Privacy Policy
Effective Date: July 25, 2024
This “Privacy Policy” describes the privacy practices of Coterie Baby, Inc. and our subsidiaries and affiliates (collectively, “Coterie”, “we”, “us”, or “our”) and how we collect, use and disclose information collected on Coterie’s website https://www.coterie.com/ and any other website that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.
Personal Information We Collect
- Information you provide to us. We collect data whenever a customer uses the site, texts with our phone number, emails customer support, engages with us on social media, or places an order (including recurring orders). Personal information you provide to us through the Service or otherwise may include:
- Contact information, such as your first and last name, email and mailing addresses, and phone number. If you purchase a gift for someone, we may collect both your contact information and theirs.
- Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload.
- Correspondence, such as information you provide when you contact us with questions, feedback, or otherwise connect with us online.
- Payment information, such as payment card details and billing address.
- Baby and familial information, including information provided in our Size Quiz such as number of children, children’s names, birth or due dates, weight, height, other physical characteristics, and diaper usage information (such as questions about sensitive skin)
- Profile information, such as your username and password that you may set to establish an online account with us, your interests, and preferences.
- Transaction information, such as information about payments to and from you, subscription details (including gift recipients), shipping address, billing address, and other details of products or services you have purchased from us.
- Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
- Publicly available information, including comments describing support for and experience with our websites and information that you or others publish on social media, testimonials, blogs, or other forums, such as tweets, comments, and photographs.
- Behavioral information disclosed through surveys and feedback.
- Profiling data, such as inferences about purchasing tastes.
- Information we obtain from social media platforms. We may maintain pages for Coterie on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, Pinterest, TikTok, Yotpo, Reddit and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. Please see the “Other Sites and Services” section below regarding how such social media platforms use information they collect about you
- Information we obtain from other third parties. We may receive personal information about you from third-party sources, such as email services that you use to log into, or otherwise link to, your Service account. This data may include your username, and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. We may also obtain your personal information from other third parties, such as advertising partners, referral partners and publicly available sources.
- Information Collected by Automated Means. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, may automatically log the following information about you:
- Device information, such as your computer or mobile device operating system type and version number, manufacturer and model, screen resolution, device identifier (such as the Google Advertising ID or Apple ID for Advertising);
- browser type;
- screen resolution;
- IP address (via logs and cookies);
- the website you visited before browsing to our website;
- general location information such as city, state or geographic area; and
- online activity data, such as information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
- Cookies and other tracking technologies. For information about our use of cookies, please see our Cookie Policy
- Referrals/Gifts. Users of the Service may have the opportunity to refer friends or other contacts to us, or to gift a subscription to another individual. Please do not submit a referral or provide us with contact details unless you have permission from the recipient to do so.
How We Use Your Personal Information
- We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
- To operate the Service. We use your personal information to:
provide, operate and improve the Service; - provide information to you or individuals you may refer about our products and services;
- establish and maintain your user profile on the Service;
- send you announcements, updates, security alerts, and support and administrative and transactional messages;
- understand your needs and interests, and personalize your experience with the Service and our communications;
- provide support and maintenance for the Service;
- to optimize the user experience;
- respond to your requests, questions, and feedback through the Service, email, or our social media platforms;
- for research and development. We analyze use of the Service to improve the Service and to develop new products and services, including by studying user demographics.
- To operate the Service. We use your personal information to:
- To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. This Privacy Policy does not apply to, and we are not responsible for, cookies or clear gifs in third party ads, and we encourage you to check the privacy policies of advertisers and ad services providers and social media companies to learn about their use of cookies and other technology. To learn more about your choices in connection with advertisements, please see our Cookie Policy.
- For marketing purposes. We may use your personal information to communicate with you about events or contests in which you participate, understand your needs and interests and personalize your experience with the Service and our communications, and send you Coterie-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the opt out of marketing communications section below.
- For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; (e) to audit our internal processes for compliance with legal and contractual requirements and internal policies; and (f) enhance security and to monitor and verify identity or service access.
- To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
- With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How We Share Your Personal Information
We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:
- Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, payment providers, shipping services, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
- Advertising Partners. We may sometimes share your personal information with advertising partners or enable these advertising partners to collect information directly via our Service. We do not control how these advertising partners use your personal information. Please review the relevant advertising partner’s privacy policy to learn about how it may use your personal information.
- Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- For compliance, fraud prevention and safety. We may share your personal information with law enforcement, government authorities, and private parties as we believe necessary or appropriate for compliance, fraud prevention and safety purposes.
