Privacy Policy

About Your Privacy and This Privacy Policy

This document referred to as the “Privacy Policy” contains details on issues related to your privacy when using our services. This Privacy Policy applies to visitors to the applications and websites owned and operated by Cocoon Connects Ltd. “Cocoon” (collectively referred to as the “Platform”). It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Platform.

California residents should read the information available in the Privacy Notice for California Residents below.

European Union residents should read the information available in the Privacy Notice for European Union Residents below about the categories of personal information to be collected from them and the purposes for which the personal information will be used below.

The Privacy Policy is part of our Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, “we”, “our”, “us”, “Platform” and “Services”) have the same meaning as in our Terms and Conditions document. When you use our Platform you accept and agree to both the Terms and Conditions and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Platform immediately or cease to provide the Services, as applicable. By accessing and using our Platform or the Services, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them.

Information Collection, Use, and Disclosure

Categories of Information Collected

To let us operate the Platform effectively and to let you use the Platform, including the Services, we may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

  1. Visitor Data: We collect, use, and store data regarding user visits to its Platform, including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, and information about the browser or device used to access the Platform, such as the user’s mobile device ID and IP address.
  2. Onboarding Data: In addition to the questionnaire responses provided by users in the process of initial registration, we collect, use, and store data certain additional data from users during the on boarding process (“Onboarding Data”). This data includes the pages viewed by the user, whether the user clicks the link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.
  3. Account Registration Data: We collect, use, and store certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number (“Account Registration Data”). We also assigns each user who creates an account an anonymized, randomly-generated client ID.
  4. Transaction Data: We collect, use, and store certain information regarding payment for services by users and related transactions on the Platform, such as whether a user completed payment for services, signed up for services using a trial offer, canceled or otherwise ended atrial, or subscription (“Transaction Data”).
  5. Login Data: We collect, use, and store data regarding logins to the Platform by registered users and activity conducted during that log in such as when a user logs in, the number of messages received or sent through the Platform during that log in, and whether a user has chosen a Counsellor. This data does not include the content of any messages sent or received by users.
  6. Customer Data: We collect, use, and store certain data from users that have signed up for Cocoon’s services such as a user’s self-reported name or nickname, age, e-mail address and phone number, service description and service licensing (“Customer Data”).
  7. Communications Data: We collect, use, and store communications between users and our customer service team, as well as when you email a Counsellor or when you email a friend about a Counsellor, such as your name and email address and your friend’s name and email address(please note that we do not read or retain the message in your email) (“Communications Data”).

Protecting this information is important for us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you requested or approved us to do so.

Purposes for Which Information is Used

We may use the information we collect for one or more of the following purposes:

Communication with you

  • To contact you or provide you with information, alerts and suggestions that are related to the Platform.
  • To verify your identity.
  • To complete an activity you requested, such as register for the Platform or obtain more information.
  • To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.

Delivery of services to you

  • To create your account on our Platform and let you log in to your account and use the Platform.
  • To manage your account, provide you with customer support, and ensure you are receiving quality service.
  • For billing and transaction processing purposes.
  • To match users with Counsellors and facilitate the Services
  • To provide, support, personalize, and develop our Platform and the Services.

Administration and improvement of services

  • To supervise, administer and monitor the Platform.
  • To measure and improve the quality, effectiveness and delivery of our services.

Customization and marketing

  • To advertise and market the Platform and Counsellor Services to potential users and Counsellors.
  • To personalize website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message.

Compliance with law

  • To confirm licensing.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.

Other uses with consent

  • Any other purpose with your consent.

Purposes for Which Information is Disclosed to Third Parties

Information about you may be disclosed to third parties for one or more of the following purposes:

  1. For business purposes and advertising: We may share a user’s information with a Counsellor and a Counsellor’s information with a user only as necessary for facilitating the Services. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.
  2. With your direction or consent: We may share your information with third parties if you request or direct us to do so.
  3. With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group.
  4. Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.
  5. In the context of a transaction: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.
  6. For other business reasons: We may share your information to enforce any applicable terms and conditions and Terms of Use, and to ensure the safety and security of the Platform and our users.

Note that if you make any information publicly available on the Platform, anyone may see and use such information.

