Last Updated: September 15, 2014
This Privacy Statement (“Privacy Statement”) explains how COCG (“COCG,” “us,” “our,” and “we”) uses your information and applies to all who use our website, mobile applications, electronic services, or social networking sites.
Please read this Privacy Statement carefully and review it periodically for the latest information about our privacy practices. By using the Site, you agree to the terms of this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, please do not provide us with your personal information or interact with the Site.
We will routinely update this Privacy Statement to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features to the Site. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on the Site prior to the change becoming effective. You can determine when this Privacy Statement was last revised by referring to the date it was “Last Updated” above.
1. Types of Information We Collect
We will collect information, including Personal Information and Non-Identifying Information, when you interact with us and the Site, for example when you:
- access or use the Site;
- open or respond to our e-mails;
- visit any page online that displays our content;
- pay invoices through the Site; and
- connect or link to any Site via social networking sites.
This Privacy Statement does not apply to the collection of information in any way other than as listed above.
2. Your Choices
We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to COCG, and you can limit the communications that COCG sends to you.
You can manage your subscriptions by following subscription management instructions contained in the e-mails that we send you. You may choose to subscribe to some types of messages, and may choose to unsubscribe from others. You may update your subscription preferences at any time. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and invoices.
You may manage how your browser handles Cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.
You may manage how your mobile device and mobile browser share certain Device Data with COCG, as well as how your mobile browser handles Cookies by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
3. How COCG Uses Information
We (or our Vendors on our behalf), use information collected as described in this Privacy Statement to:
- Operate, maintain and improve the Site and our services;
- Answer your questions and respond to your requests;
- Perform analytics and conduct client research;
- Communicate and provide additional information that may be of interest to you about COCG, sometimes by combining your information with information from Other Sources;
- Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information;
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us;
- Manage our everyday business needs, such as administration of the Site, analytics, fraud prevention, or to comply with the law;
- Allow you to pay invoices;
- Allow you to apply for a job; and/or to
- Enhance other information we have about you directly or from Other Sources to help us better understand you and determine your interests.
We also may use information collected as described in this Privacy Statement with your consent or as otherwise required or permitted by law.
4. When and Why COCG Discloses Information
We (or our Vendors on our behalf) may share your Personal Information as required or permitted by law:
- with our Vendors to provide services for us and who are required to protect the Personal Information;
- with a purchaser of COCG;
- to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;
- to combat fraud or criminal activity, and to protect our rights and users, or as part of legal proceedings affecting COCG;
- in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate; or
- with your consent.
We may also disclose Non-Identifiable Information:
- for the same reasons we might share Personal Information; or
- to facilitate targeted content and ads.
5. How COCG Collects Information
You provide us with your Personal Information when you register, subscribe, pay an invoice, or otherwise when you provide us with your Personal Information during your interaction with the Site. We also collect Personal Information when you contact us online for customer service and other support using self-help tools, such as email, or text.
When you access these pages or open email messages, we use Pixel Tags and Web Beacons to generate a notice of that action to us, or our Vendors. These tools allow us to measure response to our communications and improve the Site’ pages.
Device Data may be collected when your device interacts with the Site and COCG, even if you are not logged into the Site using your device. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
6. Security of Personal Information
COCG has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information.
7. Accessing and Correcting Personal Information
We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. Privacy Practices of Third Parties
This Privacy Statement only addresses the use and disclosure of information by COCG through your interaction with the Site. Other websites that may be accessible through links from the Site may have their own privacy statements and personal information collection, use, and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information.
9. Children’s Privacy
COCG does not intend that any portion of the Site will be accessed or used by children under the age of thirteen, and such use is prohibited. The Site is designed and intended for adults. By using COCG, you represent that you are at least eighteen years old.
10. Contact Us; California Privacy Rights and Other Countries
Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can reach us via email at support@COCG.co or via postal mail at the following address:
Click Optimize, LLC (DBA COCG)
700 Blue Ridge Rd.
Raleigh, North Carolina 27606 USA
If you reside in Canada, you may have the right to be provided with access to Personal Information that we have collected about you and written information about our policies and practices with respect to the transfer of your personal information to Vendors outside Canada. E-mail us at support@COCG.co with questions.
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the proceeding calendar year. In particular, the law provides that companies must inform consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by COCG pursuant to Section 1798.83 of the California Civil Code, please contact us via the email or address stated above. Please allow 30 days for a response.
11. Do Not Track
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
12. Glossary of Terms
Cookie means a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Site. Some cookies are temporary, whereas others may be configured to last longer. “Session cookies” are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent cookies” are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser.
Device Data means information concerning a device you use to access, use, or interact with the Site, such as operating system type or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
Non-Identifying Information means information that alone cannot identify you, including data from Cookies, Pixel Tags and Web Beacons, and Device Data. Non-Identifying Information may be derived from Personal Information.
Other Sources means sources of information that legally provide COCG with your information, and which are outside the scope of this Privacy Statement at the time of collection.
Personal Information means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. This includes the following types of information:
- Contact Information: your name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.
- Relationship Information: information you provide that enables us to determine lifestyle, interests, and activities, including location information related to your state/province, city, or neighborhood; and areas of interest, the types of deals that interest you, information collected through your interactions with social networks, demographic information (e.g., birth date, age, gender); and
- Financial Information: information collected from you as needed to process payments for COCG services that you buy, or as provided by you to administer your participation in optional services and programs, such as your payment card number, expiration date, and card verification number.
Pixel Tags and Web Beacons means tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions.
Third-Party Ad-Servers means Vendors and other third parties that provide the technology to place ads on websites and track ad performance.
Vendors mean, collectively, third parties that perform business operations on behalf of COCG, such as transaction processing, billing, mailing, communications services (e-mail, direct mail, etc.), marketing, data processing and analytics, servicing, collections, or ad management.