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Privacy

Last Updated: February 18th 2021

This Privacy Notice is issued on behalf of COOLA LLC. (“COOLA”). “Affiliate” means any company that, directly or indirectly, controls or is controlled by or is under common control with COOLA LLC by means of ownership of more than 50 percent of voting stock or similar interest in that company. Therefore, when we mention the “COOLA”, “we”, “us” or “our” in this Privacy Notice, we are referring to COOLA LLC or one of its Affiliates which is responsible for processing your information. We value the trust you place in us when you provide us with your personal information. We take your privacy seriously and are committed to protecting it.

This Privacy Notice applies to any information, including personal information, COOLA collects online, including through our websites and mobile applications, and offline, including through our consumer product helpline.

This Privacy Notice explains:

What information may be collected and the means of collection
Your information may be collected in several ways, for example, when you provide information to us (such as name, date-of-birth, mailing address, and email address or other personal information); when you use or interact with our websites, mobile applications, products or services, general non-personal and other information about your use of our websites, mobile applications, products or services may be collected (such as IP addresses and device IDs) through the use of automated technology like cookies and beacons; and when information is collected from publicly available sources or shared with us by other sources. 

How we use information
We may use information for various purposes described in more detail below, including providing you with information about our company, products, promotions and other special offers, personalizing your website experience, delivering more relevant advertising content to you in our websites, third party websites or social media platforms, and conducting research and analysis on our websites, products, marketing efforts and sales.

When we share personal information
We do not sell or rent your personal information to other companies, as those terms are generally understood. Below we discuss laws that may provide a different definition of “sell” in certain jurisdictions. We may share your personal information with (1) your consent, (2) our subsidiaries and affiliates, (3) our partners, advertisers or other companies for business or operational purposes, (4) vendors providing services on our behalf, and (5) others to comply with legal obligations. Our purposes for sharing personal information vary in each of the categories above and are described in more detail below. 
 
How we safeguard information
We use industry-accepted security measures to help protect your personal information from unauthorized access, alteration, loss, or misuse. 

More on cookies, beacons, and how to stop automated collection of information
Automated technology (e.g., cookies and beacons) is used to collect general non-personal and other information and, in some cases, online identifiers like IP addresses and device IDs. 

More on online advertising on unrelated websites (targeted advertising) and how to stop its delivery
We use information collected through automated technology (e.g., cookies and beacons) to engage in targeted advertising. Click here to read more.
What laws govern the operation of COOLA’s websites and international transfers of personal informationOur websites are governed and operated in accordance with the laws of the United States, while designed to be compatible with the laws of the countries in which we operate. Click here to read more.
How we will inform you of changes to this Privacy NoticeWe may change this Privacy Notice at any time. If we make material changes, we will seek to provide you with reasonable notice of the changes. Changes will be effective immediately upon the posting of the revised Privacy Notice on our corresponding websites. 
 
How you can communicate with us about this Privacy Notice or your personal information
This Privacy Notice contains contact information if you have any questions or concerns about this Privacy Notice or your personal information. 

Note that the laws of certain countries and states may require that we set out specific information in this Privacy Notice as it relates to such countries or states. See below to read that information for those jurisdictions. Such location-specific information is part of this Privacy Notice and applies to information collected by COOLA only if and to the extent the laws of the applicable jurisdiction require such application.

COOLA websites may contain links to websites owned or operated by other companies. Those websites may collect data independently of COOLA. Please be aware that we do not control and are not responsible for the content, privacy policies, or practices of the websites of other companies. You should review the privacy notices of these websites before deciding whether to submit information to them.

PLEASE NOTE THAT OUR WEBSITES AND MOBILE APPLICATIONS ARE NOT INTENDED FOR CHILDREN. IF YOU ARE UNDER THE AGE OF 13, PLEASE DO NOT PROVIDE INFORMATION OF ANY KIND. HOWEVER, LAWS APPLICABLE IN CERTAIN COUNTRIES AND STATES MAY RESTRICT THE COLLECTION OF PERSONAL INFORMATION FROM OLDER INDIVIDUALS AND WE INTEND TO COMPLY WITH THOSE LAWS. YOU SHOULD REVIEW THE “COUNTRY AND STATE SPECIFIC INFORMATION” SECTION BELOW. PLEASE DO NOT PROVIDE INFORMATION OF ANY KIND IF YOU ARE UNDER THE AGE OF CONSENT UNDER SUCH APPLICABLE LAWS. WE DO NOT COLLECT PERSONAL INFORMATION FROM ANY PERSON WE ACTUALLY KNOW IS A CHILD UNDER THE AGE OF 13 (OR OTHER APPLICABLE OLDER AGE OF CONSENT).

