Effective April 6th, 2020
- Who we are
- How this Policy applies
- Data you provide to us
- How we collect information
- How we use this information
- How we share your information with third parties
- Your controls and choices
- General Data Protection Regulation (“GDPR”)
- Who is the Data Controller?
- Legal basis for use of your information & controls and choices
- How we protect your information and data retention
- Data transfers, storage, and processing globally
- The California Consumer Protection Act (“CCPA”)
- Other rights of California Residents
- Children’s privacy
- Exercising rights under other privacy laws
- Contact us
Who we are
How this Policy applies
Data you provide to us
We collect information you provide directly to us, information from 3rd parties, and information that we collect through automated means. As described below in more detail, we may collect the following categories of information about you or your use of the Service: (1) identifiers (such as name, email address); (2) commercial information (such as transaction data); (3) financial data (such as credit card information); (4) Internet or other network or device activity (such as browsing history; (5) device identifiers (such as IP address); (6) geolocation information; (7) professional or employment related data (such as when you identify employers in a Campaign); (7) inference data about you; (8) legally-protected classifications (such as if you reveal gender in public forums); (9) physical characteristics or descriptions (such as if you provide us with a photograph); (10) sensory information (such as if you call us and leave a voicemail); and (11) other information that identifies or can be reasonably associated with you.
More specifically, we collect:
- Registration information you provide when you create an account or a Campaign, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and last name, country of residence, gender, date of birth, email address, username, and password.
- Transaction information you provide when you request information, or contact Coiin, (including your address if you are receiving a reward that needs to be shipped).
- Information you provide when you create a Campaign including some banking information, contact information such as your phone number, email address, mailing address.
- Information you provide to us that is used for compliance purposes when you make a Contribution or create a Campaign, such as your government ID, information needed for tax forms, other information required for payment processing. Please note that in many cases, Coiin cannot view or access all of the information you provide to us for compliance purposes, such as complete bank account numbers or government IDs, as this may be transmitted via automated means directly to the vendor that requires that compliance information.
- Information you provide in public forums on our sites and applications, such as your public posts.
- Information you provide when signing up for updates and news from a Campaign pre-launch on the Site.
- Information we obtain from a third party, such as a site or platform provider, about the use of our Site or Services on third-party platforms or devices.
- Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information.
- Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences.
- Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address.
You may decline to provide us with your information. However, this will limit your ability to register for an account or use our Services. You may review, change or remove certain types of your information through your account settings.
How we collect information
- We collect information you provide to us when you access, use, request or purchase our Services, request information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to User surveys, or otherwise interact with us online or offline.
- We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.
- We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.
- We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third-party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.
How we use this information
Consistent with applicable law and choices and controls that may be available to you, we may use information collected (including the categories set forth above) from you, or from devices associated with you:
- To enable us to provide you with our Services, and to improve and promote our Services.
- To communicate with you about your account or transactions on our Site and send you information or request feedback about features on our sites and applications or changes to our policies.
- For our marketing and third-party marketing purposes: to send you offers and promotions for our products and services or third-party products and services.
- Personalize the Services, content and experiences.
- Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications.
- Operate, understand, optimize, develop, or improve the Services, our sites, applications, products, services and operations, including by performing User market research and using analytics tools.
- Bug detection and error reporting.
- Audit consumer interactions on the Services including to measure the placement, frequency, efficacy and compliance of advertising and ad impressions.
- Security, Fraud, and Legal Compliance, including to detect, investigate and prevent activities that may violate our policies or be illegal.
- We may aggregate and/or anonymize any information collected through the Service so that such information can no longer be linked to you or your device. (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose and share such data with any third parties, including advertisers.
How we share your information with third parties
We may share the categories of information identified above for the following business and commercial purposes:
- When you join a Campaign, we share your information with the Campaign Owner so that the Campaign Owner can, for example, send you rewards, provide you with customer service, conduct market research, and comply with our Additional Terms and policies. Please note that once we share your personal information with a Campaign Owner, the information received by the Campaign Owner is controlled by that company and becomes subject to the Campaign Owner’s privacy practices.
- We also share certain types of value interaction information with necessary third parties for compliance purposes like payment processing or identity verification.
