Privacy Policy

PRIVACY NOTICE

This privacy policy notice for Cohora Inc. ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://www.cohora.com, or any website of ours that links to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies or practices, please do not user our Services. If you still have any questions or concerns, please contact us at support@cohora.com.


SUMMARY OF KEY POINTS

This summary provides key point from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.


What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Cohora Inc. and the Services, the choice you make, and the products and features you use. Click here to learn more.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Click here to learn more.

What are your rights? Dependiing on where you are located geographoically, the applicable provacy law may mean you have certain rights regarding your personal information. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what Cohora Inc. does with any information we collect? Click here to review the notice in full.


TABLE OF CONTENTS

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. How long do we keep your information?
7. Do we collect information from minors?
8. What are your privacy rights?
9. Controls for do-not-track features
10. Do California residents have specific privacy rights?
11. Do we make updates to this notice?
12. How can you contact us about this notice?
13. How can you reveiw, update, or delete the data we collect from you?


1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: we collect personal information that you provide to us.

We collect personal information that you voluntarily provide to su when you express interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by you. The personal information that we collect depends on the context of your iinteractions with us and the Services, the choices you make, and the prodcuts and features you use. The personal information we collect may include the following:

• names
• email addresses

Sensitive information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected.

In short: Some information – such as your Internet Protocal(IP) address and/or browsewr and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characterisitics, operating system, language preferences, referriing URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many business, we also collect information through cookies and similar technologies.


2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.


3. WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR INFORMATION?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimated business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information.

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.


4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with thrid-party vendors, sercie providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts iin place with our third parties, which are designed to help safehurad your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Performance Monitoring Tools
• Retargeting Platforms

We may also need to share your personal information in the following situations:

•Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similiar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set our in our Cookie Notice.


6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless a longer retention period is required or permitted by law(such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been store in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less that 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delet sich data from our records. If you becoome aware of any data we may have collected from children under age 18, please contact us at customersupport@cohora.com.


8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://edoeb.admin.ch/edoeb/en/home.html

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any tiime by contacting us by using the contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawl nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communiucation at any tiome by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to sen you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similat technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually cghoose to set your browser to remove cookies or to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt our of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have any questions or comments about your privacy rights, you may email us at customersupport@cohora.com


9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not_track ("DNT")
feature or setting you can activate to signal your provacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standar for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.


10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of addressses of all thrid parties with which we shared personal information in the immediately preceding calendar year. If you are a California residnent and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted dat that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We weill make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems. (e.g., backups, etc.)


11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" data and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.


12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments about this notice, you may email us at customersupport@cohora.com or by post to:
Cohora Inc.
16 Pettees Pond Lane
Westwood, MA 02090
United States


13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by clicking here.