PLEASE READ THIS PRIVACY NOTICE CAREFULLY, BECAUSE BY USING OUR WEBSITES AND MOBILE APPLICATIONS YOU ARE ACKNOWLEDGING YOU UNDERSTAND AND AGREE TO THE TERMS OF THIS PRIVACY NOTICE.

WHAT INFORMATION MAY BE COLLECTED AND THE MEANS OF COLLECTION

Your information may be collected in several ways, including: when you provide information to us, when information is collected automatically, or when information is shared with us by another company.

Information you provide to us
We collect information, including personal information such as name, date-of-birth, mailing address, and email address, when you provide it through registration to receive emails, request information, submit comments, sign up for an account on our websites or mobile applications, submit product reviews or participate in a promotion (e.g., contest or sweepstakes) or survey. For example, if you are on the website of a TV network, viewing COOLA content such as a product promotion, and you opt-in to receive information from COOLA, the TV network website will share information you provided with us so we can contact you as requested.

If a COOLA website offers shopping or other commercial services, you will use an order-form to request information, products and services. We will collect information relating to the transaction, including order information and shipping address. In some cases, the order-form may ask that you establish an account with a username and password. The order-form may ask you to provide financial information, like account information (including username and password) or credit or debit card numbers, the expiration date of your credit or debit card, the name on your credit or debit card, your billing address, or other payment information. This information is transmitted to us or our service providers through a secured browsing session. Do not send us any financial information outside the secured browsing session.

We maintain websites to support our business-to-business customers and end-users of our products and services in segments such as industrial, institutional and healthcare. If you are accessing our websites on behalf of a business, we may also collect your work contact information (including email address and telephone number), your title or role and details about such business. Websites intended for businesses may also provide the ability to create an account in order to access certain services and content.

We maintain certain websites for employee recruitment, including announcing job opportunities and allowing submission of applications online. If you use such websites you will be asked to create an account to manage the application process and, if you elect, to set up job alerts. You will also be asked to provide contact information, as well as other information relevant to your application, such as a resume or curriculum vitae.

Providing personal information to us is purely optional. However, if you refuse to provide details that are essential (e.g., as may be identified in a registration form or for the purposes of completing a requested transaction), it would be impossible to use some of the features and functions of the website or mobile applications and/or to benefit from our services or promotions (for instance, by not being able to participate in a sweepstakes or contest or not being able to purchase products online) or participate in certain games or other online experiences.

Information collected automatically
We, as well as agencies, advertisers and/or service providers, may place cookies, beacons or other tracking technologies in your browser to automatically collect general non-personal and other information when you visit one of our websites. Online identifiers, like your IP addresses and device IDs, which in some jurisdictions may be considered personal information, may also be collected through the use of automated technology when you visit on of our websites or use our mobile applications – see more regarding the collection of IP addresses and device IDs and the ability to associate website browsing or mobile application usage habits with your individual personal computer or other device in this section below.

In cases when you are on the website of one of our promotional or advertising partners, our cookies or beacons may be placed on your computer via COOLA content that you may be viewing (e.g., a product promotion or advertisement).

Information collected by cookies, beacons or other automated technology may be used by us or our promotional or advertising partners to deliver targeted advertising to you. The practice of displaying advertisements on the websites of unrelated companies is called targeted advertising. 