- When you create a Campaign, we share some of the information you provide with necessary third parties for financial compliance purposes, such as preparing for Campaign disbursement or sending you tax forms.
- When you allow us to share your personal information with another company, such as:
- Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services, and
- Directing us to share your personal information with third-party sites or platforms, such as social networking sites.
- Please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.
- When companies perform services on our behalf, like marketing and advertising, and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law.
- When we share your personal information with your consent, including when you post personal information on public forums or blogs accessible to third parties.
Your controls and choices
The laws in some jurisdictions require us to provide you with the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. Information for residents of certain jurisdictions is below. To the extent that those laws apply to you, your controls and choices may include any of the following:
- Updating or deactivating your Coiin Raiinmaker account.
- Choosing or changing your choices for subscriptions, newsletters, and alerts.
- Choosing whether to receive offers and promotions for our products and services from us, or offers for products and services that we think may be of interest to you.
- Choosing whether we share your personal information with other companies that would like to send you offers and promotions about their products and services.
- Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers (by visiting the Digital Advertising Alliance).
- Controlling whether you want us to access location information, such as by controlling or disabling location services on your mobile device’s settings menu.
- Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest-based ads.
- Requesting removal of your personal information from a public forum on one of our sites or application.
You may exercise these controls and choices in various ways, including by contacting our customer support team, following instructions provided in communications sent to you, or by using your device or other available settings (for example, by resetting your device’s advertising identifier and/or opting out of interest based ads).
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our Services may not be able to take account of your interests and preferences. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact us.
General Data Protection Regulation (“GDPR”)
The following sections on GDPR applies to individuals in the European Economic Area (“EEA”). If you are not sure whether the GDPR section applies to you, please refer to the text of the regulation here or consult with an attorney as Coiin is not able to give you legal advice.
Who is the Data Controller?
Coiin is the “data controller” of personal data collected by all of Raiinmaker, and we are responsible for deciding how personal data is collected, used, and disclosed. Campaign Owners may also be data controllers of certain data that you provide to Campaign Owners when you make a Contribution to a Campaign or through any of our other Services.
Legal bases for use of your information & controls and choices
The laws in the European Economic Area (“EEA”) and some other jurisdictions require us to provide Users, to the extent those laws apply to such Users, with the following information:
Legal grounds for use and disclosure of personal information
The legal grounds for use and disclosure of personal information include any of the below reasons:
- On the basis of consent, such as to send you certain information, including marketing communications, to share your information with partners when you have requested we do that, or to collect and process your information for research purposes if you have Contributed to a Campaign, or otherwise agreed.
- For our legitimate interests or the legitimate interests of others such as to ensure the security of our Sites, operate and improve our business and our Sites, respond to your questions, engage in certain marketing, make and receive payments, comply with our legal obligations, prevent fraud, conduct analysis, enforce our Terms, engage in a business change (e.g., sale, merger), to know the User to whom we are providing the Service, and to create anonymous data.
- To protect the vital interests of the individual or others. For example, we may collect or share personal data to help resolve an urgent medical situation.
Controls and choices
- In addition, Users in the European Economic Area and some other jurisdictions outside the United States have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways (for example, if you opt out of the use of your telephone number for direct marketing, we might still decide to contact you by phone regarding potential fraud on your account).
- Users in the European Economic Area have the right to opt-out of all of our processing of their personal data for direct marketing purposes. To exercise this right, you may contact us.
- The rights and options described above are subject to limitations and exceptions under applicable law. In situations in which we process personal data on behalf of our User, we may refer the request to the relevant User and cooperate with their handling of the request, subject to any special contractual arrangement with that User.
- In addition to these rights, Users in the European Economic Area have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
How we protect your information and data retention
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect User information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.
Data transfers, storage, and processing globally
The California Consumer Protection Act (“CCPA”)
The following section on CCPA, Cal. Civ. Code § 1798.100 which is effective January 1, 2020, applies to California residents who have certain rights regarding the personal information (as defined in the CCPA) collected by Coiin. It does not cover personal information not subject to the CCPA rights identified below, such as personal information we collect from our employees or job applicants. Likewise, the CCPA does not extend all the rights identified below to personal information collected from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.
