Last Updated: February 22nd, 2021
There are three basic categories of information we collect:
1.1 Personal Information You Provide To Us
When you interact with our Site or mobile app, we collect Personal Information that you choose to share with us. For example, when you set up an account with us, we need to collect a few important details about you, such as your name, a unique username you would like to go by, a phone number, your email address, and your date of birth. We may also collect other information such as a copy of your government-issued identification and your Social Security or Individual Taxpayer Identification Number for verification purposes. When you contact customer support or communicate with us in any other way, we’ll collect whatever information you volunteer, in addition to your name and email address.
1.2 Automatically-Collected Data
When you visit our Site or use our Services, we collect information about which of the Services you’ve used and how you’ve used them. Examples of this information include:
1.3 Information We Get From Third Parties
We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.
2.1 Personal Information
2.1.1 To provide the Services:
Copper may use your Personal Information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
2.1.2 For internal business purposes:
Copper may use Personal Information for its internal business purposes, including to:
2.1.3 For marketing purposes:
Copper may analyze and use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Copper may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include:
2.2 Non-Personal Information
We may share Personal Information about you in the following ways:
In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. On most web browsers, you will find a “help” section on the toolbar. Please refer to that section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
We may also use analytics tools such as Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.
We may employ a software technology called clear gifs (a.k.a. Web Beacons) that help us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ Personal Information. We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
We will retain your information for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws.
Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them Copper does not endorse, approve or make any representations about Third-Party websites or domains. We encourage you to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and you visit them at your own risk.
Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.
We take commercially-reasonable steps to protect the data you have given us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. However, please be aware that no transmission of Personal Information over the Internet or the electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any Personal Information via the Site or Services, please keep in mind these risks and know that you do so at your own risk.
10.1. Communications Preferences
10.2. Sharing Preferences
We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.
11.1 Children’s Privacy
We do not knowingly collect Personal Information, as defined under COPPA, directly from children under 13 years of age. If a primary account holder adds an individual to their account under the age of 13 as an authorized user, the primary account holder (parent or legal guardian) will provide the information to Copper that is necessary to add the individual as an authorized user. After adding the individual as an authorized user to the primary account, Copper will only collect and use personal information related to the authorized user for the purpose of providing Copper services, and any such information will not be shared with third parties for any purpose not required or permitted by law.
If you learn that your child has provided us with Personal Information without your consent, please let us know by contacting us at email@example.com.
11.2 Your California Privacy Rights
11.2.1 “Shine the Light” Law
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Copper does not share your Personal Information with third parties for their direct marketing purposes.