PRIVACY POLICY
Last Updated: September 1, 2024
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE PLATFORM OR ANY OF THE SERVICES PROVIDED BY COTL, LLC (“COTL”). IF YOU DO NOT AGREE TO ANY OF THESE TERMS, DO NOT USE THE PLATFORM OR ANY OF THE SERVICES PROVIDED BY COTL.
This Privacy Policy describes Cotl’s approach to privacy and provides information about how Cotl collects, uses, processes, and discloses personal information.
If you have questions about this Privacy Policy or would like to exercise any of your privacy rights, you may contact us at support@cotl.pet.
Please also refer to the Cotl Terms of Use, and, if you have created a Cotl Plan, the terms of your Pet Trust Agreement and your Engagement Letter with Booper Legal, each of which is incorporated herein by reference. These terms of use and the Privacy Policy, your Pet Trust Agreement, and your Engagement Letter with Booper Legal are collectively referred to as the “Plan Documents.”
WHAT THIS PRIVACY POLICY COVERS
This Privacy Policy describes how Cotl, Inc. uses personal information in connection with goods and services sold by Cotl, our websites and applications (and the websites and applications we use in connection with providing our goods and services), and the use of the Cotl website unless otherwise listed below.
Activities not covered by this Privacy Policy are (1) personal information that may be collected or used by other businesses when you click on third-party links found on our website or use social media widgets that we provide (you can refer to the privacy policy of third-party websites and services for information about their privacy practices); and (2) personal information collected and used in connection with Cotl’s employment activities.
COTL’S APPROACH TO PRIVACY
Cotl takes your privacy seriously and is mindful of potential concerns about how we use the personal information we collect from and about you. In addition to this Privacy Policy, we have internal policies and practices designed to keep your personal information secure and to ensure that information about you is only used consistent with this Privacy Policy. We are committed to ensuring that your personal information is safe and handled properly.
THE PERSONAL INFORMATION WE COLLECT
In this section of the Privacy Policy, we explain the types of personal information we may collect. The specific information that we may collect about you depends on the type of interaction and the types of products considered or purchased.
Cotl potentially collects the following categories of personal information:
Identifiers: Examples of the types of identifiers that Cotl may collect include real names, nicknames, signatures, postal addresses, online identifiers, Internet Protocol addresses, email addresses, and account numbers.
Sensitive Information: Examples of the types of sensitive information that Cotl may collect includes social security numbers, driver’s license photos or other state or passport identification cards, passport numbers, and usernames and passwords for accounts connected to Cotl.
Biometric information: With your consent, Cotl may work with Stripe to use technology to verify your identity by comparing a digital image of your face to the picture on the government identification you provide.
Characteristics protected under some laws: Examples of the types of characteristics that Cotl may collect include age, national origin, citizenship, marital status, medical information, sex, and veteran or military status. Cotl does not use this type of information to analyze your health, sex, gender identity, or sexual orientation.
Commercial information: Examples of the types of commercial information that Cotl may collect includes records of business and other property owned, products or services purchased, obtained, or considered from Cotl or our partners, and other purchasing or consuming histories or tendencies.
Internet information: Examples of the types of internet activity information that Cotl may collect includes browsing history, search history, information about the device used to access our website or applications, and information regarding your interaction with websites, applications, or advertisements. We may also collect information from visitors to our website, such as browser settings, operating systems, referring/exit pages, and clickstream data. When we send you an email, Cotl may also collect information, including about how you interact with that email.
Geolocation information: Cotl may collect information about where you reside, do business, or are otherwise located.
Audio and visual information: Cotl may make audio recordings of telephone calls. We may make visual recordings if you agree that we may videotape or photograph you. We may also collect visual images of you in connection with legal requirements, security purposes, or when required for providing certain products.
Professional and employment-related information: Examples of the types of professional and employment-related information Cotl may collect includes information about professional status and affiliations, employment history, salary, and employment status.
Other types of information: Examples of other types of information include physical characteristics or descriptions of you, telephone number, insurance policy number, financial information including bank account, credit card, and debit card numbers, and health insurance information. It also includes additional information provided to Cotl directly by you, such as when you complete a questionnaire, upload a document, answer a survey, or receive a financial consultation. This category includes information identified as personal information in California Civil Code Section 1798.80(e) that is not otherwise categorized above.
