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CoralTree, Inc. 

PRIVACY POLICY

Last Updated: May 16, 2024

This Privacy Policy (the “Policy”) describes the privacy practices for CoralTree, Inc. (“CoralTree”, “us”, “we”) and the ways we collect, store, use, and protect your personal and non-personal information on our websites which link to this Policy including, without limitation, www.coraltreetech.com, and all of the products and services contained on those websites (the “Website”).

CoralTree offers cloud-enabled software solutions Basil and Qbox, which are designed to provide real-time cloud-based collaboration, and cloud enabled collaboration for desktop software like Intuit QuickBooks, Microsoft Office products, and Autodesk CAD products (collectively the “Services”). The Services can be accessed through our Website, applications on Devices and through third parties. A “Device” is any computer used to access the Services, including without limitation, a desktop, laptop, mobile phone, tablet, or other consumer electronic device.

This Policy governs your access to the Services regardless of how you access them, and by using our services you consent to the collection, transfer, processing, storage, disclosure, and other uses described in this Policy.

For questions or feedback on this Policy or our privacy practices, please email us at support@coraltreetech.com.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for you to access our Service or parts of our Service.
  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to CoralTree, Inc., 6920 Santa Teresa Blvd. #201, San Jose, CA 95119.

For the purpose of the GDPR, the Company is the Data Controller.

  • Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

  • Sale, for the purpose of the CCPA (California Consumer Privacy Act), 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 to another business or a third party for monetary or other valuable consideration.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), you can be referred to as the Data Subject or as the User as you are the individual using the Service.

 

A. INFORMATION WE COLLECT AND CONTROL

All of the different forms of data, content, and information described below are collectively referred to as “Information.”  We may collect and store the following Information when you access the Services:

  1. Information you provide:

    Personal information
    When you register for an account, we collect some personal information, including your name, email address, home or business address, phone number. This information is stored in databases hosted by Amazon AWS services. We use information to create your account for the Service you register and for the purpose of contacting you for providing technical support related to the Services. We also collect your credit card or bank account details. This information is stored on BrainTree payment processing service whom we use for processing your payments for CoralTree services availed.  We collect information from individuals who visit the Website (“Visitors”). You do not need to register for a Service in order to review the content on the Website as a Visitor. The information described in this paragraph is referred to collectively as “Personal Information”.

    Non-personal information
    We collect email addresses (optional) of people whom you can assign to pay your CoralTree bills, and email addresses of people with whom you share your files or offer consulting services. We collect information related to your business type, number of employees and revenue of your business, which are optional. We use this information for gathering market data and deciding future product offerings. This information is stored in databases hosted by Amazon AWS services.  The information described in this paragraph is referred to collectively as “Non-Personal Information”.  Personal Information and Non-Personal Information are referred to collectively as “Information”.
  1. Information collected automatically
    We collect information related to your Device and its software when using the Services automatically, and store it in databases hosted by Amazon AWS. This information includes Internet Protocol IP address, type of operating system, number of folders and files that are shared, names of folder and files, upload and download status, history of versions of files, configuration information of the Services software installed on your Device, times at which the software accessed server software, number of messages sent by you or your clients, and times at which these messages were sent. We use this information for the purpose of diagnostics and troubleshooting, to be able to provide quality support to our customers.

    As is true of most websites, we gather certain non-personally identifiable information from your Device and its software when using the Services automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, information you search for on our Website, your mobile carrier, operating system and system configuration information, date/time stamp, click stream data and other fields. We use this information to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole

  2. Files:
    We collect and store the computer files you upload, download, or access with the Services (“Files”). These files are stored on Amazon AWS S3 storage services. Your files can be downloaded and accessed by the users with whom you share the folders containing the files, by providing their email address on our Service.

  3. Tracking Technologies and Cookies:
    We use Cookies and similar tracking technologies to track the activity on the Services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the Services The technologies We use may include:

      • Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
      • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how you can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
      • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

      Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. Learn more about cookies: Use of Cookies by Free Privacy Policy.

    • We use both Session and Persistent Cookies for the purposes set out below:
      • Necessary / Essential Cookies
        Type: Session Cookies
        Administered by: Us
        Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you with those services.
      • Cookies Policy / Notice Acceptance Cookies
        Type: Persistent Cookies
        Administered by: Us
        Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
      • Functionality Cookies
        Type: Persistent Cookies
        Administered by: Us
        Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
      • Tracking and Performance Cookies
        Type: Persistent Cookies
        Administered by: Third-Parties
        Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

  4. Testimonials:

    We collect testimonials and video clips from our customers who are willing to provide such information and have given us permission to display them at our Websites. These are stored on HubSpot systems where our Websites are hosted.


