Last Updated: June 15, 2020
Coefficient OpCo Ltd. t/a Coefficient (“we”, “us”, or “Coefficient”) is committed to ensuring your privacy is protected.
- the types of information, including personal information, we may obtain about you;
- how we may use, share or otherwise process that information;
- the safeguards we have in place to protect that information;
- the bases upon which we may use that information;
- how information about children is handled;
- your rights and options in respect of the information we hold about you;
- how to contact us or make complaints; and
The types of information, including personal information, we may obtain about you
As you interact with us in connection with our Services, we may obtain personal information about you, potentially including sensitive personal information. “Personal information” includes any information that can be used to identify you or that we can link to you as an individual. “Sensitive personal information” is personal information that includes racial/ethnic origins, political opinions, religious beliefs, medical data or similar details.
We collect your personal information when you provide it to us, directly or indirectly. This information may be collected automatically, including when you use our Digital Services, or when you provide it to us voluntarily as you communicate with us in connection with our Services. We may also obtain information about you from other sources, such as social media platforms or applications that may share your information about you, your devices, the content you access, and/or how you interact with that platform or application with us.
The personal information we obtain about you may include, but is not limited to:
- your full name and date of birth;
- your passport, driving license or other photographic identity details;
- your employment information, including your company or organization and job title;
- your contact information, including physical address, mailing address, email address, telephone number and fax number(s);
- your IP address, your MAC address, your device details and certain other digital identifiers;
- your demographic information, including your place of residence; personal preferences; interests or opinions; age; race; colour; ethnicity; national or social origin; immigrant or refugee status; primary language; gender, gender expression or gender identity; sexual orientation; pregnancy; birth; genetic information; mental impairment or physical disability; creed, religion, religious practice or belief; political or other opinion; socio-economic, marital, familial, or parental status; or other similar personal characteristics;
- your payment and/or banking information, including credit or debit card details and wire transfer instructions; and
- expressions of your personal opinion, including when you leave feedback or contact us.
Generally, you can use our Digital Services without providing us with any personal information, if you so choose. If you use our Consulting Services, we may be required to collect certain personal information about you in order to be able to provide those Consulting Services to you and comply with our obligations under applicable laws.
Information you provide to us voluntarily
We may collect information that you voluntarily provide to us, including when you communicate with us via email, telephone, fax or via other channels, when you fill out a form on our website, or when you interact with us as a customer or potential customer.
Information we may collect automatically
We may collect information automatically through the use of browser cookies, web beacons and other similar technologies (collectively, “Tracking Technology”) when you use, access, or interact with our Digital Services. We may, for example, collect information about the type of device you are using, your operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, your screen size, the content you view, the features you access, the web pages you viewed immediately before or after you access our Digital Services, whether and how you interact with content available within our Digital Services, and the search terms you may have used or advertisements you may have viewed to reach our website or other Digital Services.
We may also use Tracking Technology to remember your preferences and settings; to remember information you have entered; to keep you logged in to any portals that we may offer; to generate statistics about people who use or express interest in our Services or similar services; to help you share content with others; and to improve your or other users’ experience of our Services.
Please note that our Digital Services may not respond to web browser “do not track” signals or other mechanisms designed to allow you to opt out of the collection of information across networks, as there is no uniform standard for how Digital Services should respond to such signals. As standards develop, we may implement and develop policies for responding to such “do not track” signals.
Among other Tracking Technologies, we may also use Google Analytics, Google Signals, Google Tag Manager, Google Ads, Google Ads Remarketing, DoubleClick Ads, Mailchimp, CloudFlare, the YouTube video widget, Contact Form 7, LatePoint, Facebook Ads and/or the Facebook Pixel to serve you and others like you more targeted or personalized advertisements about our Services, to respond to your requests for our Services, to gather information about your use of our Digital Services, and/or to track the effectiveness and refine of our advertising efforts. To limit the use of these Tracking Technologies, we recommend downloading and installing the Google Analytics Opt-Out Browser Add-on, disabling ads in your Facebook Account Settings, and disabling ad personalization in your Google Account Settings. You may also wish to install ad-blocking software. Additional information about how to opt-out of these Tracking Technologies is available from the providers of the specific Tracking Technology.
Please note that, although the information we provide is not contingent on your acceptance of the Tracking Technologies we use, some of our Digital Services may function differently if you disable these Tracking Technologies on your device or in your browser.
Information we may collect from third party sources
We may receive information about you from other sources (including agents who represent you or other third parties) to help us update, expand, and analyze our records; identify new customers; improve our Services; or prevent or detect fraud. We may also receive information about you from our social media platforms, including, but not limited to, when you interact with us on those platforms or access our social media content. If you do not want these other sources to share your personal information with us, we encourage you to review the privacy policies of these sources for your options in this regard.
How we may use, share or otherwise process that information
How we may use information
We may use the information we collect:
- to respond to your inquiries in respect of our Services;
- to provide you with the Services you’ve requested from us;
- with your consent, to send you marketing communications and other information related to our Services or that we think may be of interest to you;
- to advertise our Services to you or people like you;
- to assess the effectiveness of our advertising and promotional campaigns;
- to maintain our list of contacts;
- to understand how people use and to improve our Services, including through statistical analysis;
- for other legitimate business purposes, including data analysis; invoicing; and detecting, preventing, and responding to actual or potential fraud, illegal activities or intellectual property infringement;
- to comply with our legal obligations, as we believe is reasonably necessary or appropriate;
- to respond to legal processes or requests for information issued by government authorities or other third parties; and
- to protect your, our, or others’ rights.
