Cota, Inc. Privacy Policy

Date: 11.16.2017

Introduction 

Cota, Inc. (“Cota”, “Us”, “We” or “Our”) respects Your privacy and is committed to protecting it through our compliance with this policy.

This privacy policy (this “Policy”) describes the types of information We may collect from you or that You may provide when You visit www.cotahealthcare.com (the “Site”) and Our practices for collecting, using, maintaining, protecting, and disclosing that information. 

This Policy applies to information we collect:

  • On this Site.
  • In email, text, and other electronic messages between You and the Site.
  • Through mobile and desktop applications You download from the Site, which may provide dedicated non-browser-based interaction between You and the Site.

It does not apply to information collected by Us offline or through any other means or any third party. 

Please note that Your use of our Site and any content or services provided on or through our Site are subject to Cota’s Terms and Conditions. We may make periodic changes to this \Policy. If such a change is made, Cota will post the revised terms on www.cotahealthcare.com and the revised terms will be effective on the “last modified” date stated at the top of this Policy.

This Policy is subject to change by Cota periodically. If such a change is made, Cota will post the revised Policy on the “Privacy Policy” section of the Site. Cota reserves the right to add to or change the Site or cease offering the Site or terminate Your use of the Site at any time and without liability. Cota reserves the right to refuse to offer access to the Site and/or content to anyone at any time without notice. Your continued use of or access to the Site after We make changes constitutes Your acceptance of these changes and the current version of this Privacy Policy, so please check the Policy periodically for updates. 

Please read this Policy carefully to understand Our policies and practices regarding information and how We will treat it. If You do not agree to these terms, You must not access or use the Site.

Information We Collect and Information You Provide

We may collect your information in a variety of ways through Your use of the Site including when You visit or browse the Site and its pages, register on the Site, fill out a form, or in connection with other features or resources available on the Site. The type of information We collect varies and may include:

(i) Personal information You provide to Us through Our forms on the Site, such as, demographic information like name, email address, mailing address, date of birth, or phone number. This information is provided by You to Us by filling in forms on the Site, including at the time of requesting a demonstration.

(ii) Non-personal information about You when you interact with the Site, such as, technical data and related information—including but not limited to technical information about Your device, system and application software, peripherals, IP addresses, operating system information, browser type and version, and network connectivity information, or other non-identifying information stored in cookies that We enable on the Site—that is gathered periodically to facilitate the provision of software updates, product support, and other services to you (if any) related to the Site and its content. A cookie is a small file placed on the hard drive of your computer. Unless You have adjusted Your browser setting so that it will refuse cookies, Our system will issue cookies when You direct Your browser to the Site. We do not track Your use of other website or pages. We may use this information, as long as it is in a form that does not personally identify You, to improve our products or to provide services or technologies to You. 

(iii) Information collected through automatic data collection technologies as You navigate through and interact with the Site, such as, details of Your visits to the Site, including traffic data, location data, logs, and other communication data and the resources that You access and use on the Site.

The information we collect automatically is statistical data that may include personal information We may maintain it or associate it with personal information We collect in other ways or receive from third parties. It helps Us to improve the Site and to deliver a better and more personalized service, including, by enabling Us to estimate Our audience size and usage patterns, recognize You when You return to the Site, among other things. 

The technologies We use for this automatic data collection may include:

  • Cookies (or browser cookies). As set forth above, a cookie is a small file placed on the hard drive of Your computer. You may refuse to accept browser cookies by activating the appropriate setting on Your browser. However, if You select this setting You may be unable to access certain parts of the Site. Unless You have adjusted Your browser setting so that it will refuse cookies, Our system will issue cookies when You direct Your browser to the Site.
  • Flash Cookies. Certain features of Our Site may use local stored objects (or Flash Cookies) to collect and store information about Your preferences and navigation to, from, and on Our Site. Flash cookies are not managed by the same browser setting as are used for browser cookies. 
  • Web Beacons. Pages of the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages or opened an email and for other related website statistics. 

We do not collect personal information automatically, but We may tie this information to personal information about You that we collect from other sources or that You provide to Us.

Use of Your Information

We use information that We collect about You or that You provide to Us, including any personal information: 

  • To present the Site and its contents to You and to improve its design and functionality;
  • To provide You with information, products, or services that You request from Us;
  • To personalize Your experience on the Site;
  • To improve customer service;
  • To fulfill any other purpose for which You provide the information;
  • In any other way We may describe when You provide the information;
  • For any other purpose with Your consent.

Disclosure of Your Information

We may disclose aggregated information about You, and information that does not identify You, without restriction. We do not share personal information You provide to us through the Site with any third party for any reason except:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties We use to support Our business and who are bound by contractual or other legal obligations to keep personal information confidential and use it only for the purposes for which We disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cota’s assets, whether as a going concern or as part of bankruptcy, liquidated or similar processing, in which personal information help by Cota about the Site is among the assets at issue.
  • To fulfill the purpose for which You provide it.
  • For any other purpose disclosed by Us when You provide the information.
  • With Your consent.