B. HOW WE USE INFORMATION

In addition to those uses of Information discussed in Section A of this Policy, we also use Information in the following ways:

  1. Personal Information:
    Personal Information including name, email address, phone number, and address may be used: (i) to set up your account with the Service you registered (ii) provide and improve our Services, (iii) to better understand your needs and interests, and (iv) to personalize and improve your experience while using the Service.
  1. Service-related notifications for Customers:
    We will send you notification related to the Services as necessary to administer your use of the Services. For example, we will send you email notification when your account is setup, a password is required to be sent, or when a bill has become due. We will send you email notifications as we add software updates to our Services. These emails are necessary for the maintenance of your account with us and cannot be disabled as long as your account is active. If you do not wish to receive such Service-related notifications and wish to cancel your service, please follow instructions given under section H of this Privacy Policy.
  1. Business Information:
    Customers use our Services to upload and share computer files that may contain business data, financial information, project data, architectural designs, etc., related to their business (“Business Information”). That Business Information is considered confidential to our Customers. CoralTree will not review, share, distribute, or reference any such Business Information except for the purpose of resolving a problem, providing customer support or to investigate a suspected violation of our business agreement.
  1. Billing Information:
    All billing information like credit card and bank details, that we collect is used solely to bill for our Services. CoralTree uses a third party credit card processor (BrainTree) to assist us in processing customer payments. This processing partner is not permitted to store, retain, or use the personally identifiable information provided, except for the sole purpose of credit card processing or collecting payments.
  1. Special Offers and Updates:
    We will occasionally send Visitors and Customers new information regarding our Website, webinars, or new product offerings. We will use your Personal Information to send these communications to you. Out of respect for your privacy, if you would prefer not to hear from us you can choose not to receive these types of communications. Please see Section G. below.
  1. Testimonials:
    Testimonials provided to us in text form and video clips by customers are stored on HubSpot and displayed on our websites. These can be viewed by registered users and visitors to our websites. 
  1. Webinars:
    We conduct periodic webinars for users who register by providing their Personal Information including email address, name, phone number, and location. We conduct these webinars using the service offered by Zoom, and such Personal Information is stored on Zoom website for sending Webinar related information and reminders. If you do not wish to receive such Webinar related information, you can opt-out by following instructions given in each communication or by sending us an email at support@coraltreetech.com.
  1. Email Marketing:
    We may use your Personal Data to contact you with newsletters, marketing, or promotional materials, and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
    We may use Email Marketing Service Providers to manage and send emails to you.
  1. Behavioral Remarketing
    The Company uses remarketing services to advertise to you after you accessed or visited our Service. We and our third-party vendors use cookies and non-cookie technologies to help us recognize your Device and understand how you use our Service so that we can improve our Service to reflect your interests and serve you advertisements that are likely to be of more interest to you.

    These third-party vendors collect, store, use, process, and transfer information about your activity on our Service in accordance with their Privacy Policies and to enable us to:
    • Measure and analyze traffic and browsing activity on our Service
    • Show advertisements for our products and/or services to you on third-party websites or apps
    • Measure and analyze the performance of our advertising campaigns

    Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:

  • You may opt-out of all personalized advertising by enabling privacy features on your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See your mobile device Help system for more information.

    We may share information, such as hashed email addresses (if available) or other online identifiers collected on our Service with these third-party vendors. This allows our third-party vendors to recognize and deliver you ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

    The third-party vendors we use are:

 

C. WHERE IS INFORMATION STORED

  1. Amazon Web Services
    We use Amazon Web Services (AWS) to store and process Personal Information. Personal information is stored in databases hosted by AWS. Computer files uploaded and downloaded by customers are stored on AWS S3 services. Amazon Web Services may store this information in any of their data centers located around the world and have contractual obligations and privacy policies to protect Personal and Business Information. Please refer to AWS privacy policies for details on how information is protected on their data centers.
  1. Braintree
    We use BrainTree to process payments for Services. Personal Information including credit card details, customer name and address, bank information, etc. are stored on BrainTree payment gateway for the purpose of processing payments. Please refer to BrainTree privacy policies for details on how Personal Information is protected on their payment gateways. 
  1. ZOHO
    We use ZOHO for CRM, customer support, chats, email campaigns, promotions, visitor tracking and analytics. Personal and Non-personal Information including email addresses, phone numbers, contact information, and company information are stored on Zoho. Please refer to Zoho privacy policies for details on how Personal Information is protected on Zoho services.

