Privacy Notice

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Welcome, and thank you for your interest in Cobalt Intelligence Inc. (“Cobalt,” “we,” or “us”), our website at https://www.e-cobalt.com (the “Site”), and all related websites, downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this Privacy Notice is displayed, and all other communications with individuals through from written or oral means, such as email or phone (collectively, together with the Site, our “Service”).

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This Privacy Notice (“Policy”) describes the information we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information.

 

This Policy is incorporated into and is subject to the Cobalt Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Cobalt Terms of Service.

The addresses of our offices, where Cobalt Intelligence Inc. and our affiliates are located, can be found at https://www.e-cobalt.com/.

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1. Definitions

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“Client” means a customer of Cobalt.

“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.

“Personal Data” means any information relating to an identified or identifiable natural person.

“Public Area” means the area of the Site that can be accessed both by Users and Visitors without needing to log in.

“Restricted Area” means the Site area that can be accessed only by Users and where access requires logging in.

“User” means an employee, agent, or representative of a Client who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.

“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.

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2. Roles & Responsibilities

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Cobalt is the controller of your Personal Data, as described in this Privacy Notice unless otherwise stated.

Please note that this Privacy Notice does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role such as a “service provider” in certain jurisdictions) on behalf of our Clients, including where we offer to our Clients various cloud products and services, through which our Clients (and/or their affiliates) connect their own websites and applications to our hosted platform, sell or offer their own products and services, send electronic communications to other individuals, or otherwise collect, use, share or process Personal Data via our cloud products and services. In such cases, Cobalt does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. The Client or the User is the data controller under the Regulation for any Client Data containing Personal Data.

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For detailed privacy information applicable to situations where a Cobalt Client (and/or a Client affiliate) who uses Cobalt’s cloud products and services is the controller, please contact the respective Client directly. We are not responsible for the privacy or data security practices of our Clients, which may differ from those outlined in this Privacy Notice. If not stated otherwise either in this Privacy Notice or in a separate disclosure, we process such Personal Data in the role of a processor or service provider on behalf of a Client (and/or its affiliates), who is the responsible controller of the applicable Personal Data.

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If your Personal Data has been submitted to us by or on behalf of a Cobalt Client and you wish to exercise any rights you may have under applicable data protection laws; please inquire with the applicable Client directly.

Cobalt is mainly unaware of what Client Data is being stored or made available by a Client or User to the Service and only directly access such Client Data as authorized by the Client or as necessary to provide Services to the Client and its Users.

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Except as provided in this Privacy Notice, Cobalt does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third-party Sub-processors who may process such data on behalf of Cobalt in connection with Cobalt’s provision of Services to Clients.

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Cobalt is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its sub-processors servers) at the discretion of the Client or User, nor is Cobalt responsible for how the Client or User collects, handles disclosure, distributes or otherwise processes such information.

 

3. The Information We Collect

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We collect different types of information from or through the Service.

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3.1 Information you provide directly to Cobalt

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• Account signup: When you sign up for an account to access one or more of our services, we ask for information like your name, contact number, email address, organization name and country to complete the account signup process. You may also provide us with more information, such as your photo, time zone and language, but we don’t require that information to sign up for an account.

• Event registrations and other form submissions: We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download any product, whitepaper, or other materials, (iv) participate in contests or respond to surveys, or (v) submit a form to request customer support or to contact Cobalt for any other purpose.

• Payment processing: When you buy something from us, we ask you to provide your name, contact information, credit card information or other payment account information. When you submit your card information, we store the name and address of the cardholder, the expiry date and the last four digits of the credit card number. We do not store the actual credit card number. For quick processing of future payments, if you have given us your approval, we may store your credit card information or other payment information in an encrypted format in the secured servers of our Payment Gateway Service Providers

• Testimonials: When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, contact us at info@e-cobalt.com.

• Interactions with Cobalt: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, to improve our interactions with you and other customers

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3.2 Information Collected by Clients

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A Client or User may store or upload Client Data into the Service. Cobalt has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its users, contacts and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.

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3.3 Automatically Collected Information

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• Information from browsers, devices and servers: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about website visitors.

• Information from cookies and tracking technologies: We use temporary and permanent cookies to identify users of our services and to enhance user experience. We embed unique identifiers in our downloadable products to track usage of the products. We also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information about visitors and users, understand email campaign effectiveness and target visitor and user engagement by tracking your activities on our websites. You can learn more about the cookies used on our websites here.

• Information from application logs and mobile analytics: We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools and use it to understand how your use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.

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3.4 Information that we collect from third parties

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• Signups using federated authentication service providers: You can log in to Cobalt Services using supported federated authentication service providers such as Microsoft and Google. These services will authenticate your identity and allow you to share certain personal information with us, such as your name and email address. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.

• Referrals: If someone has referred any of our products or services to you through our referral programs, that person may have provided us with your name, email address and other personal information. You may contact us at privacy@e-cobalt.com to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason it was provided to us.

