In certain instances, we may act as either a Controller or Processor of Personal Information.
- How We Collect and Use Personal Information
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with COTX and the requirements of applicable law.
We endeavor to collect only that information that is necessary for a business purpose and relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Type of Personal Information We Collect
COTX collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services, Products, or engage in certain activities, such as registering for an account with COTX, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Account Creation. To purchase Products and to obtain other Services offered on the Sites, you may have to register an account by completing a questionnaire online. Through the completion of the questionnaire we typically collect the following information: (i) full name; (ii) address; (iii) email address; (iv) credit card information; (v) password; and (vi) nickname or online identifier. This Personal Information is required and if you choose not to submit the requested information, we may not be able to provide you with the Products or Services offered on the Sites.
- You may access the Sites without being a registered user. However, you may not be able to access certain areas or purchase our Products or Services online if you are not a registered online user.
- Product Registration. To register your Product, we may request the following information: (i) name; (ii) email address; (iii) physical address, (iv) phone number, (v) product serial number, and (vi) purchase date.
- Partner Applications. To become a COTX Partner, which includes a COTX reseller, distributor, or channel partner, or to engage in another similar relationship with COTX, you must complete an application. By virtue of our application, we may collect Personal Information such as your (i) name, (ii) title and function, (iii) company name, (iv) physical address, (v) phone number, and (vi) email address. The provision of the requested information is required for users who want to become COTX Partners.
- Public Forums. Our Site offers publicly accessible blogs, forums, and user reviews. You should be aware that any information you provide in these public forums may be read, collected, and used by others who access them. To request the removal of your Personal Information from these areas, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
- Online Surveys. If you desire, you may participate in COTX’s online surveys. If you choose to participate, we may collect information about the environment you work in, telephone habits, and demographic information, for example. These surveys are developed in order for us to understand what types of Products are most effective for our customers and to find the best ways to advertise to reach new customers. Your participation in our online surveys is entirely voluntary. COTX may provide gifts to those individuals who participate in surveys and will request a mailing address to ship the gift. In addition to sending you a gift, COTX may use your mailing address or other Personal Information for the purposes set out in the survey, for marketing purposes, to improve our product, or for other legitimate business purposes. You will be given the option to opt-in to receive further emails from COTX, including but not limited to marketing emails, advertisements, newsletters, and bulletins.
- Online Support. When you choose to use the online chat tool for support, the following information may be gathered through the creation of an account or use of an existing account: email address, password, name, company name, physical address, phone number, and Device information including Product model serial number, and manufacturer. The shared information, with the exception of the password, is viewable to the support person handling the chat. You will be given the option to opt-in to receive further emails from COTX, including but not limited to, marketing emails, advertisements, newsletters, and bulletins.
- Staying in Touch. COTX may communicate with you via physical mailings, emails, phone calls, and SMS messages in accordance with your communication preferences.
- Data We Collect Automatically. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet Protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, mobile applications actually used to interact with COTX, and other Device identifiers that are automatically assigned to your computer or Device when you access the Internet, browser type and language, geolocation information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, search activity, information about the links you click and pages you view within the Services, and other actions taken through the use of the Services such as preferences.
- Information from Other Sources. We may collect or receive information about you from other sources, including through Third-Party services and organizations, including Third-Party Partners, to supplement information provided by you. This supplemental information allows us to verify information that you have provided to COTX and to enhance our ability to provide you with information about our business, Products, and Services. In short, we will collect these types of data, personal information, business information, geographic location data, network inference information.
3.2 How COTX Uses Your Personal Information/ Business Purpose
We may use the Personal Information we collect for some or all of the following business purposes:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient uses, provided the Personal Information is not disclosed to another Third-Party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Performing Services, including maintaining or servicing accounts, providing customer Service, Processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing Services, providing analytic Services, or providing similar Services.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a Service or Device that is owned, manufactured, manufactured for, or controlled by COTX, and to improve, upgrade, or enhance the Service or Device that is owned, manufactured, manufactured for, or controlled by COTX.