  2. Zoom
    We use Zoom for Webinars and customer support. Personal information including email address, name, phone number and location are stored on Zoom. Please refer to Zoom privacy policies for details on how Personal Information is protected on Zoom websites.
  1. WPengine
    We use WPengine for hosting CoralTree, Inc and our Services websites. Personal Information such as email address, name, phone number, and address, testimonials, video clips, and other such information are stored on WPengine. Please refer to WPengine privacy policies for details on how Personal Information is protected on WPEngine.
  1. HubSpot
    We use HubSpot for CRM, customer support, chats, email campaigns, promotions, visitor tracking, analytics, and for hosting CoralTree, Inc and our Services websites. Personal and Non-personal Information including email addresses, phone numbers, contact information, and company information are stored on HubSpot. Please refer to HubSpot Privacy Policies for details on how Personal Information is protected on HubSpot services.
  1. MailChimp
    We use MailChimp for email campaigns, promotions, newsletters, and product updates. Personal and Non-personal Information including email addresses, phone numbers, contact information and company information are stored on MailChimp. Please refer to MailChimp Privacy Policies for details on how Personal Information is protected on MailChimp services. 
  1. White-Label
    Users of our Services are permitted to upload their company logo, and any relevant colors or names, which will be displayed in their accounts.

    Emails sent from a user’s account will include that user’s uploaded company logo, and any other account information they choose to share. Users are solely responsible for the content they upload onto and share through their accounts, and represent and warrant that they own all right, title, and interest in and to such content. We are not liable for any content you upload to or share through your account, and you consent not to misuse or duplicate another user’s content and/or assets without their explicit consent. 
  1. Outreach.io
    We utilize Outreach.io, a Sales Engagement platform, to manage customer interactions and streamline our sales processes. Outreach.io stores customer data you provide us, such as contact information and communication history. They act as a processor for this data, adhering to strict privacy standards. Outreach.io is GDPR and CCPA compliant, and they neither sell nor share your data with third-parties beyond those needed to deliver their service. You can refer to Outreach’s Privacy Policies for details on how Personal Information is protected. 

 

D. WHO HAS ACCESS TO INFORMATION

CoralTree entities listed in this section have access to Personal Information and Non-Personal Information you provide (A1) and information collected automatically (A2). We do not sell any of your Personal Information or Non-Personal Information. Entities listed in this section adhere to confidentiality and security measures, have been made aware of our Privacy policies and have executed non-disclosure agreements with CoralTree, Inc.

  1. Employees and Independent contractors
    Employees and Independent contractors of CoralTree have access to the information listed under A1 and A2, on a need-to-know basis, for the purpose of software development, testing, diagnostics, bug fixing, customer support, and other such purposes. Employees and Independent contractors are covered by and adhere to this Privacy Policy.
  1. Business partners
    We provide access to some of the Information listed under A1 and A2 for our business partners who have executed the required confidentiality agreements with us, for the purpose of testing and support of the CoralTree products. These business partners are not permitted to retain, share, store, or use your Information for any purpose other than to complete the contracted assignment and under obligations similar to those in this Policy.
  1. Third Parties:
    We may employ or use trusted third parties to act on our behalf for our Services, including but not limited to providing marketing support, analysis, and public relations. These third parties may have access to your Information. However, such third parties are not permitted to retain, share, store, or use your Information for any other purpose other than to complete the contracted assignment, and under obligations similar to those in this Policy. From time to time, we may provide services, or sell product lines jointly with selected business partners. We DO NOT share Personal Information with third parties for unknown reasons.

 

E. LEGAL DISCLAIMER

We reserve the right to disclose your Information, when we have a good faith belief that disclosure is reasonably necessary to:

  1. Protect our rights;
  2. Comply with a law, regulation, judicial proceeding, court order, or legal process served on us;
  3. Protect the safety of any person from death or serious bodily injury;
  4. Prevent fraud or abuse of CoralTree or its Customers.

 

F. CHOICE AND OPT-OUT

If you no longer wish to receive our communications outside those communications necessary for the administration of your use of the Services, you may opt-out of receiving such communications by following the instructions included in each communication or by emailing us at support@coraltreetech.com. You may also opt-out by phone at 408-448-QBOX (7269) or 855-448-QBOX (7269) Toll Free.

 

G. CHANGES TO PERSONAL INFORMATION

If your Personal Information changes, you may correct or update it on our website by signing into your account and editing such Personal Information using the edit controls provided.

 

H. DATA RETENTION

We will retain your Information for as long as your CoralTree Services account is active or as needed to provide you Services. If you wish to cancel your account or request that we no longer use your Information to provide you Services, you may delete your account by signing into your account at the CoralTree Services website and selecting ‘Close Account’, or by sending an email to support@coraltreetech.com.

In most cases we will close your account within 48 hours of your request. In some cases, we may close your account after validating your request to avoid erroneous closures resulting in the loss of Business Information. After your account is closed, files uploaded to your account will be deleted after 30 days, if there are no other users sharing and using these files.

 

I. OUR POLICY TOWARD CHILDREN

Our Services are not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at support@coraltreetech.com. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information from our files.

 

J. CHANGES TO THE POLICY

We reserve the right to modify this Policy at any time. If we make material changes to this Policy, we will notify you here and also, as necessary via email. By continuing to use the Services after those changes become effective, you agree to be bound by the revised Policy.

