or Switzerland, have the following data protection rights:
- You may access, correct, update or request deletion of your Personal Data, any time, by contacting us.
- You may object to processing of your Personal Data, ask to restrict processing of your Personal Data or request portability of your Personal Data, any time, by contacting us.
- You may opt-out of marketing communications sent by us at any time. You may exercise such right by clicking the applicable “unsubscribe” link in the communications sent by us. For opting out of other forms of communications (such as postal or telemarketing), please contact us.
- You may withdraw your consent for collection and processing of your Personal Data by us at any time.
- You may file a complaint to the competent data protection authority in respect of our collection and use of your Personal Data.
If you wish access, correct, update, modify or delete your Personal Data, please contact our DPO at email@example.com. We will use our best efforts to respond to all requests within a reasonable timeframe in accordance with applicable data protection laws.
B) Customer Data
Cocohub processes Customer Data on behalf of its Customers and has no direct relationship with the Customer Users whose Personal Data it processes as Customer Data. If you wish to access, or wish to correct, update, modify or delete Personal Data which is part of the Customer Data, you should request to exercise such rights directly from our applicable Customer which is deemed controller of such Customer Data. Customer Data removal requests will be processes by us within a reasonable timeframe in accordance with applicable data protection laws.
Customers of our Services who wish to raise a request on behalf of their Users in connection with Customer Data, may do so by contacting us at firstname.lastname@example.org.
- ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
‘Consumer’ as defined under the California Consumer Privacy Act of 2018 (“CCPA”) is entitled to the rights set forth below:
a. Right to request information concerning:
- Categories of Personal Data collected about you.
- Specific pieces of Personal Data collected about you.
- Categories of sources of collection of Personal Data.
- Business or commercial purposes for Personal Data collection.
- Categories of third parties with whom Personal Data is shared.
b. Right to request deletion of Personal Data collected about you.
If you wish to exercise any of the foregoing rights in respect of ‘personal information’ as defined in CCPA, please contact us at email@example.com. We will use our best efforts to respond to requests within a reasonable timeframe in accordance with applicable data protection laws. By contacting us, you agree to receive communications for the purpose of validating your identity and such other information reasonably required to process your request.
Please see the information set forth above in respect of categories of ‘personal information’ collected and categories of third parties with whom such ‘personal information’ is shared. For the avoidance of doubt it is hereby clarified that Cocohub does not sell ‘personal information’.
- OPTING OUT
If you no longer wish to receive communications from us, you may click on the “unsubscribe” link located on the bottom of our communications or you contact us at firstname.lastname@example.org.
- OTHER COMMUNICATIONS
Cocohub may send you communications on occasions when we deem it operationally necessary to do so, for example in cases of Services suspension for maintenance. Opting out of such communications (which are not promotional) is not possible. Customers who do not wish to receive such communications, will need to delete their Customer Account.
- PERSONAL DATA RETENTION
Personal Data which forms part of the Customer Data is retained and expunged in accordance with our TOU.
If you us to stop using and retaining your Collected Data, please contact us.
Notwithstanding the aforementioned, Collected Data and Customer Data will be retained by us for the periods required to comply with our legal obligations, for litigation purposes, for maintaining precise financial records and enforce our rights under valid contracts.
- . LINKS TO THIRD PARTY SITES
The Services and Website may contain links to third party websites that are not controlled by us. Cocohub is not responsible for the privacy practices of such third-party websites. You are highly encouraged to read the privacy policies of each such third website prior to allowing collection of your Personal Data.
- CHILDREN’S PERSONAL DATA
We do not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please refrain from submitting any Personal Data through Cocohub’s Websites or Services. Parents and legal guardians are highly encouraged to monitor their children’s Internet practices and prevent the provision of their Personal Data through our Services or Websites without their parents and legal guardians` permission. If you are aware that any Personal Data of a child under the age of 16 has been provided to us without permission of his parents and legal guardians, please contact us immediately and we will delete such information from our databases.
- GOVERNING LAW; JURISDICTION.