Cobbler Inc. Privacy Policy

Date of Last Revision: June 6, 2022.


Welcome to the website (collectively, including https://app.cobbler.io and all other associated sites linked to https://www.cobbler.io by Cobbler, the "Site") of Cobbler Inc. ("Cobbler," "we," "us," or "our"). Cobbler provides budget management, headcount management, FP&A automation, and related technologies (collectively, including the Site, the "Service").

This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.

Before using the Service or submitting any Personal Data to Cobbler, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.


1. PERSONAL DATA WE COLLECT

Certain laws, such as the California Consumer Privacy Act (“CCPA") require that we disclose certain information about the categories of personal information that we collect about individuals. We collect information that alone or in combination with other information in our possession could be used to identify you ("Personal Data") as follows:


Personal Data You Provide: We collect Personal Data when you sign up for the Service, provide the information when using the Site or Service, update your account information, contact us with questions or feedback, or otherwise communicate with us. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include:

  • First and last name
  • Email address
  • Location
  • Company Name
  • Company Title
  • Company Website
  • User content, for example, comments and posts you submit publicly, or files you upload (which can include Personal Data if you include Personal Data in such content)

Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Instagram, Medium, Facebook, Twitter, and LinkedIn ("Social Media Pages"). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information, analytics regarding the use of our Social Media Pages, and information from your public profile, if the third party service and your account settings allow for such sharing. The information we receive will depend on the policies and your account settings with the third party service.


Personal Data Processed on Behalf of Business Customers: We may receive Personal Data about employees and customers of our business customers that such business customers make available to us, including, but not limited to, names, emails, and financial information of such customers' employees or vendors. We process that information pursuant to our Terms of Service and other agreements with our business customers. We have no direct relationship with the individuals whose Personal Data we process on behalf of our business customers. If you are such an individual and would no longer like your data to be used by one of our business customers that use our Services or you would like to access, correct or request deletion of your data, please contact the business customer that you interact with directly.


Personal Data We Receive Automatically From Your Use of the Service: When you visit, use and interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Firefox, Google Chrome, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:



  • Log data: Information that your browser automatically sends whenever you visit the Site ("log data"). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies: Please see the "Cookies" section below to learn more about how we use cookies.
  • Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
Cookies: We use cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) to operate and administer our Site, gather usage data on our Site and improve your experience on it. A "cookie" is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.


Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to https://policies.google.com/technologies/partner-sites. We also use another analytics service called Heap. Please visit https://heap.io/privacy for additional information.

Integrated Services: You may be given the option to access or register for the Services through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service"), such as through the use of your Google account, or otherwise have the option to authorize a third party integrated service (an “Integrated Service") to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this policy. 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.


Other Sources: We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.


Online Tracking and Do Not Track Signals. We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to "Do Not Track" ("DNT") signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.


Your Choices. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser's settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.


Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative's online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.


2. HOW WE USE PERSONAL DATA

We may use Personal Data for the following purposes:



  • To provide the Service;
  • To create and manage user and company profiles
  • To respond to your inquiries, comments, feedback or questions;
  • To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;
  • To contact you about Service announcements, updates or offers
  • To personalize website content and communications based on your preferences
  • To analyze how you interact with our Service;
  • To maintain and improve the content and functionality of the Service;
  • To develop new products and services;
  • To meet contract or legal obligations
  • To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture and networks; and
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties, including the enforcement of our Terms of Service.
Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.


Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.


3. SHARING AND DISCLOSURE OF PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:


  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
  • Affiliates: We may share Personal Data with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Cobbler. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
  • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
  • Social media services (if you interact with them through your use of the Services)
  • Third party business partners who you access through the Services
  • Other parties authorized by you
4. DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.


5. UPDATE YOUR INFORMATION

Please contact us if you need to change or correct your Personal Data.


6. CALIFORNIA PRIVACY RIGHTS DISCLOSURES

Third Party Marketing: If you are a California resident and wish to opt out of sharing your Personal Data with third parties for their direct marketing purposes, please email Cobbler at help@cobbler.io and clearly state your request, including your name, mailing address, email address and phone number. Please see the "Your Choices" section of this Privacy Policy for additional information.


7. CHILDREN

Our Service is not directed to children who are under the age of 16. Cobbler does not knowingly collect Personal Data from children under the age of 16. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you have reason to believe that a child under the age of 16 has provided Personal Data to Cobbler through the Service please contact us and we will endeavor to delete that information from our databases.


8. LINKS TO OTHER WEBSITES

The Service may contain links to other websites not operated or controlled by Cobbler, including social media services ("Third Party Sites"). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.


9. SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Cobbler via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.


10. YOUR CHOICES

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.


11. YOUR CALIFORNIA PRIVACY RIGHTS
In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA"), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under the CCPA.

California Residents' Rights. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
Do-not-sell: California residents have the right to opt-out of our sale of their personal information. If you are a California resident, you may submit an opt-out request here. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent.
Notice before collection: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
Request to delete: California residents have the right to request, at no charge, deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
Request to know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:
• categories of personal information collected;
• categories of sources of personal information;
• business and/or commercial purposes for collecting and selling their personal information;
• categories of third parties/with whom we have disclosed or shared their personal information;
• categories of personal information that we have disclosed or shared with a third party for a business purpose; and
• categories of third parties to whom the residents' personal information has been sold and the specific categories of personal information sold to each category of third party.
California residents may make a Request to Know up to twice every 12 months, at no charge. We will respond to verifiable requests received from California residents as required by law.

Discrimination and financial incentives: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. A business may offer financial incentives for the collection, sale or deletion of California residents' personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentive offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.

Submitting Verifiable Requests. Requests to Know and Requests to Delete may be submitted:
• By email at help@cobbler.io
We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Contact Us section below.

12. CHANGES TO THE PRIVACY POLICY

The Service, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.


13. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at help@cobbler.io.