CogoCast Privacy Policy

Updated: July 1, 2020

Because your privacy is very important to us, we want you to understand our practices with regard to collecting and using information obtained online and the steps we take to safeguard it. This statement applies to "non-personally identifiable information" collected online from our owned-and-operated web sites and those of our partners, which means information that identifies, for example, consumer product preferences, or number of children, is directly associated with personally identifiable information, this other information also becomes personally identifiable information for purposes of this Privacy Policy. Personally identifiable information is sometimes referred to in this Privacy Policy as "personal information."

Information We Collect
1. Non-personally Identifiable Information
  Cogo Labs employs CogoCast to collect non-personally identifiable information regarding the online behavior and usage patterns associated with computers or other devices used by individuals ("Users") to access web sites and other online properties ("Non-PII"). CogoCast only collects Non-PII online from Data Partners, which are web sites and other online properties that have agreed to Cogo Labs use of CogoCast to collect Non-PII relating to Users.
  
  Cogo Labs does not use CogoCast to collect online any personally identifiable information, such as, your name, address, phone number, e-mail address, financial account number, government-issued identifier, or anything else that can be used to identify, contact, or precisely locate you ("PII"). If information that relates to personal characteristics, such as consumer product preferences, or number of children, is directly associated with PII, this other information also becomes PII for purposes of this Privacy Policy.
2. Technology CogoCast Uses to Collect Non-PII Online
  CogoCast uses non-personally identifiable means, including "cookies" and "pixel tags," to collect and store User data.
  
  Cookies are small text files that web sites place in your browser when you visit them. When you return to the site, the site can access its previously placed cookie to uniquely identify your browser. Cookies cannot be used to access any other data on your computer. CogoCast may use cookies to track Users’ responses or views of advertisements when an advertisement served by us has been viewed. You may read more about cookies at www.cookiecentral.com.
  
  Pixel tags are small strings of code that provide a method for delivering a graphic image on a Web page or other document. Pixel tags allow the operator of the Web page or other document, or a third party who serves the pixel tag, to set, read, and modify cookies. Pixel tags may also be used to obtain information about the computer being used to view that Web page or other document. The entity that sends the tag can view the IP address of the computer that the tag is sent to, the time it was sent, the User's operating system and browser type, and similar information.
3. Anonymous Information Provided by Third Parties
  CogoCast obtains information from Data Partners which may include non-personal identifiers that cannot be decrypted by Cogo Labs ("Anonymous Information"). For example, a Data Partner may encode an anonymous user id into our pixel tag. However, it is not possible for CogoCast to associate such a user id with any PII that may be stored by the Data Partner.
  
  CogoCast may also obtain information from Third-Party Data Providers, which are sources of Non-PII data not collected directly on our own Data Partners’ websites. Third-party data may be combined with the data we collect via our Data Partners to create a richer profile of user interests and preferences.
4. Privacy of Children and Sensitive Consumer Information
  CogoCast is designed for those 18 years of age and older. CogoCast does not knowingly collect information from anyone under the age of 18.
  
  CogoCast does not knowingly obtain or store any Sensitive Consumer Information, such as Social Security Numbers and other government Issued identifiers; insurance plan numbers; financial account numbers; information that describes the precise real-time geographic location of an individual; or precise information related to health or medicals conditions.
  
  If Cogo Labs is made aware that we have received information from anyone under the age of 18 or Sensitive Consumer Information in violation of this Privacy Policy, we will use reasonable efforts to locate and remove that information from our records.
Use of Information We Collect
1. Displaying Relevant Advertisements and Content
  CogoCast uses the Non-PII collected by CogoCast, alone or in combination with Non-PII and Anonymous Information obtained from Third Party Data Providers, to divide Users into groups of Users based upon behavior and interests of these Users. CogoCast refers to these groups of Users as Segements. CogoCast displays advertisements and other content relevant to a User based upon a User's membership in a Segment. The membership of a particular User in a particular Segment is Segment Membership Data. Segment Membership Data is not identifiable with a particular individual and is non-PII.
2. Aggregate Information
  We also use the Segment Membership Data that we create to provide aggregate statistics for market research and analytics. We may sell aggregated statistical data or analysis based on such data to third parties.
Information We Share with Others
1. Ad Networks and Other Third Parties
  Cogo Labs may exchange or otherwise provide anonymous user identifiers to marketers, ad networks and other third parties who use this data to enable CogoCast to display advertising messages to you as you visit different websites around the Internet.
2. Service Providers
  We may transmit or share our data with third-party service providers, such as data storage and processing facilities ("Service Providers"), in order for those Service Providers to perform business functions for us or on our behalf. Any Service Providers with direct access to our data shall be contractually bound to comply with the terms of this Privacy Policy with respect to any information collected and maintained in accordance with this Privacy Policy.
3. Compliance with Law
  We may disclose information in our possession and control to respond to subpoenas, court orders and other legal process. We may disclose any information to third parties in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.
4. Asset Sale Transaction
  In the event another company acquires all or most of our assets, all data compiled or owned by us may be among the items transferred in that transaction. In such an event, all the data shall continue to be governed by this Privacy Policy.
Security
We retain the Non-PII collected via our technology for up to one year. After one year, we discard the information.

