Table of Contents
- What information does CookiePro collect
- How do we use the information
- How and why do we share your data with third parties
- How we secure your data
- Your privacy rights
- How can I exercise my data subject rights
- International data transfers
- California and Delaware “do not track” disclosures
- Linked websites
- Changes to the privacy notice
- Contact us
CookiePro offers a cookie solution. This privacy notice aims to inform you about how we collect, store, use and disclose information about you when you:
- interact or use our websites, including downloading materials from our resources page (collectively the “Websites”),
- if you use any of our products, services or applications (including any trial) (collectively the “Services”) in any manner.
What information does CookiePro collect?
We gather various types of information, including information that identifies or may identify you as an individual (“Personal Information”) as explained in more detail below.
Information You Provide to Us
From Websites: We may collect any Personal Information that you choose to send to us or provide to us. If you contact us through the Websites, we will keep a record of our correspondence.
From the Services: We receive and store information you provide directly to us. For example, when setting up new users, we collect Personal Information, such as name and e-mail address, to provide them with Services. The types of information we may collect directly from our customers and their users include: names, usernames, email addresses, postal addresses, phone numbers, job titles, transactional information (including Services purchased), as well as any other contact or other information they choose to provide us or upload to our systems in connection with the Services.
Information We Automatically Collect
When you use the Websites: When you visit the Websites, we collect certain information related to your device, such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our Website.
When you use the Services
- Usage information – we keep track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers, and performance metrics related to their use of the Services.
- Log information – we log information about our customers and their users when you use one of the Services including Internet Protocol (“IP”) address.
- Information collected by cookies and other similar technologies – we use various technologies to collect information which may include saving cookies to users’ computers.
For further information, please read the section below headed “Cookies and other Tracking Technologies” and/or read our Cookie Notice.
How do we use the information?
We will use the information we collect
- To administer our Website, our events (e.g. sending you event details and updates) and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
- To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
- For trend monitoring, marketing and advertising;
- For purposes made clear to you at the time you submit your information;
- As part of our efforts to keep our Website secure.
Our use of your Personal Information may be based on our legitimate interest to ensure network and information security, and for our direct marketing purposes, or you consenting to it (e.g. when you request a demo). For our customers, the use of personal data will be based on the contract we have in place.
We may use the information we collect from our customers and their users in connection with the Services we provide for a range of reasons, including to:
- To set up a user account,
- Provide, operate and maintain the Services;
- Process and complete transactions, and send related information, including transaction confirmations and invoices;
- Manage our customers’ use of the Services, respond to enquiries and comments and provide customer service and support;
- Send customers technical alerts, updates, security notifications, and administrative communications;
- Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities; and
- For any other purposes about which we notify customers and users.
- We use your Personal Information in this context based on the agreement that we have in place with you. Personal Information will be deleted based on the agreement.
How and why do we share your data with third parties?
We do not rent or sell your Personal Information to anyone. We may share and disclose information (including Personal Information) about our customers in the following limited circumstances:
Vendors, consultants and other service providers:
We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf. These companies include (for example) our payment processing providers, website analytics companies (e.g., Google Analytics), product feedback or help desk software providers (e.g. ZenDesk), CRM service providers (e.g., Salesforce), email service providers (e.g., Sendgrid) and others.
If CookiePro receives your Personal Information in the United States and subsequently transfers that information to a third party agent or service provider for processing, CookiePro remains responsible for ensuring that such third party agent or service provider processes your Personal Information to the standard required by our Privacy Shield commitments (see the sections below headed “Additional Information for Users in the European Economic Area (“EEA”)” and “International Data Transfers”).
We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
CookiePro Group Companies:
We may also share your personal data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Notice.
Protection of CookiePro and Others: We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of CookiePro, our employees, our users, or others.
Disclosures for National Security or Law Enforcement:
Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
How We Secure Your Data
We use appropriate technical, organizational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction.
ISO/IEC 27001:2013 Certified
Our Information Security Management System (ISMS) is ISO/IEC 27001:2013 certified as reflected in the certificate found here: http://www.coalfireiso.com/Certificates/CookiePro-ISO-27001-Certificate-Award_2-27-2018.pdf The audit established the overall operational effectiveness of a sample of control areas comprising our ISMS.
We have been audited and received a SOC 2 report addressing the security, confidentiality and availability of our services.
Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first party cookies. We also use third party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.
