CoLife respects your preferences concerning the collection and use of your Personal Information. The following privacy policies are tailored for the different ways your Personal Information is collected.
Co-Life LLC and our subsidiaries and affiliates ("CoLife" or "we") respect your preferences concerning the treatment of Personal Information that we may collect. This policy lets you know how we collect and use your Personal Information, how you can control its use, and describes our practices regarding information collected from CoLife applications, websites, affiliated websites, as well as through offline sales and marketing activities (collectively, the "Channels").
1. Personal and Other Information We Collect
Through your interaction with and use of the Channels, CoLife may collect “Personal Information,” which is information that identifies an individual or relates to an identifiable individual. Personal Information may include, but is not limited to, your name, physical address, telephone number, e-mail address, and photographs.
CoLife also collects “Sensitive Information,” which is information in your profile such as religion, gender identity, age, children, spouse, friend lists, social media accounts, work or school information, hobbies and interests. When we combine Sensitive Information with Personal Information we treat the combined information as Personal Information.
CoLife may also collect Other Information through your interaction with and use of the Channels and non-CoLife websites, which does not reveal your specific identity or does not directly relate to an individual. “Other Information” may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information.
Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code.
In some instances, we may combine Other Information with Personal Information, such as combining a precise geographical location with your name. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.
2. How We Use and Share Information
a. Personal Information
CoLife uses and shares the Personal Information it collects (unless otherwise restricted by applicable law), to:
i. Engage in Transactions. CoLife may use Personal Information to engage in transactions with you.
ii. Process Transactions. CoLife may use Personal Information along with, financial, credit card, and payment information, to process your transactions.
iii. Provide Support or Other Services. CoLife may use your Personal Information to provide you support or other services you have ordered, as well as product updates, product patches and fixes and other similar operational communications.
v. Provide CoLife Online Communities. Some Channels permit you to: participate in interactive discussions; create a profile; post comments, opportunities or other content; communicate directly with another user; or otherwise engage in social activities. Some of these services are moderated and all may be accessed for technical reasons. CoLife does not control the content that users post to these forums or social networks. You should carefully consider whether you wish to submit Personal Information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you submit appropriately. You should also review any additional terms and conditions that may govern your use of these Channels.
vii. Post Testimonials. We post testimonials (which may be edited for length or content) on our Channels that may contain Personal Information. If you wish to update or delete your testimonial, please contact us.
ix. Select Content, Improve Quality and Facilitate Use of the Channels. CoLife may use your Personal Information to help create and personalize content on our Channels, facilitate your use of the Channels (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security, keep track of shopping cart additions and preserve order information between sessions), improve quality, track marketing campaign responsiveness (including online advertising and e-mail marketing), and evaluate page response rates.
x. Power Joint Sales or Product Promotions. CoLife and its partners may engage in joint sales or product promotions. Such promotions will always reference the partners involved. Both CoLife and the partner(s) will have access to that information, and either CoLife or our partners may provide you the sales or product promotion information. Each party will be responsible for managing their own use of the Personal Information collected for the joint sale or product promotion. We recommend you review the privacy policies of these partners to address any questions you have regarding their handling of your information.
xi. Improve Products, Services, and Experiences. CoLife may use your Personal Information to evaluate and improve our products, services, marketing, and customer relationships.
xii. Communicate with You about a Conference or Event. We or our partners may communicate with you about a conference or event hosted or co-sponsored by CoLife or one of our partners. This may include information about the event's content, logistics, payment, updates, and any additional meetings, special demonstrations or other customer facilitation that we may provide related to your event registration. After the event, CoLife may contact you about the event and related products and services, and may share information about your attendance with your company. Where legally permitted, CoLife will also allow designated partners or conference sponsors to send you communications related to your event attendance. Please note that our partners or conference sponsors may directly request your Personal Information. You should review their privacy policies to learn how they use Personal Information.
xiii. Obtain Third Party Services. We also share Personal Information with third parties who provide services to CoLife, such as credit card processing services, order fulfillment, analytics, event / campaign management, application management, web site management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar services.