- Other Users of the Service and the Public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name, username, and a link to your user profile along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.
- Business transfers. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Coterie, financing of Coterie, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Coterie as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
- As you instruct us. We may also share your personal information where you instruct us to do so or where you have provided consent (for example, when you agree to share your information with third parties for their own marketing purposes, subject to their data protection policies).
Your Choices
- In this section, we describe the rights and choices available to all users.
- Access or update your personal information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
- Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at hello@coterie.com. You may continue to receive service-related and other non-marketing emails.
- Opt out of SMS communications. If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message. You may also text STOP to +1-951-467-4913.
- Cookies & browser web storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
- Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
- Google: https://adssettings.google.com/
- Facebook: https://www.facebook.com/about/ads
- Retention.com: https://app.retention.com/optout
- Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: https://www.optout.aboutads.info
- AppChoices mobile app, available at: https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
- Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
- Do not track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
- Linked third-party platforms. If you choose to connect to the Service through your email account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
- User Generated Content. Certain features of the Service may allow you to upload content (e.g., comments or photos) directly to the Service (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Coterie. If you post reviews or comments on third party sites they are governed by the terms of use of that site, please review such terms before posting.
Please note that we do not control who will have access to information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them. We are not responsible for the accuracy, use or misuse of any such UGC that you disclose or receive from third parties.
Other Sites and Services
The Service may contain links to other websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. Any information submitted by you directly to such web pages or online services is subject to that third party’s privacy policy. We encourage you to read the privacy policies of the other websites and online services you use.
Security Practices
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International Data Transfers
We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.
Children
The Service is not intended for use by anyone under 16 years of age. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will comply with applicable legal requirements to delete it. We encourage parents with concerns to contact us at hello@coterie.com or use this form
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.
Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy as well as take such other steps as required by law.
How to Contact Us
We welcome your comments or questions about this privacy policy. You may contact us at:
Coterie Baby, Inc.
Attn: Legal – Privacy
160 Varick Street
Floor 3 Suite 103
New York, NY 10013
1-866-I-OPT-OUT(1-866-467-8688) and enter Service Code 2016#. (Calls from USA only)
Supplement Notices to Residents of California, Colorado, Connecticut, Utah and Virginia
- We are providing this supplemental privacy notice to residents of various states of the United States as required by such state privacy laws including, to the extent applicable, the California Consumer Privacy Act of 2018, as amended (“CCPA”) the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (VCDPA).
It describes in further detail how we collect, use and share Personal Information in operating our business, and their rights with respect to that Personal Information. Please note that we may not be able to process your request to exercise the rights listed below if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.- Definition: For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) as amended, but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.
- What do we collect? Personal information that we collect, use, and disclose. We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal Information We Collect” section of this Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and described our practices currently and during the twelve (12) months preceding the effective date of this Privacy Policy.
Information you voluntarily provide to us, such as in webforms, may contain other categories of personal information not described below. All categories described in this Privacy Policy may include “identifiers” or “inferences” (as defined below).
Categories of Personal Information | Specific Types of Personal Information Collected | Was the information used (sold, shared, or disclosed) for a business purpose? |
---|---|---|
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers) | Real name, postal address, unique personal identifier, online identifier, internet protocol address, and email address. | This information was shared to help finalize orders, send confirmation emails, provide customer service, send shipping notifications, collect feedback about our Site, attribute referrals, and perform site analytics. |
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Name, postal address, email address. | This information was disclosed to provide reminders and other business needs listed above. |
Characteristics of protected classifications under California or federal law. | Age and sex if you create an account with us. | We collect the age and sex of your baby in our size quiz to help you find the right diapering products and sizes. |
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | Transaction data and information related to the Services you’ve purchased. | This information is shared for marketing purposes, including to send retention emails. |
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement) | Information regarding your interaction with our Sites or Services. | This information is shared for customer retention purposes |
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Customer preferences, and other aggregated metrics. | We share this information in an aggregated form only to learn about customer sentiment. |
Sensitive Personal Information (as described in CCPA): your account log-in, credit or debit card number, in combination with your credentials required for you to access your account, precise geolocation, racial or ethnic origin, sexual orientation, religious or philosophical beliefs, and union membership. | Your account log-in, credit or debit card number, in combination with your credentials required for you to access your account. | This information may be collected but is not shared. |
c. Who we may disclose information to: We may disclose each of the categories of personal information identified above to the following categories of third parties for a business or commercial purpose, for example in the preceding twelve (12) months we have sold or shared consumer personal information with:
- Affiliates; (this includes ecommerce, subscription management, email, and inventory management partners)
- service providers we use to help deliver and ship our products to you, such as payment service providers, warehouse and delivery companies;
- payment processors;
- advertising partners;
- third parties designated by you such as social media sites you link to your account and third-party payment providers;
- professional advisors;
- authorities;
- business transferees;
- credit reporting agencies;
- our insurers and brokers;
- our bank;
- external auditors;
- business and marketing partners who help run our business such as marketing agencies, website plugins, and website hosts.
