Last updated on: June 13, 2018
We at Cocycles Ltd. ("Cocycles", "we", "our" or "us") care about your privacy! This is why we have adapted our data collection and privacy policies to make it clear and coherent to our devoted community. We only collect your personal identifiable data where you provide us with your express consent, or where it is required for us to provide our services (the "Services") or otherwise improve the browsing experience of our website (the "Website") and to better improve our services. Also, we do not sell your personal information to third parties. Please take the time to read our Privacy Notice to better understand how we collect and use your personal data. Naturally, we will not collect or otherwise use your personal data in any manner contradicting this Privacy Notice. You are not legally required to provide us with any personal data, but without it we will not be able to provide you with the full range or with the best experience of using the services offered on our Website.
The means through which we collect your information differs on the basis of the purpose of your visit to our Website. For example, while we automatically collect certain information from all persons browsing our Website, if you decide to use our Services or otherwise subscribe to our electronic newsletter and other promotional notices, we, with your consent, collect data about you.
We collect three main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
Data Collected or Generated from All Users (registered / unregistered):
When someone visits our Website, or otherwise uses the "contact us" option to contact us via email, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services (as detailed in Sections 4 and 6 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 7 below).
Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies installed on such device, and the activity (clicks and other interactions) of users on our Website.
In addition, we may collect Personal Data which you actively provide when participating in any of our online communities, or when you post on our public forums or groups.
We do not use such data merely to learn a person's true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services and browse our Website, and for security and law compliance purposes. The use of such technical and device data also helps us to deliver contextual content; and our users' viewing experience, and to improve the overall user experience and performance of our Services. For more information about our uses, please see Section 4 below.
Data Collected or Received From Registered Users:
In addition to the Personal Data we collect from all users browsing our Website, when you register an account with our Website (including any subsequent login to that account), contact us with inquiries, when you sign-up to receive e-mail updates and newsletters, or registering to receive our Services you may provide us Personal Data voluntarily, such as your name, e-mail address, and your bio description.
Please note that information you elect to post on your profile account under the Website may be publicly available to other users of the Website, or generally visible on public search engines.
Furthermore, some as part of the subscription process to our Services (if you so choose to subscribe to them) you will be required to provide certain billing information. Such information will be collected and processed by the relevant Service Provider that manages our online subscription process (. We will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to your order, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.
We will use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, improving our customer service and support operations, and protecting and securing our users, ourselves and our Services.
Accordingly, we use Personal Data as follows:
We use pseudonymised Personal Data for the following purposes:
To facilitate, operate, and provide our Services and our Website;
To provide our users with customer care, assistance and technical support services; and,
To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties.
We use Personal Data for the following purposes: To contact our users (via e-mail, or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as updates, new features and services, newsletters, etc.);
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
To comply with any applicable laws and regulations.
Cookies, Tracking and Other Uses
Our Website, including our offered Services, and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities. For additional information about the type of cookies we implement and their functions, please visit our Cookies Policy.
Storage and Retention
Cocycles Ltd. is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
While privacy laws may vary between jurisdictions, Cocycles has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
We retain your Personal Data so long as you maintain an active account with us, in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to our record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), please contact us at firstname.lastname@example.org.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
We may share your data (including Personal Data) with certain third parties, including law enforcement agencies, our service providers – but only in accordance with this Notice:
Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers and Business Partners: We may engage selected third party companies and individuals to perform services complementary to our own (hosting services, data analytics services, data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). In general, these Service Providers may have access to your pseudonymised Personal Data Personal Data in connection with said hosting services, and data analytics services. However, for purposes regarding data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, as well as our business, legal, financial and compliance advisors will have access to the applicable Personal Data required for each respective purpose, and such may only be used for such purposes.
Third Party Integrations: The Services allow you integrate with certain third party services, in which case you will be bound by the terms of service and privacy notices of said third parties (e.g., GitHub) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
Protecting Rights and Safety: We may share your Personal Data with others, if we believe in good faith that this will help protect the rights, property or personal safety of Cocycles, any of our users or any members of the general public.
For the removal of doubt, Cocycles may share your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We will provide such notices through any of the contact means available to us (e.g. e-mail), through the Services and/or Website.
If you wish not to receive such promotional communications, you may notify Cocycles at any time by e-mailing us at email@example.com or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 6 above.
Data Subject Rights
If you wish to exercise your rights under applicable law (e.g. the EU GDPR) to access, rectify, erase or port your Personal Data held with Cocycles – please contact us at firstname.lastname@example.org, however please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request.
Our services are not designed to attract children under the age of 16. We do not knowingly or intentionally collect Personal Data from children and do not wish to do so. If we learn that a child is browsing the Website or otherwise uses the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us at email@example.com.
If you have any questions about this Policy, please contact us at firstname.lastname@example.org
Updates and amendments: We may update and amend this Privacy Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or via the Services or Website. After this notice period, all amendments shall be deemed accepted by you (provided however, that if any such change shall require your opt-in consent, we will first act to obtain it).
Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Notice or if you have any concerns regarding your Privacy, please contact us at email@example.com.