WHERE WE COLLECT PERSONAL INFORMATION
In this section of the Privacy Policy, we explain where and how we collect personal information.
Customers: Much of the personal information that Cotl collects comes directly or indirectly from our customers and prospective customers. Information that is collected directly from you is information that you provide when you complete a form online, upload a document, use a chat feature, or speak to us on the phone. We may also collect information indirectly about you when you interact with our website, using cookies and other tracking technologies.
Related Parties: We may collect information about you from someone you know. For instance, if you are a shareholder in a business that is formed through Cotl, we may be given information about you by that business to complete the formation or to file Beneficial Ownership Reports. We may also receive information about you from customers using our products to send communications to you, such as our e-signature product.
Service Providers: We may collect information about you from our Service Providers or other companies that we work with to deliver products to you. As used in this Privacy Policy, Service Providers means entities that Cotl has contracted with to provide us with services to help fulfill our business needs. An example of the type of information that we may receive from a Service Provider is information about whether any Legal Mail has been received as part of our Registered Agent services. Service Providers may also assist us in collecting information both directly and indirectly from you.
Professionals: We may receive information about you from Booper Legal, Towne Bank, or other service providers who support our product offerings.
Business Partners: We may receive information about you from our Business Partners. As used in this Privacy Policy, Business Partners means entities that Cotl has contracted with to engage in cross-promotional or product integration activities. An example of the type of information that we may receive from our business partners is information about the products you purchased from them.
Affiliates and Subsidiaries: We may receive information about you from our affiliates and subsidiaries. For example, if we acquire an ownership interest in a company, we may receive information about you as part of that acquisition if you have previously done business with them.
Publicly/Commercially Available Information: We may collect information about you from publicly available sources of information, including government records, social media sites, and other commercially available sources of personal information. Examples of the type of information we may collect from publicly available sources are whether your entity is in good standing with a Secretary of State or whether you have recently expressed interest in purchasing a product that Cotl sells.
Unrelated Parties: We may receive information related to you from people and entities with whom Cotl does not have a direct relationship. An example of the type of information that we may receive from unrelated third parties are documents that we receive on your behalf in our role as your Registered Agent.
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Cotl uses the information that it collects for the purposes listed below. We use technology, including automated processing, AI, and human review to accomplish these purposes. We may also combine information that we have collected from multiple sources.
If we decide to use the personal information we have collected for additional purposes that are inconsistent with what is described below, we will let you know of our plans and give you information about your legal rights regarding your personal information.
Providing Products and Services: We use personal information to provide and support our products and services. Examples of these uses include producing and delivering documents purchased by customers, administering the Cotl website, and displaying content based on customer preferences.
Corresponding with Service Providers: We use personal information to communicate with other parties who provide services in connection with your Plan Documents, including Booper Legal, Towne Bank, Knackly, and Stripe.
Security: We use personal information to ensure we maintain appropriate security over computer networks and our physical facilities, as well as detecting fraud or other suspicious activities.
Marketing and Advertising: We use personal information for marketing to current and prospective customers. More information about how you can control the use of your personal information for marketing purposes can be found in the sections “Cotl’s Use of Cookies and Similar Technology, and Your Choices” and “Your Options Regarding Personal Information Collected by Cotl.”
Product Development: We use personal information for product development, including improving our existing offerings and developing new products and services, including machine learning or Artificial Intelligence ("AI") technologies.
Analytics: We use personal information for various types of analytics. For example, Cotl uses personal information to analyze how visitors arrive at and interact with our website, and to gain insight into the types of customers that may be interested in our products and services. We may also use the information to develop inferences from the information we collect regarding customer preferences, characteristics, predispositions, behaviors, and attitudes.
Operational Purposes: We use personal information for operational purposes, and the operational purposes of our service providers, business partners, affiliates, and subsidiaries. For instance, Cotl may use the information to maintain our website and other infrastructure, training, quality assurance, for conducting surveys or sweepstakes, to promote our brand, and to use in connection with our relationships with service providers and business partners.
Financial Reporting: We use personal information in connection with various types of financial reporting and other similar internal uses. Examples of the types of financial reporting that Cotl may use personal information in connection with includes internal budgets and projections, compensation calculations, and public reporting.
Meeting Legal Requirements: We use personal information to meet our legal obligations, such as performing customer due diligence, maintaining records as required by law, or responding to subpoenas for information.