 

K. SECURITY AND INTEGRITY

The security, integrity, and confidentiality of your Information is extremely important to us. We utilize robust security measures to protect Personal Data and Personal Information from unauthorized access. Your Information and Personal Data will be stored on a secure and dedicated third-party cloud storage or on cloud storage owned and maintained by Us.

We strive to implement and maintain reasonable, industry-standard secure storage technologies, and commercially acceptable procedures and practices appropriate to the Information and Personal Data we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. Sensitive data is encrypted and web site connections are protected using secure socket layer (SSL) technology with a minimum of 128-bit symmetric encryption and a 1024-bit authenticated key agreement. Our Websites are hosted in a secure server environment that uses multi-layer perimeter security including firewalls and other advanced technology to prevent interference or access from outside intruders.

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee the absolute security of your Information or Personal Data, or guarantee that Information and/or Personal Data on the Services may not be accessed, disclosed, altered, or destroyed by unauthorized persons, or hardware or software failure. Further, please be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure. We are unable to guarantee the absolute security of the Information we collected from you, and/or your Personal Data.

Our users, employees, and partners also play an important role in protecting your Information and Personal Data. We encourage users to choose passwords and other forms of user credentials for authentication that are difficult for others to guess and to keep their personal passwords and credentials secret.

Our users are solely responsible for their interactions with other users. A user understands that We do not make criminal checks or otherwise inquire into the background of users.

Should you notice any flaws or concerns in our security, please contact Us at support@coraltreetech.com. If we ever experience a data breach in which Information and/or Personal Data is at risk of being misused, we will contact users according to legal requirements. If necessary, we will also contact data protection authorities.

 

L. EXTERNAL LINKS

Our Website may contain links to third party websites. These third-party websites maintain their own policies regarding cookies and the collection and use of your Information. We assume no responsibility or liability for the actions of such third parties with respect to their collection or use of your Information. We encourage you to read the privacy statements of every website that you visit through a link on our Website or otherwise.

 

M. BUSINESS TRANSITIONS

In the event CoralTree goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be among the assets transferred as part of that transaction. We will notify you (for example, via email or a prominent notice on our Website) of any change in use or control of your Information or Files, or if either becomes subject to a different privacy policy.

 

N. DATA TRANSFERS, STORAGE, AND PROCESSING GLOBALLY

We may transfer your Personal Information to third parties in locations around the world for the purposes described in this Policy. We may use third-party service providers to process and store your information in the United States, Canada, Japan, the European Union, and in other jurisdictions.

Information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Whenever your Personal Information is transferred, stored, or processed by us or by companies carrying out such services on our behalf, we will take reasonable steps to safeguard the privacy of your Personal Information.

We will make sure we, as a minimum, use the standards of data privacy and security that follows from the European General Data Protection Regulation (“GDPR”) anywhere in the world where we collect, store, use, or share your Personal Information. Where your local rules require more from us than the GDPR, we will adjust our practices to make sure your Information is safe with us no matter what. The rules set by European data authorities across the European Union set some of the highest standards in the world on Information collection, storage, use, and sharing.

 

O. ADVERTISEMENTS

Advertisements appearing on any of our Websites and/or Services may be delivered to users by advertising partners, who may set cookies. These cookies allow the advertisement server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows advertising networks to, among other things, deliver targeted advertisements that they believe will be of most interest. This Policy covers the use of cookies by Us and does not cover the use of cookies by any advertisers.

 

P. TELEPHONE CALLS

The CoralTree’s sales team makes calls to prospects and the calls are recorded strictly for internal training purposes, unless the person on the other end tells us not to record the call.


Q. GDPR PRIVACY
Legal Basis for Processing Personal Data under GDPR


We may process Personal Data and Personal Information under GDPR under following conditions:

  • Consent: you have given your consent for processing Personal Data and/or Personal Information for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data and/or Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data and/or Personal Information is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data and/or Personal Information is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing Personal Data and/or Personal Information is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data and/or Personal Information is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data and/or Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR
The Company undertakes to respect the confidentiality of your Personal Data and Personal Information, and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your Personal Data and/or Personal Information. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data and/or Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data and Personal Information we hold about you.
  • Request correction of the Personal Data and/or Personal Information  that We hold about you. You have the right to have any incomplete or inaccurate information We hold about you corrected.
  • Object to processing of your Personal Data and/or Personal Information. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data and/or Personal Information on this ground. You also have the right to object where we are processing your Personal Data and/or Personal Information for direct marketing purposes.
  • Request erasure of your Personal Data and/or Personal Information. You have the right to ask us to delete or remove Personal Data and/or Personal Information when there is no good reason for us to continue processing it.
  • Request the transfer of your Personal Data and/or Personal Information. We will provide to you, or to a third-party you have chosen, your Personal Data and/or Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where We used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your Personal Data and/or Personal Information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising of your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

R. NOTICE TO CALIFORNIA RESIDENTS

If you are a California resident, you are permitted by California Civil Code §1798.83 to request information regarding the disclosure of your Personal Information and/or Personal Data by us to third parties for the third parties’ direct marketing purposes. With respect to these entities, this Policy applies only to their activities within the State of California.