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the California Consumer Privacy Act.
d. How Long Personal Information will be Kept. We will keep your personal information while you have an account with us or while we are providing products to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To know who not to advertise to;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.e.
e. Your privacy rights. You may have the rights listed below in relation to information we have collected about you as defined in the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Type of Information | Your Related Rights |
---|---|
Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure or a copy of: • The categories of personal information we have collected about you, including sensitive personal information; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting, selling, or sharing personal information; • The categories of third parties to whom we disclose personal information, if any; and • The specific pieces of personal information we have collected about you. Please note that we are not required to: • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period. |
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose. You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. To opt-out of the sale or sharing of your personal information, submit your details via the form located at https://webform.ccpatollfree.com/ccpa-compliance/solutions/e782c633-a1c2-4a8d-813f-eaf21ac87003/form.html?_ga=2.150749366.1068349743.1720998770-411681035.1720998770 |
Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: • Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; • To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and • As authorized by further regulations You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, submit your details via the secure form located at https://webform.ccpatollfree.com/ccpa-compliance/solutions/e782c633-a1c2-4a8d-813f-eaf21ac87003/form.html?_ga=2.150749366.1068349743.1720998770-411681035.1720998770 |
Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: • Delete your personal information from our records; and • Direct any service providers or contractors to delete your personal information from their records. • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort. Please note that we may not delete your personal information if it is reasonably necessary to: • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: • Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
- Right to opt-out of the “sale” or “sharing” of your Personal Information for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.
- Consumers under 16. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
- Freedom from Discrimination. You are entitled to exercise the rights described above free from unlawful discrimination as prohibited by the CCPA.
f. Exercising your right to information, access, correction, and deletion. You may submit requests to exercise your right to information, access, correction, or deletion by emailing hello@coterie.com or filling out this form.
a. If you choose to contact us via telephone, you will need to provide us with:
- Enough information to identify you (e.g., your full name, email, address, and customer or matter reference number);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or if someone authorized to act on such person's behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
Under the CPA we are required to respond to your requests without undue delay but within 45 days of receipt of your request. Depending on factors such as the type and complexity of the request, we may extend the time for response once for 45 additional days, as long as we notify you within the original 45 days. If we decline to take action regarding your request, we must notify you without undue delay, but within 45 days of the receipt of the notice and provide information on our appeal process. We are required to provide justification and provide information on the appeal process within a reasonable time after the communication of the decision to decline.
g. Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. While we do not sell personal information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The CCPA may classify our use of some of these services as “selling” or “sharing” your Personal Information with the advertising partners that provide the services. You can submit requests to opt-out of tracking for targeted advertising purposes by emailing hello@coterie.com or filling out this form.
h. We share the following categories of personal information with advertising partners: Contact information; Demographic data; Account data; Correspondence; Marketing information; Profile information; Transaction information; Marketing information; Device data; Online activity data; data derived from the above. You have the right to opt-out of such sales, as described above.
i. Under the CCPA and other state laws you many enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your CCPA rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
j. California Shine the light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may request this information by emailing hello@coterie.com or filling out this form. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Supplement Notices to Residents of Washington
This portion of our Policy only applies to Washington state residents.
As a Washington resident, the Washington State My Health My Data (“MHMD”) Act gives you certain choices regarding your health data, as described below. The law applies only to “consumer health data” about your past, present, or future health condition.
Consumer Health Data We May Collect: We collect data from a variety of sources. Because consumer health data is defined very broadly in the MHMD, much of the data we collect could also be considered consumer health data.
Examples of consumer health data we collect may include:
Information about your child’s health-related conditions, symptoms, status, or treatments. For example, your use of our products may give us insight into your (or your child’s) health status. We also collect health information when you interact with our website through quizzes and similar offerings. These surveys and calculators give us additional insight into your health status.
Information that could identify your propensity to seek health care services or information.