Business Transfers: If Cotl undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including information related to customers in connection with the transaction or in contemplation of the transaction (such as conducting due diligence). If such an event occurs, your information may be treated like any other Cotl asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
HOW WE DISCLOSE PERSONAL INFORMATION
In this section of the Privacy Policy, we explain to whom we disclose personal information and under what circumstances we may make a disclosure.
Service Providers: We may share personal information with our service providers who assist us with running our business. These companies are not authorized to use the information we share with them for any purpose other than providing services to Cotl or to you.
Businesses Providing Services: Cotl may disclose personal information with other businesses in order to provide you with products and services that you have purchased from Cotl. We may share personal information with other parties who provide services in connection with your Plan Documents, including Booper Legal, TowneBank, Knackly, and Stripe. Personal information disclosed to other businesses will be subject to those third parties’ privacy practices. These companies may collect and process personal information for their own uses, including improving its services and for fraud detection and prevention.
Business Partners: Cotl may share personal information with business partners. When we share personal information with business partners, it will generally be subject to their privacy policy. We share information with business partners in the following circumstances:
If you express interest in an offer presented to you either by Cotl on behalf of a business partner or by a business partner on behalf of Cotl, you are directing Cotl to provide information about you to that business partner.
If you purchase a Cotl product that is bundled with a product offered by one of our business partners, we will share information about you with that business partner.
Your Cotl Plan Parties: We may provide information about you to someone you know or that you have listed as a spouse or caretaker in your Plan Documents. For instance, we (or Booper Legal) may provide information connected to your Cotl account with Booper Legal, other trustees, your spouse, and/or caretaker in order to facilitate our services. We may provide information about you to a customer requesting that you sign a document, such as whether you have completed the signature process.
Government Entities: Cotl may share information about customers with government entities to fulfill the products purchased by our customers. This includes information about your trust information if and as needed for your Cotl Plan trustee is make tax filings on behalf of your trust.
Public Disclosures: Cotl may publicly disclose personal information in limited circumstances.
We may display testimonials and reviews received through email surveys or other means on our website or other marketing or that are posted to publicly available websites.
When you post content in any forum or comment area on our website, these posts may be publicly available. You should use caution when deciding whether to disclose your personal information in public areas of our website.
When we collect publicly available information, we may share that information on our website.
Required by Law: Cotl may disclose personal information as required by law, such as in response to a subpoena or a lawful request by a public authority, including to meet national security or law enforcement requirements, or similar legal processes. We may also disclose personal information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legitimate request from a government entity.
Parties Related to Cotl: Cotl may disclose personal information with businesses controlling, controlled by, or under common control with Cotl. If Cotl is merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer consumer data in connection with the associated transactions.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
Cotl retains your personal information for at least as long as it is necessary to fulfill the purposes for which we collected the data, to provide you with services and products, to comply with our data retention obligations, and to successfully run our business.
COTL’S USE OF COOKIES AND SIMILAR TECHNOLOGY, AND YOUR CHOICES
Like all online companies, Cotl uses a range of technologies in connection with your use of our website, mobile application, and when you engage with emails that we send you. The types of technologies that we may use include cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers (including mobile identifiers such as Apple’s Identifier for Advertisers (“IDFA”) or Google’s Advertising ID (“GAID”)), and similar technologies, which for purposes of this Privacy Policy we refer to as “Cookies.”
We use Cookies for a variety of purposes. Depending on the purpose, you have different options regarding whether and how we use Cookies to collect your personal information.
Strictly Necessary Cookies: We use Cookies to help our website operate and for security purposes. Due to the nature of these Cookies, you do not have the ability to opt-out of the use of these Cookies.
Performance and Functionality Cookies: We use Cookies to provide enhanced functionality on our website and app, to personalize your experience, to collect information for analytical purposes to help us improve and develop products, and to help us understand how you are engaging with our products. If you reject these Cookies, the functionality of our website may be impacted, including in ways that may limit your use of our products and services.
Engagement and Marketing Cookies: Cotl uses Cookies to help us understand how you engage with our marketing and to help provide you with relevant marketing about our products when you visit other websites, including through targeted advertising. If you do not wish for Cotl to use Engagement or Marketing Cookies when you visit our website, you may opt-out through our Preference Center, or through the link at the bottom of our homepage called “Your privacy choices.” Our websites also recognize browsers’ Global Privacy Control signals and will suppress the use of Engagement and Marketing Cookies when these signals are present.