S. CCPA PRIVACY

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of Personal Information and/or Personal Data were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Information and/or Personal Data would only be collected if you provided such personal information directly to us.

  • Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

  • Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

  • Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

  • Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

  • Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

  • Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

  • Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

  • Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

  • Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from the forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.
  • Indirectly from you. For example, from observing your activity on our Service.
  • Automatically from you. For example, through cookies we or our Service Providers set on your Device as you navigate through our Service.
  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to deliver targeted advertising to you, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to you.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

  • To operate our Service and provide you with our Service.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Service.
  • To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. 

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes UNDER CCPA

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean 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 business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Share of Personal Information

We may share your Personal information and/or Personal Data identified in the above categories with the following categories of third parties:

  • Service Providers
  • Payment processors
  • Our affiliates
  • Our business partners
  • Third party vendors to whom you or your agents authorize Us to disclose your personal information in connection with products or services We provide to you.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

T. CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)

This privacy notice section for California residents supplements this Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their Personal Data and Personal Information. If you are a resident of California, you have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Information and/or Personal Data are being collected, and the purposes for which the Personal Information and/or Personal Data is being used.
  • The right to request. Under CCPA, you have the right to request that We disclose information to you about Our collection, use, sale, disclosure for business purposes and sharing of Personal Information and/or Personal Data. Once we receive and confirm your request, we will disclose to you:
    • The categories of Personal Information and/or Personal Data we collected about you;
    • The categories of sources for the Personal Information and/or Personal Data we collected about you;
    • Our business or commercial purpose for collecting or selling that Personal Information and/or Personal Data;
    • The categories of third parties with whom we share that Personal Information and/or Personal Data;
    • The specific pieces of Personal Information and/or Personal Data we collected about you;
    • If we sold your Personal Information and/or Personal Data or disclosed your Personal information and/or Personal Data for a business purpose, we will disclose to you:
      • The categories of Personal Information and/or Personal Data categories sold
      • The categories of Personal Information and/or Personal Data categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell your Personal Data and/or Personal Information. To submit an opt-out request please contact us. Once we receive and confirm a verifiable consumer request from you, we will stop selling your Personal Information.
  • The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
    • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:
    • Denying goods or services to you
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to you
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact Us:

  • By email: support@coraltreetech.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Data and/or Personal Information.

Your request to Us must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom We collected personal information or an authorized representative
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

  • Verify your identity or authority to make the request
  • And confirm that the Personal Information and/or Personal Data relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of your personal information. Once We receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Website

You can opt out of receiving advertisements that are personalized as served by our Service Providers by following our instructions presented on the Service:

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

You may access our Services through a Mobile app downloadable on both iOS and Android phones. This Privacy Policy governs your use of our Mobile app and any Services you access and use through it.

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.


U. CANADIAN PRIVACY POLICY

We do business in Canada, meaning that we sell products and services to entities and individuals residing within Canada, which may require personal information to cross international and intranational borders. As such, we comply with all applicable federal, provincial, and municipal laws and regulations regarding what we can and cannot do with your personal information in Canada.


V. APPLICABLE CANADIAN PRIVACY LAWS

Regarding what we can and cannot do with your personal information, we are compliant with the Personal Information Protection and Electronic Documents Act (PIPEDA), which is enforced by the Office of the Privacy Commissioner of Canada.

PIPEDA determines how businesses like ours handle personal information.

W. PERSONAL INFORMATION UNDER CANADIAN LAW

Personal information, as defined under PIPEDA, includes: race, national, or ethnic origin; religion; age, marital status; medical, education, or employment history; financial information; DNA; identifying numbers such as your social insurance number, or driver’s license; and views or opinions about you as an employee.

Some things that are not personal information include: information not about an individual because that connection to a person is weak; information about an organization; anonymously rendered information, unless it is possible to link said information to an identifiable person; some information about public servants, including name, position, and title; business contact information an organization collects, uses, or discloses for the sole purpose of communicating with that person relating to their employment, business, or profession; and government information.

When more than one Canadian privacy law affects us, we must comply with all applicable laws and regulations.

We may also “further consider reporting publicly on the number and types of disclosures made on an annual or semi-annual basis, using aggregate and anonymized.”


