Privacy notice

Last Modified: Oct 3, 2022

Welcome! This Privacy Notice explains how Cordoniq, Inc. (“ Cordoniq ”, “ Company ”, “ we ”, “ us ” or “ our ”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites (the “ Sites ”) and other websites we own and operate that link to this Privacy Notice, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “ Services ”). It does not address our privacy practices relating to Cordoniq job applicants, employees and other personnel.

Please note: This Privacy Notice does not apply to personal information that Cordoniq processes on behalf of our customers as a data “processor” under the European Union General Data Protection Regulation (“GDPR”), as a “service provider” under the California Consumer Privacy Act (“CCPA”) or in a similar role under other data protection laws applicable to our customers. We encourage you refer to our customers’ own privacy disclosures for more information about their practices.

If you are a customer that is considering entering into a Data Processing Agreement with Cordoniq for compliance with the GDPR, CCPA or other data protection laws, please contact us for more information.

I. What is Personal Information?

When we use the term “ personal information ” in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information” under applicable data protection laws.

II. Our Collection and Use of Personal Information

We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for an account, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, participate in a survey, redeem a promotion, or use another feature of our Services.

We may link or combine your activities and information collected from you on our Services with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You
We may collect the following categories of personal information from you through the Services:

  • Contact Information , including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
  • Account Information , including first name, email address, user ID / log-in name and any other information you provide to us. We use this information to administer your account, provide you with the relevant Services and information, communicate with you regarding your account and your use of the Services, and for customer support purposes.
  • Inquiry and Communications Information , including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the Services we offer to our users and to manage and grow our organization.
  • Newsletter, Marketing Emails, and Blog Information , including email address and applicable interests and communication preferences. We use this information to manage our communications with you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
  • Information Collected Through the Use of the Services , including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Services (collectively, “User Content”). User Content and any information contained in the User Content, including personal information you may have included, is stored and collected as part of the Services. We use the User Content to provide you with the Services.
  • Feedback Information . We may also collect feedback and ratings you provide relating to our Services. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
  • Business Representative Contact Information . If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
Personal Information Automatically Collected
As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:
  • Log Data , including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered and the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services). Log data may overlap with the other categories of data below.
  • Analytics data , Including the electronic path you take to our Services, through our Services and when exiting our Services, UTM source, as well as your usage and activity on our Services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.
  • Location data (such as geographic location we or our third-party providers may collect, such as via permissions within app operating system or browser functionality).

We and our third-party providers may use (i) cookies or small data files that are stored on your computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section.

Personal Information from Third Parties
We also obtain personal information from third parties. We may combine this information with personal information we collect either automatically or directly from you.

We may receive the same categories of personal information as described above from the following third parties:

  • Cordoniq Entities : We may receive personal information from other companies and brands owned or controlled by Cordoniq, and other companies owned by or under common ownership as Cordoniq.
  • Your Employer / Company : If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Services.
  • Other Users of our Services : We may receive your information from other users of our Services, such as your account administrator. We may use this information to administer and facilitate our Services.
  • Service Providers : Our service providers, such as survey and marketing providers, collect personal information on our behalf and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and other information about your account. We may use this information to administer and facilitate our Services, your account, and our marketing activities.
  • Business Partners : We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our Services.
  • Information we receive from authentication services you connect to our Services : Some parts of our Services may allow you to login through a third-party social network or authentication service. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. We use this information to operate, maintain, and provide to you the features and functionality of the Services. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Services, technical and security notices).
    We may offer Face ID, Touch ID or fingerprint authentication as a log-in method if you access the Services through an Apple or Android device equipped with authentication technology. We are only notified as to whether the authentication was successful and cannot access the data associated with the enrolled fingerprint. For more details, please refer to the applicable security guides offered by your device provider.
  • Other Sources : We may also collect personal information about you that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Cordoniq commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Cordoniq satisfies the requirements under applicable law.

Uses of Personal Information
We may use personal information we collect to:

  • Provide the Services you have requested;
  • Manage our organization and its day-to-day operations;
  • Verify your identity and entitlement to products or Services, when you contact us or access our Services;
  • Communicate with you, including via email, text message, social media and/or telephone calls;
  • Ask you to complete surveys about our organization, organizations we partner with, and Services;
  • Administer, improve and personalize our Services, including by recognizing you and remembering your information when you return to our Services;
  • Facilitate customer benefits and services, including customer support through our command center services;
  • Identify and analyze how you use our Services;
  • Conduct research and analytics on our customer and user base and our Services;
  • Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
  • Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
  • Help maintain the safety, security and integrity of our property and Services, technology assets and business;
  • To enforce any contracts we have with you, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
  • Comply with contractual and legal obligations and requirements;
  • To fulfill any other purpose for which you provide personal information; and
  • For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

III. Our Disclosure of Personal Information

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

  • Cordoniq Entities : We may share personal information with other companies owned or controlled by Cordoniq, and other companies owned by or under common ownership as Cordoniq, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
  • Your Employer / Company : If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
  • Marketing Providers : We coordinate and share personal information with our marketing providers in order to communicate with you about the Services.
  • Customer Service and Communication Providers : We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals who submit inquiries.
  • Other Service Providers : In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
  • Ad Networks and Advertising Partners : We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when you visit our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section below for more information.
  • Business Partners : From time to time, we may share personal data with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
  • Business Transaction or Reorganization : We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
  • Legal Obligations and Rights : We may disclose personal information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws or to respond to lawful requests and legal process;
    • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    • to detect, suppress, or prevent fraud;
    • to protect the health and safety of us and others; or
    • as otherwise required by applicable law.
  • At Your Direction : We may also disclose personal information about you to certain other third parties or publicly if you direct us to do so. For example, with your consent or at your direction we may post a testimonial you provide to us on our Sites or in other marketing materials.

IV. Third-Party Data Collection and Online Advertising

We may participate in interest-based advertising and use third party advertising companies to send you advertisements. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Please see below for more information about how you can opt out of interest-based advertising.

We may engage in the following:

  • Social Media Widgets and Advertising . Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
  • Social Media Platforms . We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
  • Third Party Partners . We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us.  We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the Services. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at  www.google.com/policies/privacy/partners/ . You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here:  https://tools.google.com/dlpage/gaoptout/ .
    We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at  https://google.com/ads/preferences , or by visiting NAI’s online resources at   http://www.networkadvertising.org/choices .

For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section below.

V. Control Over Your Information

You may control your information in the following ways:

  • Access to Your Device Information . You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications.
  • Email Communications Preferences . You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
  • Push Notifications . You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.
  • Modifying or Deleting Your Information . If you have any questions about reviewing, modifying, or deleting your information, you can contact us using the contact information at the end of this Privacy Notice. We may not be able to modify or delete your information in all circumstances.
  • Cookies : For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to cookies, please see the Information We Collect Automatically section above.
  • Online Ads : To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices . You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

VI. Children’s Personal Information

Our Services are not directed to children under the age of 16, and we do not intend to collect or solicit personal information from younger children. If you are under the age of 16, you should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

VII. Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

VIII. Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email, by prominent posting on our Services, or through other another reasonable method. All changes shall be effective from the date of publication unless otherwise provided.

IX. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please contact legal@cordoniq.com .