California residents should read the information available in the Privacy Notice for California Residents below.
European Union residents should read the information available in the Privacy Notice for European Union Residents below about the categories of personal information to be collected from them and the purposes for which the personal information will be used below.
We may use the information we collect for one or more of the following purposes:
Communication with you
Delivery of services to you
Administration and improvement of services
Customization and marketing
Compliance with law
Other uses with consent
Information about you may be disclosed to third parties for one or more of the following purposes:
Note that if you make any information publicly available on the Platform, anyone may see and use such information.
You have a number of rights with regards to your personal data:
You can use your Platform user account to opt in and out of receiving email communications and to update your personal information. If you would like to delete your website account, please contact us by email at firstname.lastname@example.org. Your account is automatically deleted after two years of inactivity.
We will need your payment card details and billing address if you make any purchases, in order to take payment and perform refunds if necessary. We do not keep your card number. Order confirmations will be sent by email.
We will use your name and email address to provide you with emails and newsletters you have chosen to receive. You will be able to unsubscribe from these at any time by clicking on the link in the email or contacting us at email@example.com.
You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.
Like many applications, we use “cookies” and “web beacons” (also known as pixels) to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A “web beacon” is a tiny and sometimes invisible image or embedded code, placed on a web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users for the purpose of analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.
You can change your browser’s settings so it will stop accepting cookies or to prompt you before accepting a cookie. Opt-out options for cookies are located at the account holder section of the Platform.
Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our Platform for purposes of analytics and analysis of certain Platform usage.
In order to provide your subscription services, we may ask you for some of the following information. This list is not exhaustive.
Name, telephone number, and postal address – As applicable, we need these to send you publications and other information relevant to your subscription, including subscription renewal information.
Email address – We need this to provide your Platform services, such as your online account and email information. We use your email address to communicate with you about your benefits, news and services, surveys, and activities.
Qualifications – Dependent on your access, we need a copy of your qualifications in order to check you are eligible. Any copies are destroyed within two years of your termination from the Platform.
Date of birth- This is used for verification purposes.
You can view and update most personal data held by logging into the account holder section of the Platform. Please email us firstname.lastname@example.org if you would like to view your data or if you would like us to update it for you.
If you decide to terminate your use of the Platform, we will keep your personal information on our database for two years. This is to allow you to re-join the Platform during this period without having to submit your information and/or supporting documentation again.
We will retain some basic information about your Platform access for archiving and historical research or for conducting statistical analysis of our users. Where appropriate this will be anonymized and any personal data held will be kept to a minimum.
Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).
While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal laws, provincial and state laws, and regulations regarding data privacy.
We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but are not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.
We cooperate with governments and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Counsellors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action including but not limited to the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.
Through your use of our Platform, 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 household (“personal information”). The description of the information that we collect is provided above, in the section titled “Categories of Information Collected.” The information that we share with third parties is described in greater detail above in the section titled “Purposes for Which Information is Disclosed to Third Parties.”
In particular, our Platform is expected to collect the following categories of personal information from consumers within twelve (12) months. Additionally, we expect to disclose the following categories of information for a business purpose within twelve (12) months:
Category / Collection / Disclosure for a business purpose
A. Identifiers. / Yes / Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). / Yes / Yes
C. Protected classification characteristics under California or federal law. / Yes / Yes
D. Commercial information. / Yes / Yes
E. Biometric information. / No / No
F. Internet or other similar network activity. / Yes / Yes
G. Geolocation data. / Yes / Yes
H. Sensory data. / No / No
I. Professional or employment-related information. / Yes / Yes
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)). / No / No
K. Inferences drawn from other personal information. / Yes / Yes
The information that we share with third parties is described in greater detail above in the section titled “Purposes for Which Information is Disclosed to Third Parties.”
We obtain the categories of personal information listed above from the following categories of sources:
We may use the personal information we collect for one or more of the following business or marketing purposes:
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that Cocoon disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:
You have the right to request that we delete any of your personal information that we collected about you and retained, subject to certain exceptions. Once we receive your request and verify who you are, 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 provider(s) to:
You have the option to opt out of the use or disclosure of your information that is considered a “sale” under the CCPA. If you would like to opt out of the use and disclosure of your information, go to the account holder section of the Platform to manage your preferences.
To exercise the rights listed above, please submit a request in writing to us via the submission methods listed below. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.
You may only make a request for access twice within a 12-month period. Your request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.
You may submit requests using the following methods:
By making the request in writing and sending it to:
Cocoon Connects Ltd.
Data Protection Office, Suite 102
951 Rowntree Dairy Road
Vaughan ON L4L 8Z5 Canada
We endeavour to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days from the day of receipt), we will inform you of the reason and extension period in writing.
For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Cocoon Connects Ltd.
Data Protection Officer
951 Rowntree Dairy Road, Suite 102
Vaughan ON L4L 8Z5 Canada
EU and Swiss residents have specific rights regarding their personal information. This section describes your rights if you are resident in the EU or Switzerland, and explains how to exercise those rights.
Right of access: You may be entitled to ask us for a copy of any personal information which we hold. This right is known as a ‘Subject Access Request.’ We will normally send you a copy of the personal information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the personal information that you request. There is usually no charge; but in exceptional circumstances we may charge but will discuss this with you if those circumstances apply.
Right to rectification: If the personal information we hold about you is inaccurate, you may request rectification. The personal information will be checked, and, where appropriate, inaccuracies will be rectified.
Right to erasure: In certain circumstances, you may be entitled to ask us to erase your personal information.
Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic personal Information that we hold about you to another organization.
Right to object: You may object to your personal information being used for direct marketing. You may object to the continued use of your personal information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your personal information, we may continue to do so. In that event, we will let you know the reasons for our decision.
Rights related to automated decision-making including profiling: We use limited personal information to operate the Platform and to carry out certain profiling activities to support and grow our business. When doing so, we rely upon our legitimate interests as the lawful basis for processing your personal information and you may exercise the above rights if you do not wish us to process your personal information in this way.
To exercise the rights in relation to your Personal Information set out in this section, please contact us by send an email to firstname.lastname@example.org.
You can contact our Data Protection Officer with questions, about this policy, or about your personal information by writing to:
Cocoon Connects Ltd., Data Protection Officer, c/o Legal Department, 951 Rowntree Dairy Road, Suite 102, Vaughan ON L4L 8Z5 Canada; email@example.com
Whilst we will always work with you to resolve any concerns you have about the use of your personal information, under GDPR you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.
Last Updated and Effective: July 21, 2023