Your rights

You have a number of rights with regards to your personal data:

  • You have the right to be given information about how your data is processed and why.
  • You have a right to access the personal data we hold about you.
  • You have the right to ensure the information we hold about you is accurate and complete.
  • You have the right to have your personal data deleted.
  • You have the right to ask us to restrict processing your personal data.
  • You have the right to ask us to transfer your personal data.
  • You have the right to object to us processing your data.
  • You have the right to withdraw consent to us sending you information by email.
  • You have rights in relation to automated decision making and profiling.

Platform User Account

You can use your Platform user account to opt in and out of receiving email communications and to update your personal information. If you would like to delete your website account, please contact us by email at support@cocoonapp.ca. Your account is automatically deleted after two years of inactivity.

Purchases through the Platform

We will need your payment card details and billing address if you make any purchases, in order to take payment and perform refunds if necessary. We do not keep your card number. Order confirmations will be sent by email.

Subscriptions and Newsletters

We will use your name and email address to provide you with emails and newsletters you have chosen to receive. You will be able to unsubscribe from these at any time by clicking on the link in the email or contacting us at support@cocoonapp.ca.

Opting out of Marketing Communication

You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.

Cookies and Web Beacons

Like many applications, we use “cookies” and “web beacons” (also known as pixels) to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A “web beacon” is a tiny and sometimes invisible image or embedded code, placed on a web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users for the purpose of analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.

You can change your browser’s settings so it will stop accepting cookies or to prompt you before accepting a cookie. Opt-out options for cookies are located at the account holder section of the Platform.

Use of Cookies, Web Beacons, and Similar Technology for Analytics

We may use third party cookies for the purposes of web analytics, attribution, and error management. Our Platform may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on social media, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the Platform.

Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our Platform for purposes of analytics and analysis of certain Platform usage.

Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks

You and others may see certain ads for our services or for the Platform on other websites because we may participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection may take place both on our Platform and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites.

Social and General Information Tools

We may use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, Instagram account and others (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.

In order to provide your subscription services, we may ask you for some of the following information. This list is not exhaustive.

Name, telephone number, and postal address – As applicable, we need these to send you publications and other information relevant to your subscription, including subscription renewal information.

Email address – We need this to provide your Platform services, such as your online account and email information. We use your email address to communicate with you about your benefits, news and services, surveys, and activities.

Qualifications – Dependent on your access, we need a copy of your qualifications in order to check you are eligible. Any copies are destroyed within two years of your termination from the Platform.

Date of birth- This is used for verification purposes.

You can view and update most personal data held by logging into the account holder section of the Platform. Please email us support@cocoonapp.ca if you would like to view your data or if you would like us to update it for you.

If you decide to terminate your use of the Platform, we will keep your personal information on our database for two years. This is to allow you to re-join the Platform during this period without having to submit your information and/or supporting documentation again.

We will retain some basic information about your Platform access for archiving and historical research or for conducting statistical analysis of our users. Where appropriate this will be anonymized and any personal data held will be kept to a minimum.

Phishing

Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

Links

The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.

Security of Information

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal laws, provincial and state laws, and regulations regarding data privacy.

Service Providers

We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but are not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.

Compliance with Laws and Law Enforcement

We cooperate with governments and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Counsellors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action including but not limited to the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.

Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.

Contacting us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please email us at support@cocoonapp.ca

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CALIFORNIA – Privacy Notice for California Residents

This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Through your use of our Platform, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The description of the information that we collect is provided above, in the section titled “Categories of Information Collected.” The information that we share with third parties is described in greater detail above in the section titled “Purposes for Which Information is Disclosed to Third Parties.”

In particular, our Platform is expected to collect the following categories of personal information from consumers within twelve (12) months. Additionally, we expect to disclose the following categories of information for a business purpose within twelve (12) months:

Category / Collection / Disclosure for a business purpose

A. Identifiers. / Yes / Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). / Yes / Yes

C. Protected classification characteristics under California or federal law. / Yes / Yes

D. Commercial information. / Yes / Yes

E. Biometric information. / No / No

F. Internet or other similar network activity. / Yes / Yes

G. Geolocation data. / Yes / Yes

H. Sensory data. / No / No

I. Professional or employment-related information. / Yes / Yes

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). / No / No

K. Inferences drawn from other personal information. / Yes / Yes

The information that we share with third parties is described in greater detail above in the section titled “Purposes for Which Information is Disclosed to Third Parties.”

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from information you submit on the Platform during the process of using and/or paying for our Services.
  • Indirectly from you. For example, from observing your actions on our Platform or on an application provided by us.
  • From third-party business partners such as social media sites, ad networks, and analytics providers.

