At Cobalt Software we respect and believe is it important to protect the privacy of our clients and employees. There are various ways that you might interact with Cobalt Software, and the information you provide when doing so allows us to improve our services. A summary of the Privacy Notice is below, and we encourage you to review the entirety of the Privacy Notice following this summary. You can opt-out of certain disclosures by following our opt-out procedures set forth at the end of this Privacy Notice.
Cobalt Software (“our”, “us” or “we”) takes user privacy very seriously. We recognize that your privacy is a high priority, and we are committed to protecting it to the reasonable extent of our ability. This Privacy Notice (this “Privacy Notice”) provides an overview of what information we may collect from you, and how we may use it. We pledge that we will take reasonable steps to ensure that your personal information and browsing Information will only be used in ways that are in compliance with this Privacy Notice and applicable privacy-related laws. This Privacy Notice is in effect for any personal information and browsing Information collected and/or owned by us, including, but not limited to, collection through any our website (and all of the subdomains located thereon) and any online feature, service and/or program offered by us (collectively, the “Website”).
Notwithstanding the foregoing, this Privacy Notice is not applicable to any other web pages, mobile applications, social media sites, email lists, generic information and Personal Information collected and/or owned by any entity other than Cobalt Software.
By submitting information to us and using our website, you are accepting and agreeing to the terms of this Privacy Notice.
• What information we collect, and why we collect it;
• How we use that information;
• How we protect that information;
• How you can control your information, including accessing, updating and deleting what we store; and
• How we share information collected.
• Information We Collect
• How We Use Information
• Information from CobaltENGAGE Visits
• Updating Your Information and Opting Out
• Disclosure of Your Personal Data to Third Parties
• Security of Your Personal Data
• Data Retention: How Long We Keep Your Personal Data
• Your Rights
• Responding to Requests
• Links to Third Party Websites and Third-Party Applications
• Employment Opportunity Information
• European Union Users
• Your Consent to this Privacy Notice
• Contacting Us
• Changes to This Policy
Information We Collect
Information Voluntarily Provided
We may collect or record basic personal information which you voluntarily provide through completing forms on our Site, through questions you send to us, or through other means of communication between you and us. The categories of personal information you provide may include:
• First and last name
• Job title and company name
• Family members
• Email address
• Phone number
• Mailing address
• Password to register with us
• Your personal or professional interests
• Any other identifier that permits us to make contact with you.
Information from Site Visits
We collect, store and use information about your visits to the Sites and about your computer, tablet, mobile or other device through which you access the Sites. This includes the following information:
• technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;
• information about your visits and use of the Site, including the full Uniform Resource Locators (URL), click stream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and Site navigation and search terms used.
Information from CobaltENGAGE Visits
CobaltENGAGE App (IOS & Android versions) uses the below Firebase & Gimbal services for Crash Reporting, Cloud Messaging & contactless check-in. Below are the more details of each area.
We use services of Firebase - a business division of Google Inc. for crash reporting and delivering push notifications.
• Crash Reporting: For crash reporting, we use Crashlytics, this services provides us information about crashes and malfunctions in CobaltENGAGE App. This service automatically collects certain information that does not personally identify club member who access or use mobile application that uses this service. The information collected includes, but is not limited to, Crash Stack traces, Crashlytics Installation UUIDs, device details(e.g., phone model, Ram, Memory.) and OS information , timestamp for when the crash occurred, App information(e.g., version, state).
We also collect, Internet Protocol address (IP), Session ID, App version, Operating System version, Information about screens you viewed.
The types of browsing information we collect may obtain non-individualized, generic information about you when you visit the Website. This may include, among other things, the following categories of information (collectively, “Browsing Information”):
• Internet Protocol (or IP) address, or device ID/UDID, protocol and sequence information;
• browser language and type;
• domain name system requests;
• browsing history, such as time spent at a domain, time and date of your visit and number of clicks;
• http headers, application client and server banners;
• operating system and fingerprinting data; and/or
• similar behavioral and usage information.
