The Services are designed to enable individual users of the Service (“Users”) to distribute custom User-generated messages and content across various digital domains and platforms to a particular audience (“Viewers”) based upon the apparent attributes and interests of the Viewers (“Viewer Attributes”). Project Cohort may receive and use information relevant to determining Viewer Attributes from its third party business partners who have directly collected such information in accordance with their respective privacy policies. Project Cohort is not responsible for the collection, storage, or use of any Personal Data or other information by its third party business partners. We encourage you to review the privacy policies of the third-party websites, mobile applications, and other online services that you visit. We may offer individuals the right to “opt out” of receiving receiving targeted messages from our Users, and to the extent we do so, the mechanism for opting out is described in the section entitled “Your Choices” below.
Information We Collect: When you interact with us through the Site, we may collect Personal Data and other information from you, as further described below:
Data from Mobile Device Address Book and Other Applications: The Services may also collect information (including Personal Data) about others that is stored in a User’s mobile device address book, mobile device contacts, calendar or other non-Project Cohort applications in order to send messages to a particular individual. Depending on a User’s mobile device operating system, the Services may request permission to access such information. For example, as a User you may use our address book or “contacts” importer (or other similar features) to upload your address book into the Services.
Data from Invitations: If you are a User, please note that when you invite another
User to connect with you on the Services or invite another person to join the Services and become a, that person may have access to your email address or, for SMS invitations, mobile number because it may be displayed in the invitation. After sending these invitations, we may also remind your invitees of your invitation on your behalf.
Non-Identifiable Data: When you interact with Project Cohort through the Site or Services, we receive and store certain personally non-identifiable information. Such information is collected passively using technologies such as cookies, pixel tags and web beacons, and at present, such information cannot be used to specifically identify an indiv. Project Cohort may store such information itself or such information may be included in databases owned and maintained by Project Cohort affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve its Users, Project Cohort often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Project Cohort may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Project Cohort may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Location Information: Our Service may collect and use your location information (for example, by using the GPS on your mobile device when you access the
Site or Services from your mobile device) to provide certain functionality of our Service. If you choose to enable our location features, your location information may be publicly displayed within the Service. Please keep in mind that your generalized location (for example, the city or locality in which you are located) may be made available to other Users or individual visitors to the Site, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your location information may be subject to abuse, misuse, and monitoring by others, so please be careful if you choose to enable location functionality. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data” section.
We have also implemented Google Analytics features based on Display Advertising (Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and Integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers). Visitors can opt out by using Google’s Ads Settings or going to
Our Use of Your Personal Data and Other Information:
Our Disclosure of Your Personal Data and Other Information:
Project Cohort is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Related Third Parties: Project Cohort, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Project Cohort may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Project Cohort, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.
Links to Other Web Sites:
Integrating Social Networking Services:
One of the special features of the Service is that it allows you to enable or log in to the Services via various social networking services like Facebook or Twitter (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access