- Assisting you in navigation;
- Assisting in registration to our events, login, and your ability to provide feedback;
- Analyzing your use of our products, services or applications;
- Assisting with our promotional and marketing efforts (including behavioral advertising).
Below is a detailed list of the cookies we use on our Website. Our Website is scanned with our cookie scanning tool regularly to maintain a list as accurate as possible. We classify cookies in the following categories:
- Strictly Necessary Cookies
- Performance Cookies
- Functional Cookies
- Targeting Cookies
You can opt-out of each cookie category (except strictly necessary cookies) by clicking on the “cookie settings” button at the bottom of the page or in our Cookie Notice.
Google offers an opt-out mechanism for the web available here.
Please consult our Cookie Notice for more information about the type of cookies and tracking technologies that we use on this Website and why, and how to accept and reject them.
Your Privacy Rights
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the unsubscribe link in the emails communications we send, or click the “Exercise your Rights” link available on the top left of our Privacy Notice, or fill out this Web Form directly.
If you have any account for our Services, we will still send you non-promotional communications, like service related emails.
How Can I Exercise My Data Subject Rights?
If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can either click the “Exercise your Rights” link available on the top left of our Privacy Notice, or fill out this Web Form directly. Our privacy team will examine your request and respond to you as quickly as possible.
Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual, and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: [email protected]
If you are a resident of the European Economic Area, please see the section below headed “Additional Information for users in the European Economic Area” for further information about your privacy rights.
International Data Transfers
Personal Information you submit on the Websites or through the Services is sent to the United States and will be primarily processed by us in the United States and potentially in other countries, on our servers or on our hosted service providers’ cloud servers on our behalf. These countries may not have similar data protection laws to those in your country of residence. However, we will always protect your information in accordance with this Privacy Notice wherever it is processed. Some of our product offerings include the ability to host your data in servers located in the EU or other countries. To request this capability, contact [email protected]
International Data Transfers – Additional information for users in the European Economic Area (“EEA”)
Self-certified to the EU-US Privacy Shield Framework
This section sets out the privacy principles we follow with respect to transfers of Personal Information from the EEA to the United States, including Personal Information we receive from individuals residing in the EEA who visits our Websites and/or who may use of our Services or otherwise interact with us.
Please note that for users located in the EEA, the term Personal Information used in this notice is equivalent to the term “personal data” under applicable European data protection laws.
We comply with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries. We have certified that we adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, see the US Department of Commerce’s Privacy Shield website located at https://www.privacyshield.gov
. To view our certification on the Privacy Shield list, please visit https://www.privacyshield.gov/
In compliance with the EU-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Information. Individuals located within the EEA with inquiries or complaints regarding this Privacy Notice should first contact CookiePro at:
Director of Privacy
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data within 45 days of receiving your complaint. We have further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Under certain limited circumstances, individuals in the EEA may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution (discussed above) have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/
We are subject to the jurisdiction of the U.S. Federal Trade Commission for purposes of Privacy Shield enforcement.
Please note that CookiePro is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Self-certified to the Swiss-U.S. Privacy Shield Framework
We comply with the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
In compliance with the Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact CookiePro at:
Director of Privacy
We have further committed to refer unresolved privacy complaints under the Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers
for more information and to file a complaint.
Under certain limited circumstances, individuals in Switzerland may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution (discussed above) have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/
California and Delaware “Do Not Track” Disclosures
California and Delaware law require CookiePro to indicate whether it honors “Do Not Track” settings in your browser concerning targeted advertising. CookiePro adheres to the standards set out in this Privacy Notice and does not monitor or respond to Do Not Track browser requests.
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If 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 a child under 13 may have provided us Personal Information, please contact us at [email protected]
For your convenience, hyperlinks may be posted on the Websites that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy notice of each Linked Site that you visit to understand how the information that is collected about you is used and protected.
Change to the Privacy Notice
We’re constantly trying to improve our Websites and Services, so we may need to change this Privacy Notice from time to time as well. We will alert you to material changes by, for example, placing a notice on our Websites and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. You can see when this Privacy Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Notice.
CookiePro is a trademark of OneTrust LLC which is the party in interest herein
PO Box 7813, 1072 W Peachtree St. NW Atlanta, Georgia 30309
Data Protection Officer
Email Address: [email protected]
PO Box 7813, 1072 W Peachtree St. NW
Attn: Privacy – DPO
Atlanta, GA 30309
If you have any questions or concerns regarding our privacy notice, please send a detailed message to [email protected]
or by mail to the address listed above.