We also collect personal information from our employees and from job applicants in connection with administration of our human resources programs and functions, including, with respect to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to our facilities and computer networks, employee profiles, employee directories, human resource record keeping, and other employment related purposes. It is our policy to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are: to comply with requests from governmental or regulatory authorities; inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verification's are acceptable; and third parties with which we have contractual agreements to assist in administration of company sponsored benefits. Prospective employers, government agencies, financial institutions, and residential property managers routinely contact us requesting information on a former or current employee’s work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the human resources department or payroll department.
How We Use Information
As a data controller, we will only use your personal information if we have a legal basis for doing so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained below.
Purposes for which we will process the information
Legal Basis for the processing
To provide you with information and materials that you request from us.
It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business. To ensure we offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.
To personalize our services and products and the Sites to you.
It is in our legitimate interests to improve the Site in order to enhance your experience on our Site, to facilitate system administration and better our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To update you on services and products and benefits we offer.
It is in our legitimate interests to market our services and products. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing.
To send you information regarding changes to our policies, other terms and conditions and other administrative information.
It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.
To administer our Sites including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To improve our Sites to ensure that consent is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access the Sites; and
To keep our Sites safe and secure.
For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.
To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.
It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.
It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate.
If you do not wish to provide us with your personal data and processing such data is necessary for the deliverance of membership services with you and to fulfill our member obligations to you, we may not be able to perform our obligations under the client agreement between us. Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us through Cobalt Software contact or as provided in “Contacting Us” below.
Updating Your Information and Opting Out
To review, correct, update, delete, object or otherwise limit our use of your personal information that has been provided to us, or request portability and/or details of your personal information that is held by us, please contact your usual Cobalt Software contact or contact us using the contact information listed below in the “Contacting Us” section and clearly describe your request. You may also determine which personal information is visible to other client via our clients’ only section of our Sites.
If you are a client with us, you can help to ensure that your personal information is accurate and up to date by logging into your account.
You may unsubscribe from marketing communications at any time by clicking the “Unsubscribe” button available at the bottom of any electronic communication we may send to you. You may also unsubscribe from any medium of communication by contacting us using the information set out in the “Contacting Us” section below.
Disclosure of Your Personal Data to Third Parties
We may share your personal information with 3rd party vendors and affiliates as necessary to carry out the purposes for which the information was supplied or collected (i.e. to provide the services and products you have requested from us). Personal information will also be shared with our third-party service providers and business partners who assist with the running of the Sites and our services and products including hosting providers, email service providers and payment processing partners. Our third-party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.
In addition, we may disclose information about you when we believe that such use or disclosure is reasonably necessary to: comply with any legal or regulatory obligation; establish, exercise or defend the rights of Cobalt Software, our staff, clients or others; and protect our rights, property or safety, or the rights, property or safety of our clients, or others.
Security of Your Personal Data
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We use appropriate measures to safeguard personally identifiable information, which measures are appropriate to the type of information maintained and follow applicable laws regarding the safeguarding of any such information under our control. No method of transmission over the Internet, or method of electronic storage, can be 100% secure. Therefore, we cannot guarantee the absolute security of your information. The Internet by its nature is a public forum, and we encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.
Data Retention: How Long We Keep Your Personal Data
We will retain personal information as long as needed to provide services and products to our clients and in accordance with any agreement in place with our members. When you contact us, we may keep a record of your communication to help solve any issues that you might be facing. Your information may be retained for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirement.
You may request from us access to, correction of, blocking of and/or deletion of your personal data in line with applicable data protection law. You may also withdraw your consent for us to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Where your personal data is processed by us with your consent or for the performance of a service by automated means, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format upon request.
Responding to Requests
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one business day. Occasionally it may take us longer than a day if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Also, please note that we may refuse a request for blocking and/or deletion where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims.
