Last modified: June 11, 2023
CopingCard, Inc. ("Company" or "we") respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide to the Company’s mobile application, tablet application, technology platform, and website including any content, functionality, and services offered on or through such application, website, or platform (collectively, "CopingCard") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to the information we collect:
It does not apply to information collected by:
We collect several types of information from and about CopingCard users, including information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). In particular, CopingCard may collect the following categories of personal information (note: some information may overlap in multiple categories):
|Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Name, email address, user/account identification, Identifier for Advertisers (IDFA); and purchase history||Directly from you; indirectly from you through a third-party authenticator 3|
|Internet or other similar network activity||Browser type, device type, operating system, web pages viewed, pages clicked, IP address, frequency of visits; time spent viewing webpages, date/time of access, connection speed; device identification||Indirectly from you; collected from cookies|
|Geolocation Data||Physical location||Indirectly from you;|
We collect the information detailed above:
By using CopingCard, you consent to our use of automatic data collection and tracking technologies. The types of technologies we may use include cookies and Google Analytics.
You can choose to not accept or delete (“flush”) cookies by adjusting your browser settings or CopingCard settings in the applicable application. However, if you do so, you may be unable to access certain parts of CopingCard or lose some of the functionality. Unless you have set your browser not to accept cookies, CopingCard will issue cookies when you are using CopingCard.
Opting-Out and Managing Cookies: When you visit CopingCard, you can change the settings in your browser or device to alter the cookie preferences, including not accepting cookies. We have provided links below to further information on how to manage cookies depending on the browser or device you use:
Google Play Services: We use Google Play Services to enable certain functionality and optimize CopingCards mobile and tablet applications. More information about Google Play Services can be found at the following URLs: https://support.google.com/android/answer/10546414
YouTube Data API: We use YouTube Data API to retrieve feeds. More information about YouTube Data API can be found at the following URLs: https://developers.google.com/youtube/v3 and https://support.google.com/code/answer/74722?hl=en
Firebase: We use Firebase to get real time crash reports of your device. More information about Firebase can be found at the following URLs: https://firebase.google.com/products/crashlytics
Sentry: We use Sentry to get real crash reports and fixes of your device. More information about Sentry can be found at the following URLs: https://sentry.io/welcome/
Adapty: We use Adapty to collect purchase information. More information about Adapty can be found at the following URLs: https://adapty.io/
Microsoft Appcenter CodePush: We use Microsoft Appcenter CodePush to make bug fixes and small updates happen faster. More information can be found at the following URL: https://docs.microsoft.com/en-us/appcenter/gdpr/data-from-your-end-users
Microsoft Azure OpenAI: We use Microsoft Azure OpenAI to generate images and suggestions for tools. More information can be found at the following URL: https://learn.microsoft.com/en-us/legal/cognitive-services/openai/data-privacy
By using CopingCard, you consent to the processing of data using the above tools in the manner described for the aforementioned and reasonably related purposes.
We may use, or disclose the personal information we collect for one or more of the following business purposes:
We may share your personal information by disclosing it to a third party for a business purpose.
We provide a brief summary of the sharing of your personal information below:
|Type of Personal Information||Business Purpose Disclosures to Third Parties|
|Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Identity verification; facilitate payment processing; data analytics; marketing purposes;|
|Internet or other similar network activity||Identity verification; facilitate payment processing; data analytics; marketing purposes|
|Geolocation Data||Provide app functionality (geolocation notifications) and customization|
We do not sell personal information.
We use measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, we always use commercially reasonable efforts to follow industry best practices for authorization, encryption and access controls. Toward that end, all information you provide to us is stored on secure servers behind firewalls such as Google Cloud. In addition, your personal information may be stored by third parties who provide services to us, which third parties will be required to maintain such information securely.
Please note that the safety and security of your information also depend on you. Because CopingCard requires registered users to provide unique identifiers such as their username and password, you are responsible for keeping such username and password information confidential. You should not therefore share your username or password information with anyone.
Unfortunately, the transmission of information over the Internet is not completely secure at all times. Although we do our best to protect your personal information, we cannot guarantee the security of such personal information transmitted 100% of the time. Any transmission of such information is therefore at your own risk. We are not responsible for the circumvention of any privacy settings or security measures on CopingCard.
We will retain your information for as long as your account is active with CopingCard. If you no longer want to use CopingCard, you may close your account. However, after closing your account, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our obligations and agreements.
You may also request that we delete any personal information that we have collected from/about you. We will evaluate your request and delete the information subject to applicable law. However, we need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use CopingCard.
Notwithstanding the above, we may retain personal information as authorized under applicable law or regulation. For example, personal information will be retained (i) to comply with federal, state, or local laws, rules, or regulations; (ii) to comply with civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, local or other governmental authorities; (iii) to cooperate with law-enforcement agencies concerning conduct or activity that are reasonably and in good faith believed to violate federal, state, or local laws, rules, or regulations; (iv) to debug to identify and repair errors that impair existing intended functionality; (v) to exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided by law; or (vi) to enable solely internal uses that are reasonably aligned with the expectations of the consumer based on your relationship with us.