X. DISCLOSURE WITHOUT CONSENT

In Canada, although the following is not a comprehensive list, we may disclose your personal information without consent to, for example:

  1. Reporting information to a “children’s aid society” if reasonably suspected that a child needs protection
  2. If reasonable grounds exist such that disclosure is necessary to “assess, reduce, or eliminate a risk of serious harm to a person or group”
  3. To Canadian law enforcement agencies to aid investigations
  4. To legal representatives or litigations guardian for certain purposes, such as proceeding representation
  5. “To comply with a summons, order, or procedural rule relating to the production of information in a proceeding”
  6. “To contact a relative, friend, or potential substitute decision-maker” in some instances, such as when an individual is “injured or incapacitated"
Y. PIPEDA

As defined by PIPEDA, personal information is about an “identifiable individual.”

PIPEDA determines how we collect, use, and disclose personal information for commercial activities in Canada. PIPEDA’s 10 fair information principles govern our collection, use, and disclosure of your personal information in Canada.

Because we sell our products and services in Canada, your personal information may cross “provincial or national borders.” Therefore, PIPEDA applies.

Because we are a private-sector organization that is not federally regulated, PIPEDA governs our conduct within: Manitoba, New Brunswick, Newfoundland and Labrador; Northwest Territories; Nova Scotia; Nunavut; Ontario; Prince Edward Island, Saskatchewan; and Yukon. 

PIPEDA includes 10 fair information principles governing access, collection, use, and disclosure of personal information, and describes our responsibilities, including that collection, use, or disclosure of personal information must be for purposes a “reasonable person” considers appropriate. Situations where access, collection, use, and disclosure of the personal information we hold about you are inappropriate include: 

  1. Collecting, using, or disclosing personal information unlawfully;
  2.  “Profiling or categorizing individuals” leading to “unfair, unethical, or discriminatory treatment” conflicting with human rights laws; 
  3. Collecting, using, or disclosing personal information in a way known to significantly harm an individual; 
  4. Publishing personal information intending to charge people to remove it; 
  5. Requiring passwords for employee screening; and surveilling an individual using that individual’s own device.

The 10 fair information principles of PIPEDA are:

  1. Principle 1 – Accountability: we are responsible for the personal information we control, and must appoint an individual for compliance.
  • Principle 1 will not be applied overly broadly
  • Principle 1 disallows for “widespread disclosure and casual sharing”
  • Principle 1 may, under some circumstances, be limited to certain purposes and specific given conditions
  1. Principle 2 – Identifying Purposes: we must identify the reason for collecting personal information before collection or during collection.
  2. Principle 3 – Consent: except when inappropriate, “knowledge and consent” of the individual is required for collecting, use, or disclosure of person information
  3. Principle 4 – Limiting collection: personal information collection must be limited to what is required by us, and personal information must be collected fairly and lawfully
  4. Principle 5 – Limiting use, disclosure, and retention: personal information may only be used or disclosed for the purpose of its collection, and must only be held for as long as necessary to satisfy the purposes for which it was collected
  1. Principle 6 – Accuracy: personal information must be as accurate, complete, and up-to-date as possible to “satisfy the purposes for which” that personal information is to be used
  2. Principle 7 – Safeguards: Personal information is to be protected by a level of security relative to that information’s sensitivity
  3. Principle 8 – Openness: we are required to describe in detail information about our policies and practices as relating to personal information management “publicly and readily available”
  4. Principle 9 – Individual Access: When requested, individuals are to be informed of the existence, use, and disclosure of their personal information and are to be provided access to that information. Individuals have the right to challenge the personal information’s accuracy and completeness and have it amended.
  5. Principle 10 – Challenging compliance: individuals are able to challenge compliance with these principles, which “should be addressed” to the person we have appointed to be accountable for PIPEDA compliance, often designated a Chief Privacy Officer

The Office of the Privacy Commissioner of Canada (OPC) requires us to perform due diligence and practice good judgment when using an exception. We must also consider each requirement explicitly, and must respect provisional limits.

The disclosure exceptions listed here “are limited to disclosures made to other organizations,” and are not “broad exceptions” permitting disclosure without consent, which, for example, include law enforcement or the family members of clients. Paragraphs 7(3)(d.1) and 7(3)(d.2) of PIPEDA provide that we may disclose, through an exception, personal information of an individual without that individual’s knowledge or consent, and may be affected:

  1. If communicated to “another organization” and is reasonable when its purpose is to investigate an agreement breach or if there is a contravention towards Canadian laws or a Canadian province which has been, is being, or is about to be committed and if it is reasonably expected that disclosing that personal information with the individual’s knowledge or consent would “compromise the investigation”
  2. When made to “another organization” and is reasonable to detect or suppress fraud, or preventing a fraud likely to be committed and reasonable to expect that disclosure with the “knowledge or consent” of the individual would compromise prevention, detection, or suppress the fraud

Paragraphs 7(3)(d.1) and 7(3)(d.2) of PIPEDA require “responsible consideration and accountability” before making disclosures as governed by paragraphs 7(3)(d.1) and 7(3)(d.2) of PIPEDA. We must ensure the “precise requirements” set out in the aforementioned paragraphs are met and “should document” that rationale before disclosing any personal information. When requests for personal information are received, the requesting organizations’ claims are not to “be taken at ‘face value.’” The receiving organization “should take certain measures,” for example, by “asking for and documenting” rationales and natures of claims.

