Types of Information Gathered
The Savvy Coop registration form requires users to give us contact information (for example, name and e-mail address). Users of Savvy Coop may also provide gender, birth date, ethnicity, demographic information (city and state), health-related information, along with social profile URLs, and other information necessary to participate in certain features of our platform or services made available through us. When using certain telephonic services as part of our services, you will also provide data relating to your voice characteristics, as well as location data, made available through your device, carrier, or IP address.
Certain non-personal information about site visits is recorded by the standard operation of our website, including but not limited to (i) IP address, (ii) domain server, (iii) type of device(s) used to access the website, (iv) web browser(s) used to access the website, (v) referring webpage or other source through which you accessed the website, (vi) geolocation information, and (vii) other statistics and information associated with the interaction between your browser or device and the website. Non-personally identifiable information may be used to improve the design and content of the Services or to personalize your experience.
Additional non-personal information that we collect is as follows:
Social Media Cookies
These cookies are used when you use a social media sharing button or you link your account or engage with our content on or through a social networking site such as Facebook, Twitter, or LinkedIn. The social network will record that you have done this. This information may be linked to targeting and/or advertising activities.
“Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect anonymous information about your use of our website, the websites of selected advertisers and the emails, special promotions or newsletters that we send you. The information collected by Web Beacons allows us to analyze how many people are using the Services, using the selected advertisers’ websites or opening our emails, and for what purpose, and also allows us to enhance our interest-based advertising.
We may use third-party website analytics services in connection with the website, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the website. These website analytics services generally do not collect Personal Information unless you voluntarily provide it and generally do not track your browsing habits across websites that do not use their services.
Mobile Device Identifiers
Mobile device identifiers are data stored on your mobile device that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and non-personally identifiable information. Mobile device identifiers help Savvy Coop learn more about our users’ demographics and internet behaviors.
Like many standard website servers, our web servers use log files. Log files include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and number of clicks. Log files are used to analyze trends, administer the site, track aggregated users' movement and gather broad demographic information. IP addresses, etc. are not linked to personally identifiable information.
We may collect your real-time geographic location in order to present relevant information from third parties with whom you may have authorized a connection. If your location is collected and used to push content, the location information will not specifically identify you.
Right to Data*
*This section is only applicable to those individuals who reside in a country or region that has regulations requiring the below (we may also have more detail for one or more regions below). When you send us such a request you will be required to provide a photograph of your government issued identification which confirms your residence in a country or region which recognizes such requirements.
If required by your country or region’s regulations, you have the right to request us free of charge, rectification and erasure of your personal data by sending an e-mail to firstname.lastname@example.org. This same email address can also be used to object to the processing of your personal data.
You can always get an overview of your own personal details and personal settings and adjust them if necessary by logging in and adjusting your account settings.
If required by your country or region’s regulations, you have the right to obtain the personal data you have provided to us, in a structured, current and machine-readable form, if you would wish to transfer them to another party.
How Your Information Is Used
We may also use anonymized or pseudonymized information for analysis purposes. Anonymization means it will no longer be able to identify you based on the information we use for our analysis. Additionally, the data you provide to us is processed by the various technology companies we interface with, including our email manager and newsletter providers and our Site provider. Savvy Coop will not sell to third parties any individually identifiable personal information, e.g., your e-mail address, name, etc., that you supply during the registration process.
Consent Regarding Communications Between Us
For contractual purposes, you (a) consent to receive all communications from us, including any possible newsletters or messages about security incidents, in electronic form via your account on our website or via the email address you submit when you register, and (b) agree that all terms, agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications would satisfy if they were in writing. Emails we send to you will contain an easy automated unsubscribe link so that you can opt-out of the subscription. Simply follow the indications or instructions in the email to unsubscribe.
Information Disclosed and Potential Business Transfers
Information that we collect from you as a user, including personal information, is considered to be a business asset and will be treated accordingly.
Individual Choice and Access
You have choices in the collection, use, and sharing of your personal information:
We are committed to maintaining the security of personal information. We use appropriate technical, administrative, and physical controls to protect personal information from unauthorized access, loss, misuse, or alteration. If we share personal information with others, we subject them to strict contractual and legal controls regarding the protection, use, and disclosure of the information. If we share anonymous or de-identified data with third parties, we will contractually require them to keep it in de-identified form and forbid them to make any attempt to re-identify the data or allow others to do so before sharing the information.
There is always some risk that unauthorized, wrongful, or illegal access to your information could occur or that data sent over the Internet could be intercepted. We urge you to take strong precautions to use secure networks and to protect your password. Do not disclose your website login credentials to unauthorized people. Also, be sure to sign off when finished using a shared computer.
Contact Us/Opt Out
Please contact us if you have any questions or comments about privacy, about how any information you send us may be used, or if you want to opt out of receiving communications from us and our professional partners:
1919 14th St., Suite 700, Boulder, CO 80302, Attn: Jason Wiener, Esq., email@example.com
Any email we send to you will contain an easy automated unsubscribe link so that you can opt-out of the subscription. Simply follow the indications in the email.
If you do not consent, many of our website’s features could be unavailable to you.
Rights in the European Union
If you are in the European Union or a resident of the European Union, the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. As applicable, we put transparency and access controls into place to help GDPR-based users exercise those rights. As required under GDPR, the rights afforded to you are:
- A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, (ii) if processed, to obtain access to such data and a copy of such data.
- A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Savvy Coop will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Savvy Coop may have legal or legitimate grounds for keeping such data.
- A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
- A right to data portability: you have the right to receive the personal data concerning you which you have provided to Savvy Coop, in a structured, commonly used, and machine-readable format, and you have the right to transmit such data to another controller without hindrance from Savvy Coop. This right only applies when the processing of your personal data is based on your consent or a contract and such processing is carried out by automated means.
- A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Savvy Coop. We may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by contacting us at firstname.lastname@example.org.
- A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about our personal data protection practices.
- A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Savvy Coop instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email email@example.com. You may access your personal data to modify or update at any time via your account on the website, or by emailing firstname.lastname@example.org.
We will respond to your request in a reasonable timeframe in accordance with applicable law.
GDPR Legal Bases for Processing Personal Data
In accordance with GDPR, Savvy Coop provides the following information regarding its Article 6 legal bases for personal data processing:
- The performance of the contract between you and Savvy Coop for the data processing relating to your use of our services;
- Our business interest in providing you with emails and push notifications for timely introductory materials and information about Savvy Coop, our services, features, and updates, and offers to upgrade your free account to a subscription account;
- Our business interest in offering you particularized or adapted content based on your usage of our services;
- Our business interest in collecting data regarding your general usage activities for the purpose of improving our overall user experience;
- Our business interest in providing you with communications regarding your account, questions about our content offerings, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests;
- Our business interest in collecting data related to unplanned downtime or errors in the services; and
- Our business interests in complying with our legal obligations, such as maintaining accurate financial records.
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing email@example.com.