We may also disclose Your personal information:

  • To comply with any court order, law or legal process, including to respond to respond to a government, court or regulatory request.
  • To enforce or apply Our Terms & Conditions and other agreements.
  • If We believe disclosure is necessary or appropriate to protect the rights, property or safety of Cota, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection or identity theft.

We do not sell, trade, or rent Your personal information to others. We may share generic aggregated demographic information not linked to any personal information regarding Site visitors or users with Our business partners and trusted affiliates for the purposes outlined above.

Choices About How We Use and Disclose Your Information

We strive to provide You with choices regarding the personal information You provide to Us. We have created mechanisms to provide You with the following control over Your information. In regards to tracking technologies, You can set Your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how You can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If You disable or refuse cookies, please note that some parts of this Site may then be inaccessible or not function properly. 

Transferring Personal Information from the EU to the US

Cota has its headquarters in the United States. Information We collect from You will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the European Union’s General Data Protection Regulation (“GDPR”). Cota relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Cota collects and transfers to the U.S. personal data only: with Your consent; to perform a contract with You; or to fulfill a compelling legitimate interest of Cota in a manner that does not outweigh Your rights and freedoms. Cota endeavors to apply suitable safeguards to protect the privacy and security of Your personal data and to use it only consistent with Your relationship with Cota and the practices described in the Terms & Conditions and in line with the Policy. Cota also minimizes the risk to Your rights and freedoms by not collecting or storing sensitive information about You.

Data Subject Rights

The European Union’s General Data Protection Regulation provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the United Kingdom’s Information Commissioner’s Office available here.

This Privacy Policy is intended to provide You with information about what personal data Cota collects about You and how it is used. If You have any questions, please contact Us at privacy@cotahealthcare.com.

If You wish to confirm that Cota is processing Your personal data, or to have access to the personal data Cota may have about You, please contact Us at privacy@cotahealthcare.com.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Cota might have received the data from Cota; what the source of the information was (if You did not provide it directly to Cota); and how long it will be stored. You have a right to correct (rectify) the record of Your personal data maintained by Cota if it is inaccurate. You may request that Cota erase that data or cease processing it, subject to certain exceptions. You may also request that Cota cease using Your data for direct marketing purposes. In many countries, You have a right to lodge a complaint with the appropriate data protection authority if You have concerns about how Cota processes Your personal data. When technically feasible, Cota will—at your request—provide your personal data to You or transmit it directly to another controller.

Reasonable access to Your personal data will be provided at no cost to You upon request made to the Company at privacy@cotahealthcare.com. If access cannot be provided within a reasonable time frame, Cota will provide You with a date when the information will be provided. If for some reason access is denied, Cota will provide an explanation as to why access has been denied.

Purpose of the Privacy Policy

The Privacy Policy is intended to provide You with information about what personal data Cota collects about You and how it is used. If You have any questions, please conduct us at privacy@cotahealthcare.com.

If you wish to confirm that Cota is processing your personal data, or to have access to the personal data Cota may have about You, please conduct us at privacy@cotahealthcare.com.

Changes to Our Privacy Policy

It is Our policy to post any changes We make to our Policy on this page with a notice that the Policy has been updated on the Site home page. If We make material changes to how We treat Your personal information, We will notify You through a notice on the Site’s home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting the Site and this Policy to check for any changes.

Security

We have implemented measures designed to secure Your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to Us is stored on Our secure servers behind firewalls.

We have adopted reasonable data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your personal information, transaction information and data stored on the Site. For example, the majority of the data exchanged between You and the Site or our third-party service providers is transmitted over an SSL secured communication channel and is encrypted and protected with digital signatures. 

That being said, We do not make any representations or warranties of any kind related to the security of the Site or Your information stored on the Site. Please see the disclaimers in the Terms and Conditions

Inherent Risk of Using Internet

Despite Our efforts to protect Your personal information, there is always some risk that an unauthorized third party may find a way around Our security systems or that transmissions of Your information over the Internet may be intercepted, and You acknowledge these inherent risks before using the Site.

The safety and security of Your information also depends on You. Where we have given You (or where You have chosen) a password for access to certain parts of our Site, You are responsible for keeping this password confidential. We ask You not to share your password with anyone. We urge You to be careful about giving out information in public areas of the Site like message boards. The information You share in public areas may be viewed by any user of the Site.

Children

The Site is not intended for children under 18 years of age. No one under age 13 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under 13. If You are under 13, do not use or provide any information on this Site or on or through any of its features/register on the Site or otherwise provide any information about Yourself to US, including your name, address, telephone number, email address or any screen name or user name You may use. If We learn We have collected or received personal information from a child under 13 without verification of parental consent, We will delete that information. If You believe We might have information from or about child under 13, please contact Us at privacy@cotahealthcare.com.

Contact

If You have any questions or concerns regarding this policy or Our use, storage, or handling of Your personal information, please contact Us:

By Email: privacy@cotahealthcare.com

By Mail: 1 State Street, 25th Floor, New York, NY 10004