These disclosures of personal information must be “’reasonable for the purposes”’ specified in each provision, and must be “reasonable for the purposes of investigating a breach of an agreement or a contravention of the laws of Canada or a province that has been, is being, or is about to be contravened,” including that:

  1. Organizations must ensure that the applicable investigation relates to an agreement breach or contravention of Canadian, provincial, or territorial laws 
  2. The disclosing organization “must be satisfied” that the agreement breaching or legal contravention has “already taken place, is ongoing, or is about to happen”
  3. Investigations are defined as formal or systematic inquiries to “discover and examine” an incident’s facts to establish truth, and is not a “fishing expedition”
  4. These disclosures must be “reasonably related and proportionate” to a specific purpose and not overreach in scope

Contraventions are to be defined by Canadian laws, and do not include contraventions of foreign laws.

“It must be reasonable to expect that disclosure with the knowledge or consent of the individual concerned would compromise the activity in question.” Acting within Paragraphs 7(3)(d.1) or 7(3)(d.2) of PIPEDA, we must evaluate if it is reasonable “to expect that informing the individual concerned of the disclosure or seeking the individual’s consent to the disclosure would compromise the activity in question:”

  1. “Before disclosing personal information” under paragraph 7(3)(d.2), we must have formed a reasonable expectation that disclosure with the knowledge or consent of the individual would compromise the investigation”
  2. “Before disclosing personal information under paragraph 7(3)(d.2),” we “must have formed a reasonable expectation that the individual’s knowledge or consent would compromise the ability to prevent, detect, or suppress the fraud”

“Other relevant considerations” include:

  1. Due diligence, whereby we document and demonstrate, “on a case by case basis, the reasons why it determined that each disclosure met all of the requirements under paragraphs 7(3)(d.1) or 7(3)(d.2)). We can demonstrate “how each disclosure is reasonable for the stated purposes and why it is reasonable to expect that the disclosure with the knowledge or consent of the individual concerned would compromise the investigation or ability to detect, suppress, or prevent the fraud”
  2. Ensure accountability and openness: we have “develop[ed] policies and procedures setting out how we request and/or respond to these disclosures. We are “open about their policies and practices,” and “make them available to individuals.” Any related “policies and procedures should be accompanied with up-to-date training for employees on an on-going basis.”
  3. Identify procedures for handling access requests from individuals: individuals usually have a “right to access their personal information, including obtaining an account of the third-parties to whom their personal information has been disclosed.” We “must provide access to personal information on request, unless an exception under PIPEDA applies.”
  4. Consider all other PIPEDA requirements: we are “still required to fulfill our other PIPEDA obligations, including, but not limited to, limiting the disclosure of personal information, safeguarding it, and ensuring that any disclosure of personal information is only for purposes that a reasonable person would consider are appropriate in the circumstances”
Z. HEALTH INFORMATION

Although what we do with personal health information is governed by PIPEDA, the collection, use, access, and disclosure of your personal health information may also be governed by different privacy laws, including those established federally by the Office of the Privacy Commissioner of Canada (OPC); provincial private-sector privacy legislations; federal, provincial, and territorial public-sector organizations; and particular health information protection laws.

In addition to PIPEDA and the laws of Alberta, British Columbia, and Quebec, we follow the laws and regulations of the following provinces, which have enacted similar laws regarding your personal health information, including: New Brunswick’s Personal Health Information Privacy and Access Act; Newfoundland’s and Labrador’s Personal Health Information Act; Nova Scotia’s Personal Health Information Act; and Ontario’s Health Information Protection Act. 

Regarding our collection, use, disclosure, retention, and destruction of personal health information, please first directly contact us. If questioning whether a privacy law would apply, you may consider contacting the Office of the Privacy Commissioner’s Information Centre. 

 

AA. PRIVACY LAWS AND OVERSIGHT

When we do business in Canadian territories and provinces, we follow those individual territories’ and provinces’ local laws governing personal information use, disclosure, sale, and collection in the private and public sector that “may apply instead of PIPEDA,” or in addition to PIPEDA.