Behavioral biometrics resulting from your use of our websites. Data collected may include pages visited, actions taken (button clicks, products purchased, files downloaded, samples ordered, searches performed, and other actions taken), and keystrokes.
Inferences derived from the above data.
Sources of Consumer Health Data
We collect personal data (which may include consumer health data) from three main sources:
- Information you provide us directly by ordering products, signing up for newsletters, filling out surveys, entering promotions, or registering for an account.
- Information collected automatically with you browse our website.
Why We Collect and Use Consumer Health Data
We collect and use this data as reasonably necessary to provide you with the products you have requested and to market to your interests. Providing requested products to you may include delivering the products, making suggestions about what products are appropriate for you, and/or personalization of certain product features. We also use consumer health data to improve our products and for other essential business operations, such as analyzing our performance, meeting legal obligations, and conducting research and development.
We may also use consumer health data to market or advertise our own products and services. We may also use your purchase history or information received from third parties to advertise other products we sell that we think may be of interest to you.
For marketing and advertising, we give you choices and/or obtain your consent as required by law. Please see the opt out section.
Disclosures of Consumer Health Data
We may share each of the categories of consumer health data described above with your consent or as reasonably necessary to provide our products and services.
We may also share your information with service providers who operate on our behalf to help us provide you with products and services you have requested, to make product improvements, and to market and advertise our products and services to you.
Processors and other Third Parties with whom We Share Consumer Health Data
As necessary for the purposes described above, we may share consumer health data with the following categories of third parties: Service Providers, Third Parties and Partners, and Government Agencies and Law Enforcement. Examples include: analytics companies, advertisers, and social media networks as well as parties to a business transaction such as a corporate merger.
How to Exercise Your Rights
The MHMD Act provides certain rights with respect to consumer health data. These rights include your right to access your consumer health data and receive a list of all third parties and affiliates—including contact information—who receive your health data. You also have the right to request that we delete your consumer health data. You can withdraw consent relating to the collection and sharing of your data too, subject to certain exceptions.
You can request to exercise such rights by filling out this form
If your request to exercise a right under the MHMD Act is denied, you may appeal that decision by contacting our Global Privacy Officer at privacy@coterie.com . If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
Cookie Policy
This Cookie Policy explains how we use cookies and similar technologies in connection with our website and any other website that we own or control and which posts or links to this Cookie Policy (collectively, the “Sites”).
What are cookies?
Cookies are small data files sent from a server to your web browser. They are stored in your browser’s cache and allow a website or a third party to recognize your browser.
Our sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them). We specifically use two types of cookies:
(1) first party cookies, provided directly by us to your computer or mobile device, which we use to recognize you when you revisit our Sites; and
(2) third party cookies, which are served by service providers or other third parties, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising, and social media features.
We Use the Following Categories of Cookies.
Essential cookies: These cookies are strictly necessary to provide you with services available through our Sites and to use some of its features. Refusal of these cookies may impact Site functionality.
Performance and functionality cookies. These cookies are used to enhance the performance and functionality of our Sites but are not required for site use. However, without these cookies, you may lose functionality, and we will not be able to conduct analytics to optimize site functionality and performance.
Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Sites are being used generally, or how effective our marketing campaigns are, or to help us customize our Sites specifically for you. Without these cookies, we will not be able to analyze your site usage to provide custom content.
Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously re-appearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
Other technologies
In addition to cookies, our Sites may use other technologies such as pixel tags to collect information automatically.
UTM codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a web page) when a user moves from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
Local Storage Objects: These are sets of data that can be stored on your browser by a site or app. They can be used to maintain preferences, a history of usage, or even the state or settings of a site or an app.
Internet of Things identifiers: Like mobile identifiers, internet-connected devices such as voice activated assistants or smart TVs may send identifiers and other data analogous to web browsers.
Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with a unique identifier that are used to understand browsing activity. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are rendered invisibly on web pages when you open a page.
Your choices
There are a number of ways that you can opt-out or manage cookies. Your options for controlling what information cookies and similar technologies collect about you include:
Your Cookie Settings. When you visit our Sites, depending on where you are located, we may show you a notice which tells you how and why we use certain cookies and provide you the ability to opt out of certain cookie use (other than Essential cookies necessary to provide our Sites).
Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.
If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
For more information about how we collect, use and share your information, see our Privacy Policy.
Changes
Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.
Questions
If you have any questions about this Cookie Policy, please contact us by emailing hello@coterie.com or filling out this form.