• Information from our reselling partners and service providers: If you contact any of our reselling partners or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to Cobalt. If you register for or attend an event sponsored by Cobalt, the event organizer may share your information with us. Cobalt may also receive information about you from review sites if you comment on any review of our products and services and from other third-party service providers that we engage for marketing our products and services.

• Information we collect and process when you integrate the Service with third parties: You may connect third-party integrations to your Cobalt account, which may ask for certain permissions to access data or send information to or from your Cobalt account. It is your responsibility to review any third-party integrations you authorize. We may collect information about what types of integrations you use in your Cobalt account. Any permission(s) granted by you grants these third parties access to your data, which may include (but is not limited to) granting third-party applications access to view, store, and modify your Cobalt account data. We are not responsible for the practices of third-party integrations, so please carefully review the permissions you grant to third-party applications. For more information on integrations with third-party providers, please see here.

• Information from social media sites and other publicly available sources: When you provide feedback or reviews about our products, interact, or engage with us on marketplaces, review sites or social media sites such as Facebook, Twitter, LinkedIn and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, better understand user reactions and issues, or to reproduce and publish your feedback on our websites. Once collected, this information may remain with us even if you delete it from these sites. Cobalt may also add and update information about you from other publicly available sources.

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4. How We Use the Information We Collect

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We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:

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4.1 Operations

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We use the information – other than Client Data - to operate, maintain, enhance and provide all Service features.

• To set up and maintain your account and to do all other things required for providing our services, such as enabling collaboration, providing website and email hosting, and backing up and restoring your data;

• To provide customer support and to analyze and improve our interactions with customers;

• To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Cobalt, Cobalt's users, third parties and the public.

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We process Client Data solely in accordance with the directions provided by the applicable Client or User.

 

4.2 Improvements

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We use the information:

• To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;

• To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;

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Should this purpose require Cobalt to process Client Data, then the data will only be used in anonymized or aggregated form.

 

4.3 Communications

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In addition to the purposes mentioned above, we may use your information for the following purposes:

• To communicate with you (such as through email) about products and materials that you have downloaded and services that you have signed up for, changes to this Privacy Notice changes to the Terms of Service, or important notices;

• To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;

• To ask you to participate in surveys or to solicit feedback on our products and services;

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4.4 Analytics

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• To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;

• To monitor and improve marketing campaigns and make suggestions relevant to the user.

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4.5 Legal Bases for Processing Personal Data (for the United Kingdom and European Economic Area and other relevant jurisdictions)

 

If you are an individual in the United Kingdom, the European Economic Area (EEA), or of another relevant jurisdiction, we collect and process information about you only where we have a legal basis or bases for doing so under applicable laws. The legal bases depend on the products and services your organization has purchased from Cobalt, how such products and services are used, how you choose to interact and communicate with Cobalt’s website systems, and whether you attend Cobalt events. This means we collect and use your Personal Data only where:

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• We need it to operate and provide you with our products and services, provide customer support and personalized features, and protect the safety and security of our products and services;

• It satisfies a legitimate interest of Cobalt’s (which is not overridden by your data protection interests and rights), such as for research and development, to provide information to you about our products and services that we believe you and your organization may find helpful, and to protect our legal rights and interests;

• You give us consent to do so for a specific purpose; or

• We need to comply with a legal obligation.

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Where we rely on legitimate interests to process your Personal Data, you can object to that processing described below under “Your Choices.” In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds or the processing is necessary in the context of legal claims. Cobalt may also process other information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Cobalt’s use of your Personal Data for this purpose at any time.

 

4.6 Additional Limits on Use of Your Google User Data

 

Cobalt’s use of information received and Cobalt’s transfer of information to any other app from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

 

5. To Whom We Disclose Information

 

Except as described in this Notice, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

 

5.1 Unrestricted Information

 

Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.

 

5.2 Other Users in Your Company Account

 

Certain information about your use of the Cobalt Services is available to the administrator(s) of your Cobalt Account and, depending on the settings chosen by the Users of the Account, also to other Users to provide the Cobalt Services.

 

5.3 Service Providers

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We work with third-party service providers who provide website, application development, hosting, maintenance, security and fraud detection, and other services for us. These third parties may have access to or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to what is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information. 

 

5.4 Cobalt Communities, Marketplace and Other User-Generated Content

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We make available various community forums and self-help support materials, as well as blogs and other means for you to post information on our websites. This information you post is publicly available information you choose to disclose, and it may be read, collected, and processed by others who visit these websites. Except for your username (which may be your real name) and the details you choose to include in your profile, the categories of data disclosed in these circumstances will depend on what information you provide. Your posts and certain profile information may remain even after you terminate your Cobalt account. We urge you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information posted on the websites if you so request, as described in Section 10, "Your Choices" below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

 

5.5 Social Media

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Cobalt’s websites may use social media features, such as the Facebook “like” button, LinkedIn and Twitter sharing features, and other similar widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share content with others within your network. Social Media Features are either hosted by the respective social media network, or hosted directly on our websites. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website, the latter may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile. Your interactions with Social Media Features are governed by the privacy policies (and any other applicable terms) of the respective companies that provide the relevant Social Media Features.