We may collect Browsing Information from you as follows:
Web Beacons: The Website may also contain electronic images known as Web Beacons (sometimes referred to as “clear gifs”). Web Beacons collect only limited information that includes a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. We may also carry Web Beacons placed by third-party advertisers. These Web Beacons do not carry any personal information and are only used to track usage of the Website and activities associated with the Website.
Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Website and some of the electronic communications you receive from us. We keep this information for our internal use, and this information is not shared with others.
Use of Collected Information: Information collected by us is used for three main purposes:
• To provide products and services to you or any third-party service provider who is obtaining services on your behalf or in connection with a transaction involving you.
• To improve our products and services that we perform for you or for any third-party service provider.
• To communicate with you and to inform you about our and third parties’ products and services, jointly or independently.
When Information is Disclosed: We might disclose Personal Information and/or Browsing Information when required by law or in the good-faith belief that such disclosure is necessary to: (1) comply with a legal process and applicable laws; (2) enforce this Privacy Notice; (3) respond to claims that any materials, document, image, graphic, logo, design, audio, video or other information provided by you violates the rights of a third party; or (4) protect the rights, property or personal safety of Cobalt Software, its users or the public.
We maintain appropriate technical and organizational measures and safeguards to keep the Personal Information and Browsing Information that is disclosed to us secure. We may provide Personal Information and/or Browsing Information to our affiliates and other businesses or persons for the purposes of (1) processing such information on our behalf, (2) providing legal services to you and on your behalf, and (3) promoting our services and the services of our affiliates and trusted business partners as permitted by applicable privacy law. We require that these parties agree to process such information in compliance with our Privacy Notice or in a similar, industry-standard manner that complies with applicable privacy laws, and we use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures. The use of your information by a trusted business partner may be subject to that party’s own Privacy Notice.
We may share Browsing Information with third parties to demonstrate the usage patterns for Cobalt Software advertisements, content, functionality promotions and to provide us with analytics services in connection with the Web Site.
We also reserve the right to disclose Personal Information and/or Browsing Information to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Web Site, and to protect the rights, property or personal safety of Cobalt Software, our users or others. We reserve the right to transfer your Personal Information, Browsing Information, and any information about or from you, in connection with the merger, sale or other disposition of all or part of our business and/or assets. We cannot make any representations regarding the use or transfer of your Personal Information, Browsing Information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings. We cannot and will not be responsible for any breach of security by any third party or for any actions of any third party that receives any of the information that is disclosed to us.
You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
IP Addresses and Aggregate Information
An Internet Protocol (“IP”) address is associated with your computer’s connection to the internet. We may use your IP address to help diagnose problems with our server, to administer the Site and to maintain contact with you as you navigate through the Site. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Site. Aggregate information is used to measure the visitors’ interest in, and use of, various areas of the Site and the various programs that we administer. We will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, we may undertake statistical and other summary analyses of the visitors’ behaviors and characteristics. Although we may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.
Certain functionality on the Website is specifically designed to permit interactions that you initiate between the Website and third-party websites or services, including third party social networks (“Social Features”). Examples of Social Features include enabling you to transmit content to the Website from your account on a third-party website or service, and to “like” or “share” our content on the Website to other websites or services.
If you choose to use Social Features, information you post or provide access to may be publicly displayed on the Website or by the provider of the Social Feature that you use. Similarly, if you post information on a third party platform that references Cobalt Software (e.g., by using a hashtag associated with us in a tweet or status update), your post may be published on the Website in accordance with the terms of the third party website or service. In addition, both we and the third party may have access to certain information about you and your use of the Website and the third-party site or service. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your “connections” web pages, profile pages, or similar pages on a social networking or other third party website or interactive service.
The information we collect in connection with Social Features is subject to this Privacy Notice. The information collected and stored by the third parties remains subject to those third parties' privacy practices, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third party websites or services.