- “Personal information” or “PI” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- “Consumer” is a California resident, a natural person who is a California resident for other than a temporary or transitory purposes, or someone who is domiciled in California but is currently outside the State for a temporary or transitory purpose.
- “Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the Coiin to another business or a third party for monetary or other valuable consideration.
California residents have the following rights under CCPA
- Right to Opt Out. You have the right, at any time, to direct us to not sell your PI. Please contact us.
- Sale of PI. Under the CCPA, sale is also broadly defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services.
- Categories of PI We Provide and Purposes of the Sale. We provide the following categories of information to third parties for these purposes: including identifiers, geolocation information, professional or employment related data, and physical characteristics or descriptions.
- Purpose of the Sale: We may provide the following categories of personal information to third parties for these purposes:
- For online targeted advertising purposes: device identifiers (such as browsing history; geolocation information; social media information), and
- For sharing with third parties to send you relevant offers and promotions and opportunities, such as when you sign up for an event or to receive more information and provide categories of information to us: identifiers, professional or employment related data (such as your job title or current company), and physical characteristics or descriptions (such as if you provide a picture of yourself).
- Right to Know or Right to be Informed. Subject to certain exceptions, you have the right to know what specific pieces of PI Coiin has collected about you in the 12 months preceding your request, along with the categories of sources of that PI, our business or commercial purpose for disclosing your PI, and the categories of third parties with whom we share your PI. You may make this request no more than twice per 12-month period.
- Right to Request Deletion. You have the right to request deletion of the PI Coiin has collected from you, subject to certain exceptions under the CCPA including, without limitation:
- Making sure you can receive your reward if you would still like to,
- Complying with Coiin’s legal or compliance obligations,
- Detecting fraudulent behavior or security incidents, and
- Other reasons that are in connection with our lawful internal uses that are consistent with your relationship with us and the context in which the information was collected.
Exercising Your Rights under CCPA
You can exercise any of your rights under CCPAby emailing us.
We will take reasonable steps to verify your identity before responding to a request, which may include the following:
- If you are exercising your Right to Delete or a similar right that does not require the disclosure of specific pieces of information about you:
- If you are writing to us from the email address associated with your Raiinmaker account or transactions that Coiin has on file for you, then to complete the verification process, we will ask you to confirm the action you wish us to take before we proceed (such as confirming you would like us to delete your information).
- If you are not writing to us from the email address associated with your Raiinmaker account or the Contributions that Coiin has on file for you, then to complete the verification process, we will ask you to provide 3 specific pieces of data that we have on file for you, such as email address you used when receiving a reward or billing information such as the last 4 digits of the credit card used or the billing address for a Contribution.
- If you are exercising your Right to Know or a similar right that does require disclosure of specific pieces of information about you:
- If you are writing to us from the email address associated with your Raiinmaker account or transactions that Coiin has on file for you, then to complete the verification process, we will ask you to both: 1) confirm the action you wish us to take before we proceed and 2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made.”
- If you are not writing to us from the email address associated with your Raiinmaker account or the contributions that Coiin has on file for you, then to complete the verification process, we will ask you to both: 1) provide 3 specific pieces of data that we have on file for you, such as email address you used when making a Contribution or billing information such as the last 4 digits of the credit card used or the billing address for a Contribution and 2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made.”
- You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above methods before processing the authorized agent’s request.
- If we are not able to successfully verify you according to the above methods, then we will not be able to comply with your request.
Coiin will not discriminate against you if you exercise your rights under CCPA. However, if your request requires us to delete, restrict or not share information, please be advised that this will inhibit some functionality of the Site. Any subsequent interaction with the Site after deletion will require new requests for action on your data.
Other rights of California Residents
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to us. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share your personal information with third parties’ direct marketing use unless you elect that we do so.
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please contact us with a detailed description of the specific content or information. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
People under 18 (or the legal age in your jurisdiction) are not permitted to use Coiin on their own. Coiin does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services. If you believe that a child has provided us with personal information, please contact us. If we become aware that a child under age 13 has provided us with personally identifiable information, we will delete it.
We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as quickly as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
Exercising rights under other privacy laws
If you would like to exercise a right under a different privacy law, please contact us.