3.3 Legal Basis for Processing Personal Information
We may collect information from you in the following ways: (i) with your consent; (ii) in order to perform our contractual obligations with you; (iii) where Processing of the information is within our legitimate business interests and such business interest is not overridden by your data protection interests or fundamental rights and freedoms; or (iv) in order to perform our legal obligations or to protect your vital interests or the vital interests of another. If legally permissible, we will inform you that we are collecting your Personal Information and whether the collection of the information is mandatory or not, including the possible consequences if you do not provide the information requested (e.g., our inability to perform certain requests).
If you have questions about or need further information concerning the basis on which we collect and use your Personal Information, please contact us at email@example.com.
3.4 Opting-Out and Product White Paper Information
Even if you have opted-in to sharing your Personal Information, you may opt-out at any time. To view the categories of Personal Information collected, the categories of sources from where Personal Information is collected, the business purpose for collecting the information, or the categories of Personal Information disclosed to Service Providers please reach COTX by email firstname.lastname@example.org.
3.5 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Please note this does not opt you out of being served untargeted ads.
Our Third-Party Partners may also use other tracking technologies, such as clear GIFs (a.k.a. web beacons/web bugs), that help us better manage content on our Sites by informing us what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users.
We also use clear GIFs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
We, and our Third-Party Partners, use Local Shared Objects (Flash cookies) or Local Storage (HTML 5), to store content information and preferences. Various browsers may offer their own management tools for removing HTML 5.
Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Sites and Services and to develop website content. Our uses of such Technologies fall into the following general categories and meet a legitimate business purpose:
Advertising or Targeting Related. We may use first-party or Third-Party Partner cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on Third-Party Partner websites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browsers or Devices permit.
3.6 Third-Party Websites, Social Media Platforms, Software Development Kits
The Sites may contain links to other websites and other websites may reference or link to our Sites or other Services. These other domains and websites are not controlled by us, and COTX does not endorse or make any representations about Third-Party or Third-Party Partner websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
COTX’s Services may include publicly accessible blogs, community forums, or private messaging features. The Sites and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your Device when using our Sites or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform, or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.
3.7 Third-Party Partner Payment Processing
When you make purchases through the Services, we Process your payments through Third-Party Partner applications. The Third-Party Partner application may collect certain financial information from you to Process a payment on behalf of COTX, including but not limited to, your name, email address, address, and other billing information.
- Onward Transfer – COTX May Disclose Your Information
4.1 Information We Share
- Compliance with Law. We may disclose your data to any competent law enforcement body, regulatory, government agency, court or other Third-Party where we believe disclosure is necessary, for example, (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
4.2 International Data Transfers
You agree that all Personal Information collected by COTX may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, Australia, Singapore, or China, as well as the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our Service Providers, our group companies, and partners that may operate around the world. All sensitive user information will be encrypted during storage, transmission, and sharing （TLS, SSL, HTTPS, AES256, RSA, etc.). We follow the principle of minimizing information sharing, sharing only with the fewest people who need to know this type of information.
We do not trade, rent, or sell your Personal Information. Although we may share your information with others, such as Agents, Service Providers, or Third-Party Partners, we only disclose the minimum amount of Personal Information necessary.
- Opt-Out (Right to Object to Processing)
You have the right to object to and opt-out of certain uses and disclosures of your Personal Information. Where you have consented to COTX’s Processing of your Personal Information you may withdraw that consent at any time and opt-out to further Processing by contacting email@example.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites, Services, and/or information from the advertisements on Third-Party websites for non-interest-based advertising purposes, such as determining the effectiveness of the advertisements, or use your Personal Information for legitimate business purposes including fulfillment of billing or contractual obligations, as well as legal requirements.
