COCONA, INC. PRIVACY POLICY

Cocona, Inc. d/b/a Cocona Labs (“COCONA,” “Company,” we,” “us,” “our,” or similar pronouns) (“Company” or ”We”) respect 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 www.thirtysevenfive.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

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, giveaways and applications on third-party websites and services including but not limited to social media platforms

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company 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 through the Website.

By accessing this Website, you agree to be bound by the following Website Terms of Use [www.thirtysevenfive.com/terms] and Privacy Policy (together the “Terms”). Further, you represent and warrant that: (a) you are 18 years of age or older; (b) if you are under the age of majority in your jurisdiction, you have your parent’s or legal guardian’s authorization to use and access this Website and to agree to these Terms; (c) you own or have authorization to use the personal computer, mobile device, tablet, or other electronic computing device used to access this Website; and (d) you will use this Website in accordance with these Terms. 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.

Information We Collect About You and How We Collect It

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

  • Personal Information.  By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”)
  • Non-Personal Information.  Non-Personal Information is aggregated information, demographic information and any other information that does not reveal your specific identity.
  • About your internet connection, the equipment you use to access our Website, and usage details such as your IP Addresses.  Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever users visit the Site, along with the time(s) of such visit(s) and the page(s) that were visited.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • When you sign up to receive our newsletters.
  • From third parties, for example, the contact information collected when you enter giveaways on third party social media platforms.

Information You Provide to Us 

The information we collect on or through our Website may include:

  • To access some of the resources the Website offers, you may be asked to provide certain registration details or other information. It is a condition of your use of the Website that all information you provide on the Website is correct, current, and complete.
  • Information that you provide by filling in forms on our Website. This includes information provided at the time of or requesting further services or applying for Pro Team. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
  • We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  •  Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). 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.  For more information on “do not track” options, please see: http://donottrack.us/.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties]. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Web Beacons. Pages of our Website [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. You can also delete the cookie we set for you. This will eliminate our ability to link your past behavior with future behavior, but we will be able to monitor your future behavior based on a new cookie we supply.

Third-Party Use of Cookies and Other Tracking Technologies

We use Google Analytics, to analyze the use of and improve the functionality of our App. By way of example, Google Analytics gathers information about App use by means of cookies. The information gathered relating to our App is used to create reports about the use of our App for marketing and improvement purposes. We have hyperlinked the privacy policy above.

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How Do We Use Information Collected From You?

1. Personal Information.

We may use Personal Information:

  • for the purpose for which it was provided (e.g., regarding a possible employment opportunity, to provide services to you and contact you regarding these services),
  • to respond to your problems and comments,
  • to approve and enable your participation in the Site and Site services (e.g., to permit you to subscribe to our newsletters, blogs and RSS feeds, or enter giveaways, as applicable),
  • for our internal business purposes, such as data analysis, audits, developing new products, and enhancing our website,
  • improving our services,
  • identifying usage trends and
  • determining the effectiveness of our promotional campaigns.

We also may partner with third parties to provide specific services within the Website and Personal Information you provide may be used or disclosed for these purposes.  We will share contact and other information you provide as necessary for such third party to provide these services and by agreeing to the Terms, you authorize us to do so.  We do not allow these parties to use Personal Information except for the purpose of providing these services.

In addition, we may share your Personal Information with any third party, without your consent or approval and without notice to you:

(i). as permitted or required by law;

(ii). as incident to a corporate sale, merger, reorganization, dissolution, bankruptcy or similar event;

(iii). under circumstances we believe reasonably necessary to protect the personal safety of our employees, users of the Website, or the public;

(iv). to disclose information that is necessary to identify, contact or bring legal action against someone who may be violating our published policies; or

(v). as is otherwise described in this Policy.

2. Non-Personal Information.

Because Non-Personal Information does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non-Personal Information, which does not personally identify you, with affiliates and other third parties, for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we do combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information hereunder as long as it is so combined.

3. IP Addresses.

We use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, administering the Site, and tracking your Internet usage, including identifying your geographic location, which may be disclosed to search engines and other partners. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Information. Please note that we treat IP Addresses, server log files and related information as Non-Personal Information, except where we are required to do otherwise under applicable law.

Disclosure of 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 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 COCONA ‘s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by COCONA 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. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
  • To fulfill the purpose for which you provide it.
  • 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 [www.thirtysevenfive.com/terms] 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 COCONA, 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 checking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email with your request to legal@cocona.com.
  • Promotional Offers from COCONA. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (or at any other time by sending us an email stating your request to legal@cocona.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 the Company 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 checking the relevant box located on the form on which we collect your data or at any other time by sending us an email stating your request to legal@cocona.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.

Accessing and Correcting Your Information

You may also send us an email at legal@cocona.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Other Important Notices Regarding Our Privacy Practices.

Third Party Sites.  This Privacy Policy does not address, and we are not responsible for, the privacy of information collected by or other practices of any third parties, including without limitation any of our affiliates and any third party operating any site to which this Site contains a link. The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our affiliates.

Note Regarding the Use of the Site by Children. The Site is not directed to individuals under the age of thirteen (13).  COCONA does not knowingly collect or solicit personal information from anyone under the age of 13.  If you are under 13, you are prohibited from sending any information about yourself to us, including your name, address, telephone number, or email address.  No one under age 13 may provide any Personal Information to us.  In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible.  If you believe that we might have any information from or about a child under 13, please contact us at:  legal@cocona.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information.

Revisions and Errata.  The materials appearing on COCONA’s Website could include technical, typographical, or photographic errors. COCONA does not warrant that any of the Content on its Website are accurate, complete, or current. COCONA may make changes to the Content contained on its Website at any time without notice. COCONA does not, however, make any commitment to update the Content.

Links and Third Party Applications.  COCONA is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by COCONA of the site. Use of any such linked website is at the user’s own risk. For example, this Website may provide direct links to client websites or social networking services. You acknowledge that COCONA has no control over and is not responsible for the availability of any such third party applications, websites, content, or resources, which are made available by companies or persons other than COCONA. You further acknowledge that COCONA is not liable to you for any loss or damage which may be incurred by you as a result of these third party applications, websites, content, or resources.

International Users.  This Website is controlled, operated, and administered by COCONA from its offices within the United States. COCONA makes no representation that materials on its Website are appropriate or available for use at other locations outside of the United States. If you access this Website from a location outside of the United States, you are responsible for compliance with all local laws.  You agree not to provide us with any data for which you intend to claim protection under any data privacy laws, regulations, or directives of the European Union or any other foreign country.

Jurisdictional Issues. We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. By using the Site and submitting any Personal Information, you consent to the transfer of Personal Information to other countries, such as the United States, which may provide a different level of data security than in your country of residence.

Data Security. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

If you are provided with a username, password, or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any other person or entity. You agree to notify us immediately of any unauthorized access to or use of your username or password or any other breach of security. You should use caution when accessing your account from a public or shared computer so that others are not able to view or record your password or other personal information.

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.

Contacting Us.  If you have any questions regarding this Privacy Policy, please contact us by email at legal@cocona.com.

Last Updated: July 2022