To exercise your deletion requests subject to applicable law, please submit your request via email to email@example.com with the subject heading “DELETION REQUEST” (or else your request may be delayed or inadvertently ignored). Please also specify your name and your state (or states) of residence within the past twelve months.
For security purposes, we may request additional information from you to verify your identity.
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
PLEASE NOTE THAT THE EXERCISE OF YOUR RIGHTS DEPENDS ON WHETHER WE ARE A “COVERED BUSINESS” UNDER THE CCPA. CURRENTLY WE ARE NOT A COVERED BUSINESS. WE WILL HONOR YOUR RIGHTS BELOW WHEN WE BECOME A COVERED BUSINESS.
CA’s Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:
CA’s Right to Correct
You have the right to request that we correct any inaccurate personal information maintained about you.
CA’s Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Your CA Rights to Know, Correct, or Delete
To exercise your rights to know or delete described above, please submit a request by:
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child. You (or your guardian acting on your behalf) may only submit a request to know twice within a 12-month period. The request to know or delete must:
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.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact support@CopingCard.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If we cannot reply with a request, we will explain the reasons for refusing your request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer 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.
You can review and change your personal information by logging into CopingCard and visiting your account profile page.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of CopingCard, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to CopingCard. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the CopingCard.
No Discrimination for Exercising CA Rights
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
This Privacy Notice applies to CopingCard and is intended to comply with the European Union’s (“EU”) General Data Protection Regulation (“GDPR”). This Privacy Notice applies to Personal Data that CopingCard Inc. ("Company" or "we") collects or processes through CopingCard about a user (“Data Subject” or “you”) while the Data Subject is located in the EU, regardless of whether the Data Subject is a citizen or permanent resident of an EU country. “Personal Data” means any information relating to an identified or identifiable Data Subject.
CopingCard is a professional tool that aims to assist you in stressful situations. As such, CopingCard collects, processes, and uses Personal Data to review and process the information to enable use by the Data Subject and render services.
CopingCard’s lawful basis or bases for collecting and processing Personal Data include the following:
If a Data Subject refuses to provide Personal Data that CopingCard requires in connection with one of our lawful basis or bases for collecting such Personal Data, such refusal may make it impossible for us to render our services. CopingCard’s services are specifically tailored to you. If you are uncomfortable sharing your personal data, please do not use CopingCard.
CopingCard collects and processes the following categories of Personal Data in order to enable creation of a profile to facilitate suitable course recommendations.
Personal Identifiers: Name, email address, user/account identification, Identifier for Advertisers (IDFA); and any purchase information
Internet or Other Similar Network Activity Browser type, device type, operating system, web pages viewed, pages clicked, IP address, frequency of visits; time spent viewing webpages, date/time of access, connection speed; device identification.
Geolocation Data Physical location
The Personal Data that we collect is only shared with our data processors in order to provide CopingCard and who have agreed to protect the confidentiality of your Personal Data.
If you have specific questions regarding the collection and use of your Personal Data, please contact us at firstname.lastname@example.org.
We receive your Personal Data (i) directly from you or (ii) it is automatically collected.
This notice serves to inform you of your privacy rights pursuant to the GDPR. You as a Data Subject also have the right to:
If you wish to exercise any of the above-mentioned rights, you may do so by contacting us at email@example.com.
Cookies are files that many websites transfer to users’ web browsers to enable the site to deliver personalized services or to provide persistent authentication. The information contained in a cookie typically includes information collected automatically by the web server and/or information provided voluntarily by the user.
We also process automatically-gathered information as described in our Cookies Dashboard. Cookies that are necessary to display content or perform other functions you have requested, or that are necessary for the security or basic operation of our website, are turned on by default and cannot be turned off. We request your consent for the use of other cookies as listed on our Cookies Dashboard. You can always revoke your consent by visiting the Cookies Dashboard again.
Our main administrative offices are based in the USA and that’s where we process Personal Data collected through CopingCard. When you provide Personal Data to us, we request your consent to transfer that Personal Data to the USA. The USA does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the USA provide adequate protection for Personal Data. Although the laws of the USA do not provide legal protection that is equivalent to EU data protection laws, we safeguard your Personal Data by treating it in accordance with this GDPR Privacy Notice. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Data in storage. We use secure transmission methods to collect Personal Data through our website. We also enter into contracts with our data processors that require them to treat Personal Data in a manner that is consistent with this Notice.
How long we retain Personal Data varies according to how long you maintain an account with us. We delete Personal Data within a reasonable period after it is clear you are no longer active on CopingCard or we no longer need to use it for the purpose for which it was collected (or for any subsequent purpose that is compatible with the original purpose). This does not affect your right to request that we delete your Personal Data before the end of its retention period. We may archive Personal Data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.