How This Policy Applies
This Policy describes the information we collect from you, how we use that information and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.
What We Collect and Receive
In order for you to create an account on COTL and use our Services, we need to collect and process certain information. Depending on your use of the Services, that may include:
- Information you provide by completing forms on COTL – your name, email and postal addresses, telephone number, country of residence, login, and password details. We may ask for this information if you register as a user of the Services, subscribe to our newsletters, upload or submit content through COTL, or if you contact us;
- Information you provide for identity verification purposes when launching or backing a project, including your legal name, business name and Tax ID for business entities, and date of birth. In some cases, our payment processor will request that you provide a secure upload of an identity document (such as your passport, driver’s license or other government-issued ID) to COTL;
- Details of any requests or transactions you make through the Services. COTL partners with other companies for payment processing, and the payment information you submit is collected and used by them in accordance with their privacy policies. COTL doesn’t store your payment information apart from the last four digits of your credit card or bank account (as applicable), expiration date, and country, which we require for tax, government regulatory, and security purposes;
- Information about your activity on and interaction with COTL, including use of our mobile apps (such as your IP address, the type of device or browser you use, and your actions on the Site);
- Information about the ways people visit and interact with our Site, in the form of traffic analytics. Note that we do NOT utilize Google Analytics.
- Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem);
- Information that you submit on or to COTL in the form of comments, contributions to discussions, or messages to other users.
You may decline to provide us with your information. However, this will limit your ability to register for an account or use our Services. You may review, change or remove your information through your account settings.
How We Use This Information
We use the information we collect for the following purposes:
- To keep your account secure and protect our Services (including to verify the identities of customers and prevent fraud and abuse);
- To enable us to provide you with our Services, and to improve and promote our Services;
- To create and administer your account, contact you, and customize your experience on COTL; and
- To track and analyse use of the Services so that we can improve how COTL is performing and provide users with the best experience possible.
European Union Users
Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:
- Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver the Services, enable creators to establish and display their projects, and enable backers to find and make pledges to them.
- Legal compliance: Sometimes the law says we need to collect and use your data. For example, tax laws require us to retain records of pledges and payments made through our Services.
- Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your data and we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.
For example, we use identity, device, and location information to prevent fraud and abuse and to keep the Services secure. We may also send you promotional communications about our Services, subject to your right to control whether we do so.
We analyse how users interact with our Site so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our users.
How This Information Is Shared
Information that’s shared publicly
When you create an account, we create a basic profile page for you on COTL. Your username appears with the comments you post and messages you send on COTL and people can click your username to view it. Others will be able to see the following things:
- The account username you select, and the date the account was created;
- Any information you choose to add to your profile (like a picture or about information);
- Comments you’ve posted on COTL; and
- If you have interacted with a post or comment with a vote up or down, a repost, or quote.
You can modify or delete certain information associated with your account (such as your profile image or about information) from your account settings.
Information that isn’t shared publicly
The following data will not be publicly displayed or revealed to other users:
- Any payment information you provide;
- Your password details;
- Your IP address;
- Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem).
Information that’s shared with trusted third-party services
We may share your information with certain trusted third-party services to help us provide, improve, promote, or protect COTL’s Services (like when we partner with payment processors, or use services that help us manage our ads on other sites). When we share data with third-party services that support our delivery of the COTL Services, we require that they use your information only for the purposes we’ve authorised, and that they protect your personal information at least to the same standards we do. We may also share information that’s aggregated and anonymized in a way that it doesn’t directly identify you.
We do reserve the right to disclose personal information when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect COTL’s legal rights, property, or the safety of COTL, its employees, users, or others.
Links to other websites and services
We will retain your information as long as your account is active, as necessary to provide you with the Services or as otherwise set forth in this Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect COTL’s legal rights.
We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations.
Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information. While these rights are not applicable globally, all COTL users can manage their personal information in their account settings.
To modify or delete the personal information you’ve provided to us, please log in and update your profile. You may also delete your account from your account settings page. We may retain certain information as required by law or as necessary for our legitimate business purposes.
Email and Mobile Notifications
We want to communicate with you only if you want to hear from us. We try to keep emails to a minimum and give you the ability to opt in to any marketing communications we send.
We will send you email relating to your transactions on COTL. You may also elect to receive certain marketing email communications, in accordance with your preferences, and from which you may opt out at any time by adjusting your notification settings.
We’ll also send you service-related announcements when it’s necessary to do so.
We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so COTL cannot guarantee its absolute security. Your account information is protected by a password, which you should choose carefully and keep secure. We encourage all users to enable two-factor authentication in account settings to further protect their account.
Data Protection Authority
Subject to applicable law, if you are a citizen or resident of the European Economic Area, you also have the right to (i) object to COTL’s use of your personal information and (ii) lodge a complaint with your local data protection authority or the United Kingdom Information Commissioner’s Office.
United Kingdom Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 5AF, United Kingdom
Telephone: +0303 123 1113
Fax: 01625 524510
People under 18 (or the legal age in your jurisdiction) are not permitted to use COTL on their own. COTL does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services.If you believe that a child has provided us with personal information, please contact us at [email protected] . If we become aware that a child under age 13 has provided us with personally identifiable information, we will delete it.