xiv. Protect our Employees, Sites, Facilities, and Operations. CoLife may disclose your Personal Information as we believe to be necessary or appropriate to protect the health and safety of our employees and visitors, our physical and online operations, our property, rights, and privacy, and/or that of our affiliates, you or others. If you visit our offices, you may be photographed or videotaped as part of maintaining the security of our facilities. Facility security photography will be treated as sensitive information and will only be used for security and investigation purposes.
xv. Comply with Legal Requirements and Corporate Transactions. CoLife may disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.
xvi. Conduct Background Checks. CoLife reserves the right to conduct—and you authorize CoLife to conduct—any background check or other screenings at any time using available public records, and you agree that any information you provide may be used for that purpose. If CoLife decides to conduct any screening through a consumer reporting agency, you hereby authorize the company to obtain and use a consumer report about you to determine your eligibility under these terms.
b. Other Information
We may use, transfer, and disclose Other Information we collect for any purpose, except where applicable law requires otherwise. If we are required to treat Other Information as Personal Information under applicable law, then we will only use it in the same way that we are permitted to use and disclose Personal Information.
3. How We Collect Information
CoLife and our third party service providers may collect both Personal Information and Other Information from a variety of sources that generally fall into three categories:
a. Direct Interactions: From your use of and interaction with us through the Channels and other activities such as account creation, submission of registrations and forms, or sales inquiries and transactions.
b. Publicly Available Data / Data from Third Parties: Data from Automated Interactions on non-CoLife websites, or other data you may have made publicly available, such as social media posts, or data provided by third party sources, such as CoLife Customers, marketing opt-in lists, or data aggregators.
c. Automated Interactions: From the use of technologies such as electronic communication protocols, cookies, embedded URLs or pixels, or widgets, buttons and tools.
Although CoLife's use of Automated Interactions may change over time as technology evolves, the following descriptions are designed to provide you with additional detail about CoLife's current approach to information collected from Automated Interactions.
i. Electronic Communications Protocols: As is true when you visit most websites and apps, CoLife may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), your IP address (which may identify your general geographic location or company), and date and time.
CoLife may also automatically receive and record information about your interaction with the Channels, such as clickstream information (when each CoLife webpage was visited, how much time was spent on the page, and how you interacted with the webpage), or general geo-location data.
ii. Cookies: CoLife's server will query your browser to see if there are "cookies" previously set by our electronic Channels. A cookie is a small piece of information sent by a Web server to store on a Web browser so it can later be read back from that browser. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, and general usage and volume statistical information. Cookies may also be used to collect individualized web site use data, provide electronic Channel personalization, or conduct and measure the effectiveness of advertising in accordance with this Policy. Some cookies may remain on users' computers after they leave the Website. While the majority are set to expire within 1-24 months of your last visit to the website that set the cookie, others may not expire because of their nature, like cookies that remember opt-out preferences.
Your browser may provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion. Cookies, however, are important to the proper functioning of a site, and disabling them may degrade your experience and interfere with Web site features and customizations.
CoLife may track and analyze both individualized usage and volume statistical information from interactions with electronic Channels.
iii. Embedded URLs: We may use a tracking technique that employs embedded URLs to allow use of the electronic Channels without cookies. Embedded URLs allow limited information to follow you as you navigate the electronic Channels, but are not associated with Personal Information and are not used beyond the session.
iv. Embedded Pixels and Similar Technologies: On the electronic Channels, CoLife and its service providers may use embedded pixel technologies for the purposes of identifying unique user visits (as opposed to aggregate hits), and for advertising purposes. In addition, embedded pixels or other technologies may be used in e-mails and our online display advertising to provide information on when the e-mail or ad was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient's e-mail address.
vi. Physical Location: We may collect the physical location of your device and use it to provide you with personalized location-based services or content. In some instances, you may be permitted to allow or deny such use of your device's location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized services or content.
d. Third Party Permission-Based Lists. On occasion, CoLife may use third-party lists to send communications about CoLife products and services. These lists, which are maintained by third parties, include users eligible under applicable law to receive e-mails from other companies such as CoLife.