Use of Personal Information

We may use the personal information we collect for one or more of the following business or marketing purposes:

Category of Personal Information & Purpose of Use

  1. Identifiers. We may use Identifiers (provided account name, email address, online identifier, and IP address) to communicate with you, deliver our services to you, facilitate the Services, customize and market the services (attribution and optimization), conduct research and development and other activities to improve our service, understand how you interact with our services, and comply with the law.
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). We use your name (if you provide it to us) and the payment details you provide to us to communicate with you, deliver services to you, and facilitate the Services. We may also use your name and contact details to optimize our marketing to prospective users and Counsellors.
  3. Protected classification characteristics under California or federal law. We may use your age, religion, sex, orientation and medical condition to customize and deliver the services to you. If you are a veteran or have military status, we may use this information to offer you a discount for our services. We may also use this information to conduct research and development and other activities to improve our service, show and optimize advertising, and understand how you interact with our services.
  4. Commercial information. We use information regarding your purchase of our services to customize and market services, conduct research and development and other activities to improve our services, show and optimize advertising, and understand how you interact with our services.
  5. Internet or other similar network activity. We use information regarding your activity on our Platform to deliver our services to you, customize and market services (attribution and optimization), conduct research and development and other activities to improve our service, and understand how you interact with our services.
  6. Geolocation data. We use your geolocation information to personalize the services to you and for analytics.
  7. Inferences drawn from other personal information. We use information regarding your actions on our Platform and the information you provide to deliver our services to you, customize and market the services, conduct research and development and other activities to improve our service, and understand how you interact with our services.

Disclosure of Personal Information

Within the 12 months of this Privacy Policy, we expect to share personal information with the following categories of third parties:

Category of Personal Information & Purpose of Use

  1. Identifiers
    We may disclose your IP address, unique identifier, or email address to our analytics vendors for analytics and to ad network partners for advertising optimization and attribution.
    We may disclose your credit card information to payment processing vendors for payment processing.
    If you are a user that uses the Platform as the result of a business arrangement we have with an organization you are affiliated with or with your employer, we may disclose, with your authorization, identifiers to those entities in order to deliver the services to you.
    Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
    We may disclose your contact information to webinar providers and to customer support and payment processing vendors to provide services for the Platform and to ad network partners for advertising optimization and attribution.
    We may disclose personal information between users and Counsellors as necessary to provide the Services.
    We may disclose your credit card information to payment processing vendors for payment processing.
  2. Protected classification characteristics under California or federal law.
    We may disclose information regarding your age, sex, race, gender, sexual orientation, medical conditions, and disabilities to our advertising partners to optimize marketing, and to Counsellors as necessary to provide the Services.
  3. Commercial information.
    We may disclose information regarding your purchase of our services to our advertising partners to optimize marketing.
    We may disclose your credit card information to payment processing vendors for payment processing.
  4. Internet or other similar network activity.
    We may disclose information regarding your activity on our Platform to our advertising partners to optimize marketing.
  5. Geolocation data.
    We may disclose geolocation data to our advertising partners to optimize marketing.
  6. Inferences drawn from other personal information.
    We may disclose information regarding your activity on our Platform to our advertising partners to optimize marketing.
  7. All data categories
    We may disclose all necessary information about you to comply with legal requirements that apply to us
    We may disclose information about you at your direction or request.
    We may disclose information about you to vendors and other contractors and advisors that provide services to us, including data hosting and storage providers, analytics providers, engineering vendors, data security vendors, marketing services processors, lawyers, advisors, auditors, accountants, and others.
    We may disclose information about you in connection with an asset sale, merger, bankruptcy, or other business transaction.
    We may disclose information about you with corporate affiliates as necessary for internal business operations, and with subcontractors as necessary in the provision of services to you.
    The CCPA defines “sale” broadly. It includes the sharing of personal information in exchange for anything of value. According to this broad definition, in the 12 months before this section was last updated, our use of analytics and targeting cookies and web beacons to deliver advertising tailored to individual interests may have been considered a “sale” of personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Request Access to Information

You have the right to request that Cocoon disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we shared that personal information.
  • The specific pieces of personal information we collected about you.
  • If we disclosed your personal information for a business purpose and identifying the personal information categories that each category of recipient obtained.

