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Privacy Policy

 

Introduction
Your privacy is very important to Savvy Coop ("us", "we", "our", and "Savvy Coop"). This Privacy Policy explains how your personal information is used and protected. Information requested or provided other than through Savvy Coop’s website will contain separate privacy terms and conditions. This Privacy Policy explains how we deal with personal information that is obtained via our platform available at Savvy.Coop. We respect the privacy of our users and use all reasonable steps to ensure that any personal information we receive will be protected and treated confidentially.

Types of Information Gathered

Personal Information
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.

When using our services and/or website, you may also use the services and/or websites offered by other parties. Payment systems are provided by third parties and the information you provide to facilitate payment is collected by such third parties and not Savvy Coop. If you link, connect, or login to the platform with a third party service (e.g., Google, Facebook), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage. Please check the privacy practices of these other companies or persons (if any) to understand how they treat the personal information that you provide to them and contact them if you have any concerns.

All personal data we collect from UK residents that relates to their health or healthcare experience is considered "special category" data under UK GDPR. We process this data only with the individual's explicit consent as required under Articles 6(1)(a) and 9(2)(a) of UK GDPR. Consent is recorded at the point of data collection with timestamp and IP address or equivalent device information.

Non-Personal Information
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.

Cookies
We use cookies on our website to make your experience easy and meaningful and to enable certain technical operations. Cookies are files that web browsers place in a device’s memory and are used to tell us whether customers and visitors have previously visited our website. Usage of a cookie is not linked to any personally identifiable information while on the website.

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
“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.

Website Analytics
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.

Log Files
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.

Location
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.

How Your Information Is Used
We expect to primarily use your email address to send you updates about the status of Savvy Coop (giving you updates and potentially polling you for input). We may also email you regarding opportunities to participate in different "gigs," such as focus groups, and to send you information about any new services or initiatives or to respond to your requests. We will only send your personal information to other companies or people when: (1) we have your consent to share the information; (2) we need to share your information to facilitate your involvement in a "gig"; (3) we respond to subpoenas, court orders or other valid legal process; (4) we find that your actions on our website violate our Terms of Service, or any of our usage guidelines for specific products or services; or (5) as part of an engagement with a Client (if your personal information will be shared with a Client, we aim to require the Client to agree to terms and conditions no less protective of your confidentiality and personal information than this Privacy Policy).

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
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.

Sponsored Content
The Savvy Coop website includes some sponsored content. These resources and tools are created directly with industry sponsors. If sponsored content includes a separate or unique privacy policy, Savvy Coop will display the sponsor’s full privacy statement or a link to the policy within the content or web pages.

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. If you do not want us to have your information, do not register with our website or sign up for research studies or opportunities. Our website contains links to other sites. Please read the privacy statements of any other websites that you visit because those websites are not governed by this Privacy Policy. Savvy Coop is not responsible for the privacy practices or the content of those websites. If you want to review and correct your personal information, please contact us and we would be glad to assist you (see Contact Information, below).

Cross-Border Transfers
We transfer personal data collected from UK, EU, and Swiss residents to secure servers in the United States. These transfers are governed by appropriate safeguards, such as the UK International Data Transfer Agreement (IDTA), UK Addendum to the EU Standard Contractual Clauses, or Standard Contractual Clauses (SCCs) as applicable. We are actively pursuing self-certification under the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, but do not currently claim participation in these frameworks. Once our certification is confirmed by the U.S. Department of Commerce, we will update this Privacy Policy to reflect our participation status.

Data Privacy Framework Notice

Savvy Coop is in the process of self-certifying its compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), as set forth by the U.S. Department of Commerce.
Until our self-certification is approved, we do not claim participation in any DPF program. Upon completion, we will update this policy to confirm certification and designate our Independent Recourse Mechanism for unresolved complaints under the DPF principles.

 

Savvy Coop is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Subject Rights
We maintain a dedicated email address for UK and EU residents to submit requests related to their data rights: uk-privacy@savvy.coop. These include the right to access, rectify, erase, restrict, object to processing, or request portability of their personal data. We will respond to such requests within one month in accordance with UK GDPR and EU GDPR requirements. We also log and confirm any deletion or access actions taken in fulfillment of such requests.

Data Protection Impact Assessments
For projects involving large-scale processing of sensitive personal data, including health data from UK residents, we conduct a Data Protection Impact Assessment (DPIA) to evaluate risks and ensure appropriate controls are in place. Our DPIA process includes evaluation of necessity, proportionality, risk, and safeguards including pseudonymization, encryption, and role-based access controls.

Security and Retention
All data collected through our platform is protected using encryption in transit (TLS 1.2+) and at rest (AES-256 or equivalent). Access to identifiable data is limited to designated staff on a role-based access model and is monitored via access logs. We retain identifiable data for as long as there is a legitimate business purpose to do so, or until a participant requests deletion. Unless otherwise legally required, we periodically review retention to ensure data is not kept longer than necessary.

Children
At this time, children under the age of 18 cannot create Savvy Coop accounts. Parents may share information about their own children in accordance with the Terms of Service and this Privacy Policy.

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:
hello@savvy.coop
1919 14th St., Suite 700, Boulder, CO 80302, Attn: Jason Wiener, Esq., jason@jrwiener.com
201-293-6336
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.

Updates
We may modify this Privacy Policy at any time, although we expect that most changes will only be editorial in nature or reflect changes in the services we offer. However, in the unlikely event that we would ever make material changes that would permit us to share your information more broadly than we have previously described, we will use reasonable efforts to notify you of such a change so you can make an informed decision about continuing to use the Site. 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 hello@savvy.coop.
  •  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 hello@savvy.coop. You may access your personal data to modify or update at any time via your account on the website, or by emailing hello@savvy.coop.

 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 hello@savvy.coop.

Effective Date
 This Privacy Policy is effective May 25, 2018. Updated: May 6, 2020, June 5, 2025. Last updated: June 11, 2025.