The type of information that may be collected automatically includes:

internet browser type
  • computer or device type
  • IP address**  **NOTE: An IP address is a number that is assigned to your computer by your Internet Service Provider (ISP) so you can access the internet. Some ISPs assign a new IP address every time you access the internet while other ISPs assign you the same number every time you access the internet. In instances when you are assigned the same IP address, it is possible for information about your browsing habits to be associated with your individual personal computer.
  • device ID**  **NOTE: A device ID is a unique number associated with your device. As a result it is possible for information about your use of mobile applications to be associated with your individual device.
  • operating system
  • browsing behavior, like referring website information, webpages visited, content viewed or downloaded, time spent on the site and links clicked
  • purchasing behavior, including items placed in shopping carts and items abandoned
  • date and time of visits
  • geographic location, such as country, city and zip (or postal) code


This information helps us provide a better website experience by analyzing the performance of our websites, diagnosing problems with our servers, evaluating site navigation and better understanding the demographics of our site visitors so we can provide more relevant content, functionality and offers.

COOLA also makes available mobile applications for use on your phone or other mobile devices, including for the purposes of participating in promotions, games and other online experiences, connecting to “Internet of Things” or “smart” devices, or otherwise using services we make available to you. In order to use some of the features and functions we may use technologies that automatically collect information from your device when you use the mobile applications, including your mobile device type, information about your device’s operating system, how you use the mobile application or device, and your general geographic location.

Information shared with us by other sources
We may receive information about you from other sources such as online retailers, public databases, data aggregators or resllers, or companies/websites where you have consented to have your information shared with other companies. For example, if you are on the website of a TV network viewing content from a TV show, you may have an opportunity to sign-up to receive periodic communication/news about the TV show. While you are registering, the TV network also may ask you if you would like to have your information shared with the TV network’s partners. If you consent to do so and COOLA is one of the TV network partners then we may receive some of your information.

We may also receive information about you from social networking sites if you or other users (e.g., your “friends”) give us access to your profiles, comments, or “connections”, if you “like” us, if you enage with our advertising content on these plarforms, or if you choose to participate in a COOLA sponsored page or program residing in a social networking site (e.g., COOLA’s Facebook page). The type of information that we may receive includes comments you have posted or shared, interests, location, direct messages you send to us, and if you took an action within or linking from our advertising content. You should review the privacy policies and applicable terms of the social networking sites and adjust your settings as appropriate.

Our websites may also have “plugins” and other website features from other companies, such as the Facebook “Like” button and Facebook Conversations and other features which allow for login or other website functionality or interactions with social networking sites. These “plugins” and features, including their operation and use, and the information you provide to those other companies as part of their use, are governed by their privacy policies and practices. Please be aware that we do not control and are not responsible for the privacy policies or practices of such parties. You should review the privacy notices and applicable terms before deciding whether to use “plugins” or other website features from other companies.

We also use the services of companies who administer rewards and other incentive programs that enable the delivery of customizable and real-time content and offers to participants in their programs, including coupons and rebates. Such companies collect and share information about your purchasing habits. In some cases, this may include precise geographical location information from your phone or other mobile device in order to deliver relevant real-time content and offers to you. You should review the privacy policies and applicable terms applicable to such programs before agreeing to participate.

HOW WE USE INFORMATION

We may use information for various purposes to:

  • respond to your questions and requests,
  • provide you with information about our company, products, services, promotions and other special offers, including through the delivery of targeted advertising,
  • review ad performance, delivery verification and measurement,
  • personalize your website experience through tailored content, ads and offers,
  • help you locate stores near you that sell our products,
  • communicate with you about your account and other matters, and in our discretion, changes to any COOLA policy that may affect you,
  • conduct research and analysis related to, and manage and improve, our websites, mobile applications, products, services, advertising, ecommerce product listings, promotions and sales, and understand how you interact with us through social media platforms, including, for example, to make our websites and mobile applications easier to use with better content by understanding how people use our websites, mobile applications, products and services and engage with us using social media and advertising,
  • process transactions and ship products to you,
  • manage online communities for the sharing and exchange of reviews, comments, feedback, ideas, and other user generated content,
  • administer programs and promotions for which you sign up, including sweepstakes and contests, and mobile applications for games and other online experiences,
  • implement other activities disclosed at the time you provide your information,
  • implement social networking features you have activated, and/or
  • combine all the information we collect or receive about you for any of the foregoing purposes.

