Effective Date: December 5th, 2022
The Service collects and processes personal data, which is information about you or that identifies you, as well as anonymous data, which does not identify you.
Subject to legal, contractual and technical requirements, you may choose not to provide Company with certain data or request the deletion of certain data, which may impact Service features available to you or essential operations of the Service.
The following is a description of the personal data that we may collect, use and process in connection with the Service:
● Microsoft Account data, which may include all personal information shared by you on the Microsoft Account including but not limited to your first and last name, user ID, your workplace, email address, phone number and address;
● your profile picture and biography on your Microsoft Account and any other personal information you choose to share on the Microsoft Account;
● data related to Coffee Chats such as matching history and booking times;
● your calendar and schedule information;
● your time zone information, and other indicators of location including but not limited to business addresses;
● support and feedback data information and all messages related to troubleshooting tickets or feedback submission to Company;
● information relating to the device through which you access the Service, which may include your operating system, associated software, product keys, and network;
● your browsing and usage data associated with the Service; and
● your IP address.
We also collect anonymous data that does not identify you, including but not limited to responses to anonymous feedback requests, metrics and other types of statistical data, which could be derived from use of the Service and analytical data concerning the Service.
We process your personal and anonymous data primarily for our legitimate business purposes, such as providing the Service to you, to understand your needs and the needs of our users and to improve the quality of the Service and analyze the data we collect. Specifically, these uses include but are not limited to:
● providing the Service;
● interacting with you through our social media accounts or profiles and providing customer support and feedback;
● authenticating users;
● maintaining and analyzing functionality of CoffeePals and the Service, backing up data, testing and developing new aspects of CoffeePals, researching new features of the Service, updating CoffeePals and the Service and generating reports and data models that we use to improve the Service;
● supporting the security and integrity of the Service and its users including but not limited to detecting and protecting CoffeePals and other third-parties against error, fraud, theft and other illegal activity or for contractual, legal, regulatory or audit obligations;
● investigating improper or suspicious activity; and
● contacting you for various reasons including, but not limited to, user feedback requests or marketing purposes and events, if you previously consented to such contact.
We may disclose your personal and anonymous data to our parent companies, affiliates, subsidiaries, employees and contractors for the same purposes described above. We may also disclose your personal and anonymous data to third-parties, who may be located in a foreign jurisdiction and subject to foreign laws. The situations where we disclose your personal and anonymous information to third-parties include, but are not limited to:
● processing your information as described above as well as providing and enhancing the Service features;
● providing customer support and feedback, analyzing Service functionality and technical issues, tracking use of the Service and generating reports and data models that we use to improve the Service;
● providing customized, tailored and personalized advertisements to users of the Service; and
● responding to a request from law enforcement or a government that has asserted its lawful authority to obtain the data or where Company has reasonable grounds to believe the data could be useful in the investigation of unlawful activity, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending our rights and the rights of others or providing information to our legal counsel.
You may contact Company to obtain a copy of any personal data we collected about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you are responsible for the accuracy and completeness of your personal data, and you may contact Company to correct inaccurate personal data or to complete incomplete personal data.
You may be able to opt-out of some or all of the ways in which your personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital:
● to comply with our legal obligations;
● to protect your interests or those of another person; or
● for our legitimate interests or the legitimate interests of a third-party,
and may do so by removing personal data, if the Service permits such removal, by ceasing your access to the Service and contacting us using the contact information found below.
While Company is a Canadian company, the data you provide through the Service may be stored and processed by third parties in countries around the world. You authorize Company and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal and anonymous data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.
Company complies with international personal data transfer laws in applicable jurisdictions. For EU residents, Counselling complies with Articles 44-49 of the European Union’s General Data Protection Regulation (the “GDPR”). Company also follows UK laws equivalent to what is required by the GDPR for all data collected from UK data subjects. Currently, all transfers of personal data to Canada from residents of the EU are covered by an adequacy decision as described in Article 45 of the GDPR. All transfers of personal data to the United States from residents of the EU are covered by standard contractual clauses as approved by the European Commission when required until the adoption of a new GDPR framework has been provided which shall supersede.