For California Residents. Under California Civil Code Section 1798.83 (also known as S.B. 27), if you are a California resident and your business relationship with CoLife is primarily for personal, family, or household purposes, you may request certain data regarding CoLife's disclosure, if any, of Personal Information to third parties for the third-parties' direct marketing purposes. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties' names and addresses. Please note that not all Personal Information sharing is covered by S.B. 27's requirements.
4. Access, Correction, and Profile Updates
You may request to review, correct, update, suppress, or otherwise modify any of your Personal Information that you have previously provided to us through the Channels, or object to the use or processing of such Personal Information by us. You have the ability to update your Personal Information at any time. If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us.
5. Retention and Deletion
CoLife will retain your Personal Information for as long as needed to provide you products or services; as needed for the purposes outlined in this policy or at the time of collection; as necessary to comply with our legal obligations (e.g., to honor opt-outs), resolve disputes, and enforce our agreements; or to the extent permitted by law.
At the end of the retention period, CoLife will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.
Some banner ads may contain embedded pixels that may write and read cookies or return session connection information that allows advertisers to better determine how users have engaged with the ad banner.
CoLife may use advertising technologies and participate in advertising technology networks that collect Other Information from CoLife and non-CoLife websites, as well as from other sources, to show you CoLife-related advertisements on CoLife’s own and third-party websites. These advertisements may be tailored to your perceived interests using retargeting and behavioral advertising technologies, a set of practices collectively referred to as “interest based advertising” in this policy. Any retargeted or behavioral advertisements served to your browser will contain information on or near it that informs you about the advertising technology partner and how to opt-out of viewing such advertisements. Opting-out does not mean that you will stop receiving ads from CoLife. It means that you still stop receiving ads that have been targeted to you based on your visits and browsing activity across websites over time.
The security of your Personal Information is very important to CoLife. We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
In addition, CoLife uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as credit card details.
In the event that your Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, CoLife will notify you by e-mail, fax, or U.S. mail. CoLife will give you notice promptly, consistent with the reasonable needs of law enforcement and/or CoLife to determine the scope of the breach and to investigate and restore the integrity of the data system.
8. Model Release
If you provided a testimonial, CoLife may wish to develop and/or use photographs, videos, and/or audio recordings of you (“Media”). If you agree to the creation or development of Media, or provide Media in connection with your testimonial, then you are a “Model.”
Model hereby grants to CoLife the irrevocable and unrestricted right and permission to copyright, in CoLife’s own name, and use, re-use, publish, and re-publish Media in which Model may be included, in whole or in part, including but not limited to composite in character or form, without restriction as to changes or alterations, or reproductions thereof in color or otherwise, made through any and all media now or hereafter known for illustration, promotion, art, editorial, advertising, trade, or any other purpose whatsoever.
Model hereby waives any right that Model may have to inspect or approve the finished product or products and the advertising copy or other matter that may be used in connection therewith or the use to which it may be applied.
Model hereby releases, discharges and agrees to save harmless CoLife and all persons acting under the permission or authority of CoLife from any liability by virtue of any blurring, distortion, alteration, optical illusion, or use in composite form, whether intentional or otherwise, that may occur or be produced in the taking of said Media or in any subsequent processing thereof, as well as any publication thereof, including without limitation any claims for libel or invasion of privacy. Model’s release shall be binding upon Model and Model’s heirs, legal representatives, and assigns.
CoLife may only assign its rights related to this Section in connection with a merger, consolidation, or through the transfer of all or substantially all of the equity, assets, or business of CoLife.
9. Children's Privacy
CoLife's Channels are not directed to minors and CoLife does not promote or market its services to minors, except as part of specific educational outreach programs. If you believe that we have mistakenly or unintentionally collected Personal Information of a minor through our Channels without appropriate consent, please notify us so that we may immediately delete the information from our servers and make any other necessary corrections.
Last Revised: May 25, 2019