To the extent that you provide us with financial information in connection with shopping or commercial services, we will use the financial information to process orders and bill you for products and/or services. By submitting your account or credit or debit card number and related personal information, you are authorizing our store to give that information to our service providers and the merchant and credit card company for order confirmation and fulfillment, identity verification and managing risk and fraud.

WHEN WE SHARE PERSONAL INFORMATION

We will not sell or rent your personal information to other companies, as such terms are generally understood. Periodically, we may share your personal information with our subsidiaries, affiliates, business partners and vendors who provide services to us, such as in the circumstances below. This includes sharing your personal information with providers of advertising services to engage in targeted advertising. Such activities may be considered a “sale” under certain laws and require disclosure. We may also share aggregated, de-identified and/or anonymized information with our business partners for their own business purposes.

Your consent to have your personal information shared
We share information with your consent, including when you request or direct such sharing. For example, while on our websites or when you use our mobile applications, you may have the opportunity to opt-in to receive information and/or marketing offers from another company. By opting-in you consent to the sharing of your information with another company. If you consent to have your information shared, your information will be disclosed to the other company, and the information you disclose will be subject to the privacy policy and business practices of that other company.

COOLA subsidiaries, affiliates and business partners
We may share your information with subsidiaries and affiliates of People Against Dirty Holdings Limited, or with our partners, advertisers or other companies primarily for business and operational purposes, including joint promotional activities with such other companies.

Vendors providing services on our behalf
We share your information with vendors that provide services to us, including to help us fullfil your requests, make various features, services and materials available through our websites and mobile applications, respond to your inquiries, deliver more relevant advertising to you and carry out the other purposes described in the section above on “How we use information”. The unrelated companies to which we may provide this information may include providers of advertising services (including website tracking services,advertising exchanges and inventory management services, and data management and analytics services), commercial partners, sponsors, licensees, researchers and other similar parties. We may also use your information, such as online identifiers that do not personally identify you (for example, through hashing), to develop general audience segments for delivering targeted advertising on social media platforms and third party sites. More specifically, we share personal information with third parties that create customer segments based on insights from our websites, other unrelated websites, and other sources such as social networks, and deliver advertising to such segments.

We may also share information that has been aggregated, de-identified and/or anonymized with other companies that provide services to us, including for analytics and research purposes. For example, we may share aggregated customer information, such as demographics, in a manner that does not personally identify such customers to help us identify meaningful similarities to reach new customers. With the help of such companies, we are able to send marketing materials and advertisements to those potential customers.

Legal proceedings and other special circumstances
We may share your information to comply with a legal obligation such as at the request of governmental authorities conducting an investigation; to verify or enforce our websites’ terms of use or other applicable policies; or to protect the rights, property, safety or security of visitors to our websites, the public or other parties. We may also disclose your information as part of a reorganization or sale of one of our business units, divisions or brands to another company.

HOW WE SAFEGUARD INFORMATION

We take information security seriously and use industry-accepted security measures to help protect your personal information from unauthorized access, alteration, loss, or misuse. For example, we store personal information on computer systems with limited access and these systems are located in controlled facilities. When we transmit very confidential information (e.g., a credit card number) over the internet, we protect it through the use of data encryption methods.

Please remember not to ever send your credit card numbers, social security, or any personal passwords through unsecured email. Also remember not to ever share your passwords, never leave your computer unattended, and always log-out when you are done using it.

MORE ON COOKIES, BEACONS, AND HOW TO STOP AUTOMATED COLLECTION OF INFORMATION

COOLA uses automated technology to collect general non-personal and other information. Automated collection of information occurs mainly through the use of two technologies: cookies and web beacons.

More on “Cookies”
What is a cookie — A cookie is a small file that a website you are visiting places in your computer through your internet browser. Cookies have the ability to identify your computer and store information like web pages visited, advertisements viewed, frequency, and type of browser used. Cookies may also be used on mobile devices.

Cookies are usually managed through your internet browser.

If the website you are visiting provides free content then it is likely that you will also see advertisements of other websites/companies. If so, the website you are visiting and the companies that sponsor the advertisements may place their own cookies in your computer. Displaying on-line advertisements on unrelated websites is primarily accomplished through a practice called targeted advertising (more on on-line advertising on unrelated websites (targeted advertising) and how to stop its delivery later in this Privacy Notice).