Right to Request Deletion of Information

You have the right to request that we delete any of your personal information that we collected about you and retained, subject to certain exceptions. Once we receive your request and verify who you are, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • We may also deny your request if the information in question is not subject to the CCPA. Examples of such information include de-identified information, information covered by the Health Insurance Portability and Accountability Act, and information covered by the California Confidentiality of Medical Information Act.

Right to opt out of sale

You have the option to opt out of the use or disclosure of your information that is considered a “sale” under the CCPA. If you would like to opt out of the use and disclosure of your information, go to the account holder section of the Platform to manage your preferences.

Exercising Your Rights

To exercise the rights listed above, please submit a request in writing to us via the submission methods listed below. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

You may only make a request for access twice within a 12-month period. Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.

You may submit requests using the following methods:

By making the request in writing and sending it to:

Cocoon Connects Ltd.

Data Protection Office, Suite 102

951 Rowntree Dairy Road

Vaughan ON L4L 8Z5 Canada

support@cocoonapp.ca

(416) 555-1212

Response Timing and Format

We endeavour to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days from the day of receipt), we will inform you of the reason and extension period in writing.

For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. We will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@cocoonapp.ca.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make any changes to this Privacy Notice, we will post the updated Privacy Notice on our Platform and update the Privacy Notice’s effective date. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform. Your continued use of our Platform and services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Cocoon Connects Ltd.

Data Protection Officer

951 Rowntree Dairy Road, Suite 102

Vaughan ON L4L 8Z5 Canada

support@cocoonapp.ca

General Data Protection Regulation (GDPR) Notice

This section provides additional information about our Privacy Policy relevant to users from the European Union (EU) and Switzerland. It supplements and should be read in conjunction with the rest of the Privacy Policy. Under the GDPR, Cocoon is the Controller with respect to your Personal Data.

Cocoon may use your personal information:

  • When it is necessary to do so to perform our obligations in accordance with any contract that we may have with you, for example to manage your account, and to respond to enquiries about your use of the Platform.
  • When it is in our legitimate interests or a third party’s legitimate interests to use personal information in such a way to ensure that we provide the Platform in the best way that we can. In particular, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Platform. We only rely on our or a third party’s legitimate interests to process your personal information when these interests are not overridden by your rights and interests.
  • When it is necessary to do so in order to comply with any legal obligations imposed upon us, for example under applicable law.
  • When you have consented to the use of your personal information, for example for marketing purposes or to track your online activities via cookies and similar technologies.

Your Rights and Choices:

EU and Swiss residents have specific rights regarding their personal information. This section describes your rights if you are resident in the EU or Switzerland, and explains how to exercise those rights.

Right of access: You may be entitled to ask us for a copy of any personal information which we hold. This right is known as a ‘Subject Access Request.’ We will normally send you a copy of the personal information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the personal information that you request. There is usually no charge; but in exceptional circumstances we may charge but will discuss this with you if those circumstances apply.

Right to rectification: If the personal information we hold about you is inaccurate, you may request rectification. The personal information will be checked, and, where appropriate, inaccuracies will be rectified.

Right to erasure: In certain circumstances, you may be entitled to ask us to erase your personal information.

Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic personal Information that we hold about you to another organization.

Right to object: You may object to your personal information being used for direct marketing. You may object to the continued use of your personal information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your personal information, we may continue to do so. In that event, we will let you know the reasons for our decision.

Rights related to automated decision-making including profiling: We use limited personal information to operate the Platform and to carry out certain profiling activities to support and grow our business. When doing so, we rely upon our legitimate interests as the lawful basis for processing your personal information and you may exercise the above rights if you do not wish us to process your personal information in this way.

To exercise the rights in relation to your Personal Information set out in this section, please contact us by send an email to support@cocoonapp.ca.

International Data Transfers

The Platform is controlled and operated by us from Canada and the Units State of America. By accepting the terms of this Privacy Policy you agree that any personal information you provide to us through use of the Platform may be stored and processed, transferred between and accessed from Canada and the United States of America and other countries that may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy at all times.

You can contact our Data Protection Officer with questions, about this policy, or about your personal information by writing to:

Cocoon Connects Ltd., Data Protection Officer, c/o Legal Department, 951 Rowntree Dairy Road, Suite 102, Vaughan ON L4L 8Z5 Canada; support@cocoonapp.ca

Whilst we will always work with you to resolve any concerns you have about the use of your personal information, under GDPR you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.

Last Updated and Effective: July 21, 2023