CALIFORNIA RESIDENTS - additional information pertaining to CCPA
The California Consumer Privacy Act (“CCPA) provides certain rights for California consumers. If you are a consumer residing in California, the following additional terms apply to you.
You have the right to request that we disclose what personal information we collect, use, disclose, and sell. To submit a verifiable request, please visit https://www.coghlancapital.com/contact/ or email firstname.lastname@example.org
(a) Right to Know About Information Collected, Disclosed or Sold
If you have an account with us, we will verify the request by confirming the email address used to make the request is the same as the email address on file for the account. If you do not have an account with us, we will verify the request by sending an email to the email address used to make the request. We may ask for additional information reasonably related to the request to verify the request.
(b) Collection of Personal Information
The categories of California consumers’ Personal Information we may collect are listed above in Section 2 (“What Categories of Information We Process”). In reference to Section 2, we may collect Personal Details, Demographic Information, Contact Details, Consent Records, Location Information, Purchase and Payment Details. We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy. As detailed in Section 2, this may include, but is not limited to, information about your use of, visits to and interaction and engagement with the Services, content, all of which may be aggregated; browsing history; and searches for offers contained in the Services.
We may collect California consumers’ Personal Information from the sources listed in Section 4 (“How We Collect User Information”). As defined in Section 4, this may be: Data You Provide; Relationship Data; Data You Make Public; Service Data; Content and Advertising Information; Third Party Information. We may obtain personal information from the following sources as defined in Section 2 (“What Categories of Information We Process”): GeoIP Data; ID; IDFA; IP address; ISP; SSID; IMSI; IMEI; Log files; Web Beacons; Pixel Tags; Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, and equivalents.
We use this data for the purposes listed above in Section 5 (“Purposes for which we may Process your Personal Information”).
(c) Disclosure or Sale of Personal Information
We may and may have disclosed or sold the categories of Personal Information listed in Section 9 (“What Information We Disclose to Third Parties”) for a business or commercial purpose.
We may and may have disclosed Personal Information to the following categories of third parties for a business purpose:
- other entities within the Company group for a legitimate business purpose such as operating the Services and providing the Services to you;
- third party Processors for the purpose of providing the Services to you;
- third party providers where our Services use third party advertising, plugins or content;
- third party providers to assist with the collection, storage and segmentation of Online Data. These third party providers may collect User Information from our Services for their own purposes, including but not limited to, monitoring fraud around the web;
- third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Coghlan Capital with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser; and
- third party vendors involved in the administration of contests, quizzes, competitions, sweepstakes, or prize draws.
We may have disclosed Personal Information to the following categories of third parties for a business purpose or a commercial purpose:
- third party providers where our Services use third party plugins or content. If you choose to interact with any such plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider;
- third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, and information about your browser or operating system; (ii) combine User Information about you received from Coghlan Capital with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser;
- third parties such as advertisers who will use Online Data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture
The Services are not intended for use by minors. We do not sell personal information of minors under 16 years of age without affirmative authorization.
(d) Right to Request Deletion of Personal Information
You have the right to request deletion of Personal Information collected or maintained by us. To do so, please submit a request via https://www.coghlancapital.com/contact or email email@example.com. If submitting a request by email, we may ask for additional information to verify your request.
(e) Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of personal information by a business. To do so, please submit a request via https://ww.coghlancapital.com/contact or email firstname.lastname@example.org. If submitting a request by email, we may ask for additional information to verify your request.
(f) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You have the right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the California Consumer Privacy Act.
(g) Authorized Agent
To make a request under the California Consumer Privacy Act on a consumer’s behalf, we require a signed authorization letter from the consumer to email@example.com.
(h) Contact for More Information
2. What Categories of Information We May Process
Summary – Categories of Information We May Process
We may Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; information about your interactions with our content; and any views or opinions you provide to us.
We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable. “Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We may Process the following categories of Personal Information about you:
- Personal details: your name; username or log in details; password; areas or topics of interest; information provided in response to quizzes or surveys.
- Demographic information: gender; age/date of birth; salutation; and language preferences.
- Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
- Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
- Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
- Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
- Browsing history including the websites or other services you visited before and after interacting with the Services.
- Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
- Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.
- Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
- Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
- Device type, settings and software used.
- Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
- Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
- Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
- Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
- Mobile analytics to understand the functionality of our mobile applications and software on your phone.
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.
3. Sensitive Personal Information
Summary – Sensitive Personal Information
Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. The Services are not intended for use by children.
To the extent that information we collect is a special category of personal data subject to CCPA or GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you sign up for a newsletter on our site or agree to allow us to track you. You can withdraw your consent at any time by contacting us at firstname.lastname@example.org.
Children. The Services are not intended for use by children, especially those under 16 (or applicable age in your country) (“Minor(s)”). Minors should not provide any Personal Information or use our public chat. Minors under the age of 18 are not permitted to make purchases through the Services. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from a Minor , we will delete that information immediately.
4. How We Collect or Create Information
Summary – Collection and Creation of Information
We may collect or obtain User Information about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your Personal Information public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Services; when you visit our Services; when you register to use any part of the Services; or when you interact with any third party content or advertising on the Services. We may also receive User Information about you from third parties (e.g., social network sites). We may also create User Information about you, such as records of your interactions with us. Coghlan Capital is not responsible for Personal Information you volunteer about yourself in public areas of the Services. This Policy does not cover the practices of third parties who may provide information about you to Coghlan Capital.
Collection of User Information: We may collect User Information about you from the following sources:
- Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters or SMS messages; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; participate in surveys and quizzes; perform search queries through the Services; contact us via email, telephone or by any other means; make a purchase; etc.).
- Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
- Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
- Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
- Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; and social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.
Please note that Coghlan Capital is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us at https://www.coghlancapital.com/contact or via email at email@example.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.
Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also use User Information you have provided to us with data obtained from third parties to enhance our records or enhance our ability to provide products and services, such as appending additional information to your profile.
5. Purposes for Which We May Process Your Information
Summary – Purposes for Which We May Process Your Information
We may Process User Information for the following purposes: providing the Services to you; communicating with you; providing advertising to you on the Services; analyzing engagement with our audience; observing user engagement and purchase activity across the Service and Channels; offering lead generation services; marketing our services and offerings to current and prospective customers; managing our IT systems; financial management; conducting surveys and quizzes; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our Services.
The purposes for which we may Process User Information, subject to applicable law, include:
- Provision of the Services to You: providing the Services to you from Coghlan Capital or its partners including (i) offering of contests, as well as chat areas, forums and communities, (ii) management of your account, and (iii) customer support and relationship management.
- Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
- Identification: using information from third parties to verify information about you in order to provide the Services (e.g. verify your mailing address to send you requested products or services.
- Surveys and Quizzes: engaging with you for the purposes of obtaining your views on our Services, as well as learning more about your interests, including your interest in third parties and their offerings.
- Research: analyzing, benchmarking and conducting research based on User Information and your interactions with the Services.
- Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding content and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 6 below.
- Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties. For further information, please see Section 7 below.
- Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
- User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
- Marketing to Customers: We may market to current and prospective customers who have indicated an interest in doing business with, or have previously conducted business with, Coghlan Capital in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising, marketing our lead generation, job boards, and other business services offered by Coghlan Capital.
- IT Administration: administration of Coghlan Capital’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
- Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
- Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements
- Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
- Legal Proceedings: establishing, exercising and defending legal rights.