How are cookies used — Cookies are normally used to help with security (e.g., time you out of a secured browsing session after a certain period of inactivity), site navigation (e.g., remember your preferences so that you don’t need to reenter information like language preference), improve your browsing experience (e.g., deliver content, advertisements, or offers that are consistent with your browsing habits), and to engage in targeted advertising.

Cookies can remain in your computer for the duration of a browsing session or for a predetermined period of time. Cookies that remain in your computer for the duration of a browsing session are called “session” cookies (e.g., the contents of an online “shopping basket” will disappear at the end of your browsing session). Cookies that remain in your computer for a predetermined period of time are called “persistent” cookies (e.g., selecting English in a website that offers content in multiple languages so that the content is displayed in English when you return to the website even weeks or months later).

Accepting, disabling or deleting cookies – You may be able to set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it, or to block cookies altogether. To do so, please refer to your browser’s help menu.

Most browsers also allow you to erase cookies already stored. Please be aware that deleting cookies will likely have a negative effect on the performance of the websites you visit and, consequently, you may not be able to see content or use applications offered through the websites.

To delete cookies that have been installed in your computer, please refer to your browser’s help menu. Below are links to some of the most popular internet browsers where you can find additional information on managing cookies:

 


In addition, some of our websites and mobile applications may contain an icon or link (such as “AdChoices”, “Cookie Consent” or “Do Not Sell My Personal Information”), typically on the footer of the page, or other button that enables users to learn more about the companies that use cookies on our websites and their choices with respect to such cookies and how to disable them.

We use service providers to help us manage your privacy preferences, provide notice regarding our use of cookies and, if applicable, obtain consent for such use as required by applicable law. Implementing your choice to limit targeted advertising, such as by opting out of cookies placed in our website, may itself require placing a cookie in your computer. As a result, if you delete those cookies you will need to opt out again to limit targeted advertising.

You can also learn more about cookies at:

https://www.allaboutcookies.org/

https://www.consumer.ftc.gov/topics/online-security

https://youradchoices.com/ or http://www.youronlinechoices.com/

More on web “beacons”
What is a web beacon — Web beacons are small pieces of computer code placed in transparent graphic images displayed in websites you may be viewing or emails you may receive. Web beacons are not noticeable since they are usually placed within a very small portion of an image being observed. Web beacons are also known as pixel tags, clear GIFs, and web bugs.

How are web beacons used — Web beacons are normally used to monitor website traffic. Web beacons can also be used with cookies to gain an understanding of how website users navigate and process the content contained in websites. For example, a company owning a network of websites may use web beacons to count and recognize users travelling through its multiple websites. Being able to recognize users allows the website owner to personalize users’ visits and make them more user-friendly.

How to delete web beacons — To delete web beacons, you will need to delete cookies from your browser (see the section above on “How to delete cookies”).

You can learn more about web beacons at:

http://www.allaboutcookies.org/faqs/beacons.html

MORE ON ONLINE ADVERTISING ON UNRELATED WEBSITES (TARGETED ADVERTISING) AND HOW TO STOP ITS DELIVERY

We and our promotional and advertising partners use information collected by cookies or beacons to engage in targeted advertising.

What is targeted advertising — Targeted advertising is the most common practice of delivering advertisements in the websites of unrelated companies. For example, when you visit the website of a sports’ network, you may see advertisements from unrelated sporting equipment companies.

How does targeted advertising work — Targeted advertising utilizes technologies such as cookies and web beacons to assemble usage information from websites you’ve visited. This information is utilized to try to understand your potential interests and match them with potential suppliers of related product and services. If one of these potential suppliers has contracted with a website that you are visiting to deliver its corresponding advertisement, your internet browser will assemble appropriate ad information and deliver it to you while you are browsing on the unrelated website.

How to limit targeted advertising – Your jurisdiction may have adopted laws or an industry self-regulatory framework that enables you to limit or stop targeted advertising. An increasing number of advertisers have embedded an icon (such as an “AdChoices” icon) in or near their ads to indicate compliance with applicable self-regulatory frameworks. By selecting this icon, you may be redirected to a website that should allow you to limit or stop the delivery of advertisements to your computer. However, you should know that such icons (including the “AdChoices” icon) can only help you limit advertisements from companies that have signed-up to use the applicable icon to manage targeted advertising.