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5.7 Partners

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We may share data with trusted Cobalt partners to contact you based on your request to receive such communications, help us perform statistical analysis, provide sales support, or provide customer support. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data. We partner with trusted third parties to provide content that may be relevant to you. When you engage with these partners, we will tell you who we are sharing data with and provide a link to the partner’s privacy policy so you can learn how to opt out of the partner’s communications. These partners are required to adhere to our privacy and data protection policies. For more information on our partner program, see (To be added when available). If you do not want us to share your Personal Data with these companies, please contact our partner's team at partners@e-cobalt.com

 

5.8 Non Personally Identifiable Information

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We may make certain automatically collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service, all of the foregoing being subject to additional limits on use of your data as stated in this Privacy Notice.

 

5.9 Legal Process and Compliance

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We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

 

5.10 Change of Ownership

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Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or Visitor Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Notice.

Client Data may be physically or electronically transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Client Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Notice.

 

6. Data Security

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At Cobalt, we take data security very seriously. We have implemented appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. These measures have been audited and certified to industry standards. However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and other authentication factors, as well as maintaining the security of your devices. If you believe your Personal Data has been compromised, please contact us as outlined in the “Contact Us” section. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

 

7. International Data Transfers

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Cobalt may transfer your Personal Data, for example, when sending notifications like SMS and emails, to countries other than where you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, Cobalt will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with Cobalt’s obligations.

 

8. Minors and Children’s Privacy

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Protecting the privacy of young children is especially important. Our Service is not directed nor intended for children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 has obtained an Account on the Service, you may alert us at privacy@e-cobalt.com and request that we delete that child’s Personal Data from our systems.

 

9. Data Retention

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We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

For Cobalt Service:

• the contents of closed accounts are deleted within 180 days of the date of closure;

• the content of closed Free Trial Accounts are deleted within 60 days of the date of closure;

• server archival backups are kept for 90 days.

 

10. Your Choices

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10.1 Your rights concerning the information we hold about you as a controller

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• Right to access – you have the right to know which data we hold about you (if any).

• Right to data rectification – you have the right to require corrections to your Personal Data in case they are inaccurate or incomplete.

• Right to data deletion – you have the right under certain conditions to request the deletion of your Personal Data, including in situations where the processing of your Personal Data is no longer necessary for the purposes for which it was collected or if the processing of your Personal Data was based on your consent and you wish to withdraw your consent, and there are no other grounds for processing your Personal Data.

• Right to restriction of processing – You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Right to data portability – You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format in circumstances where the information is processed with your consent or by automated means.

• Right to object – You have the right to object to the use of your information in certain circumstances, such as the use of your personal data for direct marketing.

• Right to complain – You have the right to complain to the appropriate supervisory authority if you have any grievance against how we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

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We respect your privacy rights and provide you with reasonable access to the Personal Data you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you or to request that we delete or transfer any information we have obtained from an Integrated Service, you may contact us as outlined in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database. Additionally,

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• You may update, correct, or delete your Account information and preferences anytime by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

• You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.

• Optional information: You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information.

• You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.

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At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Cobalt’s Data Protection Officer at privacy@e-cobalt.com.

 

10.2 Navigation Information

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You may opt-out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature. You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.

 

10.3 Opting out of Commercial Communications

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You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages or by sending an email to the address provided in the “How to Contact Us” section. Please note that you will continue to receive essential notices and emails such as account notification emails (password change, renewal reminders, etc.), security incident alerts, security and privacy update notifications, and essential transactional and payment-related emails. Users are able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the “Account functionality” tab on the Service.

 

10.4 Information processed on Cobalt Client’s behalf

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Cobalt has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of the Client. An individual who seeks access or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly.

Cobalt Clients can delete, amend or block access to any Personal Data inside the Cobalt application or by contacting Cobalt Support.

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11. Do Not Track (DNT) requests

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Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit, indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.

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In the meantime, you may opt out of receiving interest-based advertising from advertising networks by visiting the following websites: http://www.aboutads.info/consumers and http://www.networkadvertising.org. This will opt you out of many – but not all - of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device-specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices.

 

12. Changes and Updates to this Notice

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Please revisit this page periodically to stay aware of any changes to this Notice, which we may update from time to time. If we modify the Notice, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Notice has become effective indicates that you have read, understood and agreed to the current version of the Notice.

 

13. How to Contact Us

 

Please contact us with any questions or comments about this Notice, your Personal Data, our use and disclosure practices, or your consent choices by email at privacy@e-cobalt.com. If you have any concerns or complaints about this Notice or your Personal Data, you may contact Cobalt’s Data Protection Officer by email at privacy@e-cobalt.com.

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