How we may share information
We may disclose information we collect to:
- third-party service providers that perform services on our behalf, such as web-hosting companies, mailing vendors, marketing service providers, analytics providers, and information technology providers;
- employees, agents or contracted third parties to the extent reasonably necessary to perform their duties and in line with the reason for the processing;
- law enforcement, other government authorities, or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the applicable laws of any jurisdiction; as provided for under a contract; or as we deem reasonably necessary to provide our Services; and
- service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another organisation or if we sell, liquidate, or transfer all or a portion of our assets, in which case we may share or transfer your personal information to that other organisation.
Third-party services and content
While we are located in the Cayman Islands, our third-party service providers may have facilities in other jurisdictions. Accordingly, when using those third-party service providers, we may transfer your personal information or process the information we collect in jurisdictions where those third-party service providers have facilities. By using our Services, you consent to the storage and processing of data in these locations, even though the data protections afforded in some such locations may not rise to the level of an “adequate level of protection” within the specific meaning of that term under Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”) or the Cayman Islands Data Protection law.
The safeguards we have in place to protect that information
We are committed to ensuring that your information is secure.
Although we may be required to keep certain information for an extended period of time or even indefinitely in order to comply with applicable laws, analyze statistical trends over time, protect our rights, and/or for other legitimate purposes, we endeavor not to hold your personal data for any longer than we deem reasonably necessary.
We deploy administrative, technical, and physical safeguards designed to safeguard the information that we collect to the extent we deem reasonably feasible. Your personal information is generally only accessible by a limited number of persons who have special access rights to such systems. In addition, all credit or debit card information you supply is processed through a gateway provider and is not stored or processed on our servers.
That being said, no information system can be 100% secure, and we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the internet and wireless networks. Accordingly, any personal data submitted by you is at your own risk.
The bases upon which we may use that information
We rely on several legal grounds to process your personal information, including:
Performance of a contract
We may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us. For example, when you use our Consulting Services, we may use your personal information to respond to your requests, to confirm your identity or to provide you with the goods, services and information you have requested.
We may need to collect and use your personal information to comply with any legal obligations to which we are or may become subject.
We may use personal information with your consent. To withdraw your consent, contact us via email at email@example.com or disable the settings on your device that permit the sharing of information with us (for example, the sharing of location information in your browser or mobile application settings, or the ability for websites to utilize cookies, as described above). Where required by applicable laws, we will rely on your consent for direct marketing and for collecting information from your device or computer.
Where we do not otherwise have specific legal grounds on which to process your personal information, we may nevertheless use your personal information when reasonably necessary to further our legitimate interests and when we do not believe our interests are outweighed by your own. Our legitimate interests may include our interests in furthering our commercial enterprise, in providing our Services to you, in improving our Services, in marketing or sharing information about our Services with you or people like you, and in furthering charitable endeavors or other endeavors with a societal benefit in which we may engage.
How information about children is handled
Our Services are not intended to be used by children under the age of thirteen. Additionally, we do not knowingly collect or maintain personal information from anyone under the age of thirteen through our Services, unless or except as permitted or required by law.
Parents or legal guardians of children under thirteen or their agents may voluntarily provide personal information to us about children under thirteen so that we can better provide our Consulting Services to them. If you are the parent or legal guardian of a child under thirteen who has provided personal information to us, please contact us at firstname.lastname@example.org if you would like to have that child’s information deleted from our records.
Your rights and options in respect of the information we hold about you
Where required by applicable laws, we will rely on your consent for direct marketing and to collect information from your device or computer. Any electronic marketing communications we send you also contain opt-out mechanisms that allow you to opt-out from receiving those communications at any time. We will honor your choice and refrain from sending you such announcements. You may also opt back in to receive those communications at any time. If you no longer wish to receive email marketing communications from us, you can let us know by clicking the unsubscribe link contained in the bottom of our emails or contacting us at email@example.com.
You also have certain rights regarding the information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes, or if you believe that any information that we have collected about you is inaccurate or out of date. You may also be able to ask us to see what personal information we hold about you, to erase your personal information, and to object to our use of your personal information. You also have the right to be notified in the event of the security measures we have in place protecting your data are compromised, and the right to complain to the Cayman Islands’ data protection authority, as described below, if you believe we have violated your rights.
Your ability to exercise these rights will depend on a number of factors. Please be aware that, in some instances, we may not be able to fully comply with your request. We may, for example, need to retain and process your data in order to respond to your requests, to provide you with the goods, services and information you have requested, to comply with applicable law or for other legitimate purposes.
How to contact us or make complaints
We welcome your inquiries and comments. If you would like to contact us with questions about our privacy or data protection practices, please email firstname.lastname@example.org or send a letter to:
Data Privacy Officer
10 Market Street #1157
Camana Bay, Grand Cayman KY1-9006
We are committed to obtaining a fair resolution of any complaint or concern you might have about your privacy as a result of your interactions with us. If you nevertheless believe that we have not been able to assist with your complaint or concern, you may have the right to complain to the data protection authority in your jurisdiction or to the Office of the Ombudsman in the Cayman Islands.