If and to the extent an advertisement does not include the applicable icons, you should visit the website where you are receiving the ad or the actual advertiser’s website to view its privacy policy, which may provide information on how to stop receiving their advertisements.

You can learn more about targeted advertising and how to limit related advertisements at:

http://www.aboutads.info/

Please note that COOLA has no control over this advertising network or the companies that belong to the network.

What is Do Not Track – Do Not Track is a privacy preference that you can set in your web browser that is intended to allow you to control the tracking of your online activities across websites.

How we respond to Do Not Track Signals – COOLA websites do not currently honor Do Not Track settings that are enabled from your web browser.

WHAT LAWS GOVERN THE OPERATION OF COOLA’S WEBSITES AND INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Our websites are governed and operated in accordance with the laws of the United States, while designed to be compatible with the laws of the countries in which we operate.

Because we are an international business, the computer servers that support our websites and process your personal information may be located outside the country from which you accessed our websites and your information was collected. Consequently, your personal information may be processed, maintained and/or transferred abroad in and to another country that does not have the same privacy laws as your country of residence. If so, we will handle your personal information in accordance with this Privacy Notice.

Be aware that by using our websites or providing us with information, you are: (a) agreeing that our websites are subject to the laws of the United States, and (b) consenting to the collection, processing, maintenance and transfer of such information in and to the United States and/or other countries.

Note that the laws of certain countries and states may require that we set out specific information in this Privacy Notice as it relates to such countries or states. See below to read that information for those jurisdictions. Such location-specific information is part of this Privacy Notice and applies to information collected by COOLA only if and to the extent the laws of the applicable jurisdiction require such application.

HOW WE WILL INFORM YOU OF CHANGES TO THIS PRIVACY NOTICE

Please note that we reserve the right to change this Privacy Notice, at any time. To the extent that we make material changes, we will seek to provide you with reasonable notice of the changes. Changes will be effective immediately upon the posting of the revised Privacy Notice on our corresponding website. Please check back from time to time.

HOW YOU CAN COMMUNICATE WITH US ABOUT THIS PRIVACY NOTICE OR YOUR PERSONAL INFORMATION

If you have any questions or concerns about this Privacy Notice or your personal information, please let us know by contacting us at the below email and mail addresses and your request will be handled by our customer service center in the United Kingdom:

By email: hello@coola.com
By mail: COOLA
6023 Innovation Way
St 110
Carlsbad, CA 92009

By phone or web form: Click here to visit our “Contact Us” page and find out if there is an option enabled to contact us by phone or web form in your location.

Note that the applicable laws of certain jurisdictions may grant you rights, including, if applicable in your jurisdiction, the right to request us:

  • to provide you with information about the categories and specific pieces of personal information we have collected about you, our use and processing of such personal information, including the purpose of our use and processing, information on the source from which we obtained your personal information, how we use and process your personal information and the categories of other parties with whom we share or disclose your personal information, and to obtain a copy of the personal information we have about you;
  • to correct or update your personal information;
  • not to contact you in the future;
  • to delete your personal information;
  • to stop the use and processing, including the sharing or disclosing, of your personal information; and
  • to notify any change or requirement of deletion to another party with whom we shared or disclosed your personal information.

 


Not all such rights may be applicable in your jurisdiction; COOLA will comply with applicable laws. You should review the “Country and State Specific Information” section below.

Prior to responding to a request we may need to ask for additional information to verify that the request comes from the individual to whom the personal information pertains or an authorized representative. We will seek to minimize the information we collect for purposes of verifying such identity and authorization, but the level of verification needed will depend on various factors, including the type of request and the sensitivity of the personal information. In some cases, we may need to request a government-issued identification for identity verification. Any personal information we collect in connection with such verification will be used only for the purposes of responding to the request.

Please be aware that in accordance with our routine record keeping, at our discretion and from time-to-time, we may delete records that contain information.