Although non-comprehensive, the following is a list of some individual territories’ and provinces’ local laws :

  1. In Alberta, we comply with the Personal Information Protection Act, which is “substantially similar” to PIPEDA
  2. In British Columbia, we comply with the Personal Information Protection Act, governing the private sector
  3. In Nova Scotia, we comply with the Personal Information International Disclosure Protection Act.
  4. In Quebec. we comply with the Act Respecting the Protection of Personal Information in the Public Sector, governing the private sector

BB. EMPLOYEE INFORMATION

In Alberta and British Columbia, we comply with the additional privacy laws enacted there applying to “employee information.”

CC. SECTOR PRIVACY LAWS

We comply with the FCAC, which governs “payment card network operators” to determine compliance with the Payment Card Networks Act and the Code of Conduct for Credit and Debit Card Industry. Payment card network operators operating in Canada include: American Express; Discover: Interact; MasterCard; Visa; The Exchange; UnionPay.

DD. UK GENERAL DATA PROTECTION REGULATION

In the UK, we comply with a version of the GDPR, which has been maintained in the UK as the UK GDPR, and which operates together with the Data Protection Act of 2018 and the Privacy and Electronic Communications Regulations (PECR), which all govern the “processing of personal data from individuals located inside the United Kingdom.”

Because the EU Commission adopted “adequacy decisions” for the UK GDPR and the Law Enforcement Directive, information may “continue to flow freely from the EU to the UK.” Data transferred “from the EU to the UK” regarding UK immigration control is subject to the “immigrant exemption in the Data Protection Act 2018,” which allows us an exemption from certain people’s personal information protection rights if they prejudice “immigration control” or the “detection of activities that undermine immigration control.”

If we have an office, branch, or established presence in the EEA, or have customers located there, we will comply with both UK and EU data protection regulations regarding personal information. As required by applicable laws and regulations, we have designated an EEA representative, which is a “person, company, or organization that represents an individual or organization regarding their obligations under the GDPR,” who acts as our “public face” and “acts as a local contact for data subjects and supervisory authorities,” including “about any issues relating to the processing of personal” information.  

We adhere to the EU GDPR in the UK when we operate in the EEA, offer to individuals in the EEA services or goods, or when monitoring the behavior of individuals in the EEA.

When there has been no EU GDPR adequacy decision, the “Frozen GDPR,” instead applies, including to personal information which was processed in the “UK under the EU GDPR before 1 January, 2021,” and personal information that is being processed in the UK “on the basis of the Withdrawal Agreement” between the EU and the UK When applying the “Frozen GDPR,” we may “need to identify any personal data about individuals located outside the UK collected before the end of 2020,” and may need to “identify any new non-UK personal data you process to comply with the Withdrawal Agreement.

EE. "DO NOT TRACK" POLICY AS REQUIRED BY CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CALOPPA)

Our Service does not respond to Do Not Track signals. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If We become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before We collect and use that information.

Our Cora Chat feature will help You chat online with Your clients and staff members, and will be hosted through Amazon Chime. Your use of Cora Chat is subject to the terms of this Policy and to any third-party Terms of Service and Privacy Policies of Amazon, including those of AWS and Amazon Chime. Any misuse of Our Cora Chat feature is grounds for termination of our provision of our Services to you, and we have the sole right to refuse to provide Our Services to you and to terminate your access and use of our Services if you misuse any of our Services. No one under the age of 18 is permitted to use Cora Chat, and We reserve the sole right to terminate provision of our Services to you and to terminate your access and use of the Services if you assist someone under the age of 18 to use our Services or if You as a user of our Services are found to be under the age of 18.

 

FF. Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data and/or Personal Information with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact Us using the contact information provided below.

GG. California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

HH. NOTICE TO EUROPEAN UNION USERS

Our operations are located primarily in the United States. If you provide information to use, it will be transferred out of the European Union (EU) and sent to the United States. The adequacy decision between the EU-US became operational on August 1, 2016. This framework protects the fundamental rights of anyone in the EU whose Personal Data and/or Personal Information is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the United States under the Privacy Shield, which provides a mechanism to comply with data protection requirements when transferring personal data from the EU and Switzerland to the United States. By providing Personal Information and/or Personal Data to us, you are consenting to Its storage and use as described in this Policy. 

II. PRIVACY POLICY CHANGES

Although most changes are likely to be minor, we may change the contents of this Policy from time to time, and in Our sole discretion. We encourage Visitors and Users to frequently check this page for any changes to its Policy. If you have an account with Us, you may also receive an alert informing you of such changes. Your continued use of our Website and/or Services after any change to this Policy will constitute your acceptance of such change. 

We reserve the right to modify this Policy at any time. If We make material changes to this Policy, we will notify you here, and also as necessary via email. By continuing to use the Website and/or Services after those changes become effective, you agree to be bound by the revised Policy.

JJ. CONTACT US

If you have any questions or suggestions regarding our Privacy Policy, please contact us by email at support@coraltreetech.com. You may also contact us by phone at 408-448-QBOX (7269) or 855-448-QBOX (7269) Toll Free.