Links to Third-Party Websites and Third-Party Applications
Our Sites may contain links to third party websites. These third-party websites are operated by companies that are outside of our control, and your activities at those third-party websites will be governed by the policies and practices of those third parties. Cobalt Software does not in any way endorse or make any representations about such third-party websites and applications. As such, Cobalt Software is not responsible for the privacy practices or content of such third-party websites and applications that are subject to their own privacy policies. If you choose to access such links, we encourage you to review all third-party site privacy policies before submitting any of your data.
Employment Opportunity Information
For individuals interested in job opportunities with us, the Website may allow prospective employees to request additional job opportunity information or submit a response to a job opportunity. The Website may be used to collect Personal Information from prospective employees for human resources recruitment purposes. By submitting any of the foregoing information, you consent to its dissemination to, and use by, us and our affiliates. The foregoing also applies to job application inquiries that you may transmit to us other than through the Website.
We do not sell or market our services to children and the Site is not intended for or directed at children under the age of 13 years. As such, our Sites are designed for adult user interaction. We do not intentionally collect personally identifiable information from children under the age of 13. If you believe that we may have collected personal information from someone under the age of 13 (or the applicable age of consent) without proper consent, please let us know using the methods described in this policy. THE WEBSITE ARE NOT INTENDED FOR CHILDREN UNDER 13 WHO ARE UNACCOMPANIED BY HIS OR HER PARENT OR LEGAL GUARDIAN. Parents and legal guardians should be aware that this Privacy Notice will govern our use of Personal Information, but also that information that is voluntarily given by children – or others – in email exchanges, bulletin boards, or the like may be used by other parties to generate unsolicited communications. We encourage all parents to instruct their children in the safe and responsible use of their Personal Information while using the Internet.
European Union Users
The Website are hosted in the United States and are governed by United States law. If you are using the Website from outside the United States, please be aware that your Personal Information and/or Browsing Information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Website, you consent to your Personal Information and Browsing Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.
The European Union’s General Data Protection Regulation (Regulation (EU) 2016/679) gives certain rights to European data subjects in relation to their personal data.
Lawful basis for processing. We will only process your personal data when we have a legal basis to do so. When we do process your personal data, we will do so with your consent or because the processing is necessary: for the performance of legal services for you; to comply with our legal obligations; to pursue our legitimate interests; or to establish or defend a legal claim.
Your rights. If applicable, you may have the following rights under some circumstances:
• You may request information about what personal information we have about you.
• You may request rectification, deletion, and limitation of the processing (blocking) of your personal information as long as this is legally permissible and possible within the framework of an existing contractual relationship.
• You have the right to transfer the personal information that you have provided us on the basis of a consent or a contract (data portability).
• If you have given us consent for personal information processing, you can revoke it at any time in the same way that you have granted it. The revocation of the consent does not affect the legality of the processing done before you revoked your consent.
To exercise your rights, contact us by one of the methods set forth at the end of this Privacy Notice. We will respond to your request within thirty days. We may not be able to accommodate your request in every situation, but if that is the case, we will let you know why. We may charge you an administrative fee for subsequent requests.
Complaints: If you are a data subject in the European Union and you believe that our processing of your personal data infringes applicable law, you may submit a complaint with a supervisory authority. The name and contact details of the Data Protection Authorities in the European Union can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
If we receive formal written requests or complaints, we will follow up with the party making the request or complaint. To the extent permitted by applicable law, where we would not properly address your request, you have the right to lodge a complaint with the competent data protection authority in your locality.
Your Consent to this Privacy Notice
By submitting Personal Information and/or Browsing Information to us, you consent to the collection and use of information by us as specified above or as we otherwise see fit unless you inform us otherwise by means of the procedure identified below. If we decide to change this Privacy Notice, we will make an effort to post those changes on this web page. Each time you provide information to us, or we receive information from you, following any amendment of this Privacy Notice will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.
Computer Software & Solutions International LLC
6650 Park of Commerce Blvd
Boca Raton, FL 33487
Changes to This Policy
EFFECTIVE AS OF: May 1, 2020