UNITED KINGDOM –

GDPR and DPA
PLEASE NOTE THAT OUR UNITED KINGDOM WEBSITES ARE NOT INTENDED FOR CHILDREN UNDER THE AGE OF 13 OR THE UNITED KINGDOM’S MINIMUM DIGITAL AGE OF CONSENT. IF YOU ARE UNDER THE AGE OF 13 OR THE DIGITAL AGE OF CONSENT IN YOUR COUNTRY, PLEASE DO NOT PROVIDE INFORMATION OF ANY KIND. WE DO NOT COLLECT PERSONAL INFORMATION FROM ANY PERSON WE ACTUALLY KNOW IS AN INDIVIDUAL UNDER THE APPLICABLE AGE OF CONSENT FOR DATA COLLECTION AND PROCESSING ACTIVITIES.

COOLA is subject to the European Union General Data Protection Regulation (GDPR), a data protection law applicable to the European Union (EU) and European Economic Area (EEA), effective May 25, 2018, and the United Kingdom’s Data Protection Act 2018 (DPA). GDPR is also applicable to the United Kingdom. Your rights under the GDPR and DPA, as applicable, include those mentioned previously in this Privacy Notice, as well as the right, under certain conditions as described in the GDPR and DPA, as applicable:

  • to have personal data transmitted to you or another controller in a commonly used machine readable format (right to data portability);
  • to require COOLA erase personal data in certain circumstances, and where the data has been made public to take reasonable steps to inform controllers that are processing the data that you have requested its erasure of any links to, copies or replication of it (right to erasure);
  • to more information about COOLA’s processing through an access request and to provide the information in a commonly used electronic form (right of access);
  • to obtain restriction of processing of personal data (right to restrict processing);
  • where processing is based upon consent, the right to withdraw such consent;
  • to object, on the grounds relating to your particular situation, to processing of your personal data (right to object);
  • to obtain the rectification of inaccurate personal data (right to rectification); and
  • to lodge a complaint with the relevant Data Protection Authority. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 


If you have any requests for COOLA under GDPR or DPA, send a request using this form or contact us at:

By email: hello@coola.com
By mail: COOLA 
6023 Innovation Way
St 110
Carlsbad, CA 92009


COOLA processes personal information primarily based upon consent, but may also process personal information where legally obligated to do so, or on the basis of legitimate interests. For example, COOLA  may process personal information you provide to us on the basis of a legitimate interest as necessary for the purposes of (1) responding to your questions and requests, such as when we provide customer service or address and resolve claims or disputes that may arise, or (2) managing and improving our websites, such as when we identify your location and language preferences for content delivery, when we monitor comments and reviews on our websites to prevent terms of use violations, or when we enable the operation of privacy compliance notices and consent and opt-out functions for cookies. Other legitimate interests may be applicable to our processing of your data as described in this Privacy Notice.

COOLA processes personal information only for the legitimate purposes described in this Privacy Notice and, if applicable, only such other purposes as are compatible with such purposes, and not for additional incompatible purposes. In addition, COOLA will not maintain your personal information longer than is necessary, and will only do so in accordance with applicable GDPR and DPArequirements. COOLA  considers relevant criteria for determining the period during which COOLA will maintain your personal information, for example, the nature and categories of the personal information, the purpose for which the personal information is stored (including the need for further processing in accordance with the legitimate purpose for which it was collected), the security measures that can be applied to protect such personal information and safeguards that can be implemented to reduce any risks, and the balance of any potential impact on the data subject (both positive and negative).

As we described previously in this Privacy Notice, because we are an international business, your personal information may be transferred abroad for processing, including in the United States. You can read below for more information on how COOLA complies with the applicable GDPR and DPA requirements relating to such transfers to the United States.

Transfer of personal information outside the EEA
We may transfer your personal information outside the European Economic Area (“EEA”). We try to limit this where possible but it may be necessary where, for example, one of our suppliers has a data centre outside the EEA. Whenever we transfer your personal information outside of the EEA, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and that the appropriate legal safeguards are in place prior to the transfer, for example particularly ensuring that any contracts between us and the recipient of the information have EU-approved standard data protection clauses, or are recognised as having adequate protection for the transfer of personal data.

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