If the user refuses COTX to collect personal information, COTX will not provide users with products and services. The services that COTX has already offered to users may also be terminated immediately. COTX will not compensate users for losses, and COTX will not refund the fees that have been collected.
5.2 Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will Process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding Products or Services you have requested or used.
5.3 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.4 COOKIES AND INTEREST-BASED ADVERTISING
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note cookie-based opt-outs are not effective on mobile applications. However, on many mobile Devices, application users may opt-out of certain mobile ads via their Device settings.
To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each Device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile Device. You must separately opt-out on each Device.
- Data Retention
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so. For example, we will retain your information for as long as your account is active or as needed to provide you Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us at firstname.lastname@example.org.
Please note that if you ask us to delete your Personal Information we will endeavor to comply with your request in compliance with applicable law, but we may need to retain and use some information where necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Security of Your Information
We take steps in accordance with good industry practice to protect the information, including Personal Information, we collect from you from unauthorized access, disclosure, alteration, or destruction. We do this by implementing and maintaining reasonable security procedures and practices appropriate to the nature of the Personal Information that we collect and Process about you. The measures we use are intended to provide a level of security appropriate to the risk of Processing your Personal Information.
Your data is accessed by COTX as required to support the Services and Products, and access is limited to only those within the organization with the need to access to support the Services and Products.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, COTX cannot guarantee the security of any information you transmit to us or from our Products or Services.
- International Users
- Children’s Privacy
The Sites and Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and COTX does not knowingly collect Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you learn that we have collected your child’s Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.
- Redress and Accountability
10.1 Questions or Lodging a Complaint
10.2 Worldwide Inquiries and Concerns
If you are concerned that we have breached this policy or the privacy laws in any country around the world, you may lodge a complaint by sending an email to firstname.lastname@example.org.
Please provide us with specific details regarding your complaint together with any supporting evidence.
We will investigate the issue and determine the steps that are needed to resolve your complaint appropriately. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation.
If the user wants to inquire about the personal information collected by COTX, the user needs to send an inquiry request to email@example.com, and COTX will reply to the user via email. California users have the right to request COTX to disclose the types and specific personal information collected within the last 12 months; European and Chinese residents have the right to lodge complaints about information breaches with COTX.
- Other Rights and Important Information
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt-in in certain jurisdictions, and otherwise to opt-out. Where consent of the Individual for the Processing of Personal Information is required by law or contract, COTX will comply with the law or contract.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent,” “Service Provider,” or “Third-Party Partner” means any company, natural or legal person, public authority, agency or body that Processes Personal Information pursuant to the instructions of, and solely for, COTX or to which COTX discloses Personal Information for use on its behalf, and who has a written contract with COTX.
- “Controller” means the business, natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Information; where the purposes and means of such Processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
- “Device” means any physical object that is capable of connecting to the Internet, directly or indirectly, or to another device.
- “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person (“Individual”), household, or device.
- “Process,” “Processing,” or “Processed” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Processor” means a natural or legal person, public authority, agency or other body that processes Personal Information on behalf of a Controller, and pursuant to the Controller’s instructions.
- “Third-Party” or “Third-Parties” means any company, natural or legal person, public authority, agency, or body other than the Individual, COTX, or COTX’s Agents, Service Providers, or Third-Party Partners.
- The term “Data Protection Laws” means any applicable law relating to personal data or the collection, use, storage, disclosure, transfer, or other processing of personal data of or by any government, or any authority, department, or agency thereof, or self-regulatory organization, including, without limitation: (a) the Singapore Personal Data Protection Act (PDPA) of 2021, (b) the Personal Information Protection Law of the People's Republic of China 2021, (c) the California Consumer Privacy Act of 2018, (d) the California Privacy Rights Act of 2020, (e)the United Kingdom’s Data Protection Act 2018 as amended by the UK-GDPR, (f) the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), any implementing acts of the foregoing in the applicable jurisdiction, each as may be amended, supplemented or superseded.