Even though the information that we store is Non-PII or encrypted, security is important to us. We have implemented reasonable measures to protect the information we collect and store, taking into consideration the types of risks we face and the reasonable protections available to us. No method protecting information is 100% secure, and we cannot guarantee its absolute security.
Privacy Practices of Third Parties
Some of ad networks or Data Partners may place their own cookies or other technological devices on your Internet browser, independent of CogoCast. We have no control over these third parties and no responsibility for the technologies they employ. To learn how a particular web site collects and uses your PII and Non-PII, you should read the privacy policy of that web site.
Opting Out
You may opt-out of CogoCast at any time. There are two ways to opt-out of receiving relevant advertising from us.
1. Block all cookies by disabling cookie use in your browser. This may cause some sites to work incorrectly.
2. Opt-out by setting a cookie which tells CogoCast to ignore you. Click here to view/change your opt-out status.
Please note that when you opt-out, we still need to maintain a cookie on your computer in order to recognize that you have opted out. You must opt-out in this same manner again if you want to clear that cookie from your browser, or if you use a different Internet browser or different computer to access the Internet.

You may also opt-out of cookie use by various third-party vendors, including ad networks used by CogoCast by visiting the Network Advertising Initiative opt-out page.
Policy Changes
From time to time, we may use customer information for unanticipated uses not previously disclosed in our privacy notice. If our information practices change, we will post these changes on our web site. We encourage you to review our Privacy Policy periodically.

California Consumer Privacy Act Notice

The California Consumer Privacy Act (“CCPA”) confers upon California Consumers certain rights regarding their Personal Information (“PI”), as those terms are defined in the law. The statute became effective on January 1, 2020, but the California Attorney General’s office is still in the process of promulgating – and, in some respects, already modifying – proposed regulations that will help clarify the CCPA’s requirements.

For now, and based on its good-faith understanding of the new California law, CogoCast is providing you with notice of the personal information it collects and its purposes for that data collection – insofar as it may be subject to the CCPA. This notice does not cover information outside the scope of the CCPA. Nor does it apply to data collected from employees, applicants or contractors, or to data collected from individuals acting as representatives of another business in connection with business communications or transactions.

For the purposes listed below, CogoCast (referred to as “we,” “us” or “our”) may collect – and share with the types of third parties indicated – the following categories of PI that may be subject to the CCPA:

Category(ies) of PI	Purpose(s) for Collection	Category(ies) of Third Parties
1. Internet Usage Information (e.g., information regarding your interaction with our services)	Security, internal analytics & reporting	Vendors, data analytics partners, advertising partners
2. Geolocation Data	Security, internal analytics & reporting	Vendors, data analytics partners, advertising partners
3. Inferences from PI Collected (e.g., your preferences, your likelihood of interest in certain of our services)	Providing our services, improving our services, marketing	Vendors, data analytics partners, advertising partners

In addition, CogoCast may collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.

We do not knowingly “sell” (as that term is defined in the CCPA) the personal information that we collect from you, and we will treat any such PI as being subject to a do-not-sell request.

California Consumers have the right to exercise certain privacy rights under the CCPA, either directly or through authorized agents who meet the law’s agency requirements. Any CCPA request you submit to CogoCast is subject to an identification and residency verification process. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify that you are the Consumer about whom we collected PI – i.e., that yours is a “Verifiable Consumer Request.”

CogoCast will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use, and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to respond to a Verifiable Consumer Request, but we may charge a reasonable fee – or decline to act upon a request – if it is excessive, repetitive, unfounded or overly burdensome.

If you are a California Consumer and would like to register a request under your “right to know about personal information collected, disclosed or sold,” your “right to request deletion of personal information” or your “right to opt out of the sale of personal information,” or to exercise any other privacy rights you may have under the CCPA, please contact us in writing and by email at privacy@cogocast.com. We will respond as and when we have sufficient regulatory guidance on how to properly verify and respond to such requests and are able to do so.

As a California Consumer, you would have the right to send us a request, no more than twice in a twelve (12)-month period, for any of the following (for the twelve (12)-month period preceding the date of your request):

The categories of PI we have collected about you;
The categories of sources from which we collected your PI;
The business or commercial purposes for our collecting or selling your PI;
The categories of third parties with whom we have shared your PI;
The specific pieces of PI we have collected about you;
A list of the categories of PI disclosed for a business purpose in the prior twelve (12) months, or that no disclosure occurred; or
A list of the categories of your PI sold in the prior twelve (12) months, or confirmation that no such sale occurred. If we did sell your PI, we would explain in our response to your request:
The categories of your PI we sold; and
The categories of third parties to which we sold that PI, by categories of PI sold to each third party.

A California Consumer also has the right to make or obtain a transportable copy, no more than twice in a twelve (12)-month period, of her/his PI that we both collected during the twelve (12) months prior to the copy request date and are still maintaining as of the date of the request.

Please note that PI is retained by us for various time periods, so we may not always be able to respond fully to each request covering the full twelve (12) months – or even some lesser periods – prior to the date it is made.

Except to the extent we have a basis for retention under CCPA, a California Consumer may request that we delete her/his PI that we have collected directly from her/him and are maintaining. Please note that we are not required to delete any PI that we did not collect directly from the California Consumer her/himself.

Alternatively, a California Consumer may exercise more limited control of her/his PI through one of the more limited opt-outs, including unsubscribing from email newsletters.

CogoCast will review – and, as appropriate, revise – this CCPA notice from time to time (such as when implementing regulations take effect and/or other interpretive guidance becomes available).

EU General Data Protection Regulation
Because CogoCast (a) does not have any establishment(s) in the EU, and (b) does not actively or intentionally (i) offer goods and services to individuals in the EU, or (ii) monitor the behavior of individuals known to be located in the EU its business activities do not fall within the coverage of the General Data Protection Regulation.

We welcome any and all comments, questions and feedback. For privacy-related issues, please contact us at:

CogoCast c/o Cogo Labs
One Kendall Square, Suite B2102
Cambridge MA 02139
privacy@cogocast.com