Your personal data is retained until you request its deletion or until Company no longer requires such data for the purpose for which it was collected or until required to be deleted by laws applicable in your jurisdiction. Please email us at email@example.com to delete any personal data we hold.
Company complies with the United States Children’s Online Privacy Protection Act and all other applicable privacy laws and regulations concerning children and the Internet including laws applicable to residents of the EEA. The Service and CoffeePals are not directed to children under the age of 18 and although it may be possible that children below the age of 18 access certain features of the Service, we do not knowingly collect personal data from children under the age of 18 without first obtaining the appropriate parental consent required by law. If we learn that we inadvertently collected personal data from a child under the age of 18, in a jurisdiction where consent of a parent or guardian is required to be collected prior to the collection of such personal data, without first obtaining such appropriate parental consent, we will delete that data as quickly as possible. If you are a parent or guardian of a child under 18, who you believe provided Company with personal data without your consent, please contact us at firstname.lastname@example.org.
Do Not Track (“DNT”) is a web or device setting that allows users to request that receivers of personal data stop their tracking activities. When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug in providers and other web services you encounter to stop tracking your activity. Currently, there are no DNT technology standards, and it is possible that there may never be any DNT technology standards. As a result, we do not respond to DNT requests.
If you are a California resident, California Civil Code § 1798.83 grants you the right to request our disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would like to make this request, please contact us using the contact information set forth below.
Please note that you may only make this request once per year.
If you are a resident of the European Union or the United Kingdom, you have certain rights in regard to your personal data. These rights include:
● A Right of Access. You have the right to access your personal data that we hold about you free of charge in most circumstances;
● A Right to Rectification. If your personal data is inaccurate or incomplete, you can change the information you provided by changing the information yourself on your Account or by contacting Company using the email listed below;
● A Right to Erasure. You have the right to obtain deletion of personal data concerning you in many cases. Often you can just delete your information by yourself through your Account, but you can also request the deletion by using the contact information found below. Please be careful as the deletion of your data in this manner is permanent and may never be restored;
● A Right to Object. If the processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR, you have the right to object to this processing in most cases. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the personal data is necessary for the establishment, exercise or defense of legal claims or in the case where the personal data is required for the provision of certain features of the Service, and you still wish to use such features of the Service;
● A Right to file a Complaint. You have the right to file a complaint with the appropriate supervisory authority in your jurisdiction;
● A Right to Restriction of Processing of your Personal Data. You have the right to obtain restrictions on the processing of your personal data as described in Article 18 of the GDPR;
● A Right to Personal Data Portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller under the conditions described in Article 20 of the GDPR. Although the personal data collected by Company is not particularly useful to other companies as the data collected largely relates to your usage of the Service, Company will comply will all requests for the portability of your personal data;
● A Right to Post-Mortem Control of Your Personal Data. If data protection legislation and related regulations in France are applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of your personal data after your death in accordance with Article 40-1 of the Act No. 78-17 of January 6, 1978 on Information, Technology, Data Files and Civil Liberties;
● A Right to Opt-out of Marketing Communications. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link on any marketing e-mails Company sends you. To opt-out of other forms of marketing, please contact us using the contact details provided below; and
● A Right not to be Subject to Solely Automated Decisions. You have the right to not be subject to solely automated decisions, including profiling, which have a legal or similarly significant effect upon you.
We are committed to ensuring that your data is secure. To prevent unauthorized access, disclosure, or breach, we put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process. More about our security processes can be found at coffeepals.com/security.
We may communicate with you through the Service itself, but we may sometimes collect your email address in order to respond to support requests or comments. If you have provided us with your email address and would like to change the email preferences, we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with “unsubscribe” in the email title or body or by modifying your email settings within the Service. On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.
Officer, Kacper Zylka, at email@example.com.