In addition to the tools provided by Cotl, you may also use tools provided by the Networking Advertising Initiative, the Digital Advertising Alliance, and Google Analytics’ Ad Settings to control how these types of Cookies are used when you are on the internet, even when you are not on Cotl’s website.
YOUR OPTIONS REGARDING PERSONAL INFORMATION COLLECTED BY COTL
This section describes how you can access and control the information that Cotl may have about you. It applies to all consumers worldwide, including individuals who have purchased goods or services from Cotl or who believe that information about them may have been provided to us by a third party. Depending on where you reside, you may have additional rights beyond what is described in this section. If you are a U.S. resident of a state with a comprehensive privacy law or reside in a jurisdiction outside the United States, please review the sections "Information for U.S. Residents of States with Comprehensive Privacy Laws" or “Information for Visitors Outside the United States” for more information about your rights.
Confirmation of Possession of Information Related to You. Upon a verified request, subject to the privacy interests of others and technical limitations, solely to the extent we are legally required to do so, Cotl will provide you with information about whether we hold any information related to you. At Cotl’s sole discretion, unless otherwise required by law, we may, in some instances, correct or delete information upon a verified request. Please note that in certain circumstances, we may be required by law to retain your personal information or may need to retain your personal information to continue providing a product or service to you or another customer.
If you would like to submit a request about your data, you may do so by emailing us at support@cotl.pet. You may also be asked to provide additional information to verify your identity.
Opting Out of Promotional Email. You can opt-out of promotional emails by using the “Unsubscribe” link and following the unsubscribe instructions in an email you receive from us. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at support@cotl.pet.
Opting Out of Marketing Calls. If you wish to be placed on Cotl’s internal “Do Not Call” list, you can tell us either while speaking to us on the phone or by emailing us at support@cotl.pet.
Opting Out of SMS/Text Messages. If you wish to stop receiving SMS or text messages from Cotl, you can reply STOP to any SMS/text that you receive from us.
COTL’S SECURITY AND IDENTITY VERIFICATION PRACTICES
Cotl is committed to protecting the personal information that we collect and ensuring our products and services are provided in a secure manner. We have implemented security measures designed to protect the personal information that we maintain. This includes implementing physical, technical, and administrative safeguards to secure the information we collect. We use industry-standard SSL/TLS to transmit payment card information. We also regularly monitor our systems for possible vulnerabilities and attacks.
Regardless of the measures and efforts that Cotl takes to protect personal information, we cannot guarantee absolute protection and security of your personal information. For instance, when we transmit documents to you via mail delivery services or electronically, there remains the possibility that this information may be misdirected, misdelivered, or intercepted.
We encourage you to take precautions in protecting the information that you share with Cotl. For example, we encourage you to set strong passwords on your account and avoid sharing your password with anyone. Where available, we encourage, and may at times require, you to utilize multi-factor authentication to further ensure access to your account is restricted.
If you believe that you have discovered a security vulnerability in our website or services, you may let us know by emailing us at support@cotl.pet. If you believe that someone has accessed your personal information or that your personal information has been misused, please let us know immediately emailing us at support@cotl.pet.
INFORMATION FOR U.S. RESIDENTS OF STATES WITH COMPREHENSIVE PRIVACY LAWS
If you are a U.S. resident of a state with a comprehensive privacy law, this section provides information regarding your rights, and Cotl’s responsibilities, regarding your personal information.
Certain states have privacy laws that provide consumers with rights regarding their personal information, such as the right to request:
Specific information about what information Cotl has collected about you,
A copy of your personal information,
Corrections to inaccuracies in the personal information Cotl maintains about you, and
The deletion of your personal information.
These rights are not absolute, and in some circumstances, Cotl may decline to satisfy your request. For example, if we are unable to verify your identity or if your request impacts other people’s privacy rights, we may deny your request to exercise these rights. We may also deny your request when Cotl has the legal right to do so, such as when we have an ongoing business relationship with you, an ongoing need to use the information for purposes outlined in this Privacy Policy, or we are legally required to retain your personal information. If Cotl denies your request to exercise your privacy rights, we will tell you why we are denying the request and provide you with information about how to appeal this decision.
If you choose to exercise your privacy rights, we will not charge you different prices or provide a different quality of services unless those differences are related to your personal information.
HOW TO SUBMIT A REQUEST FOR ACCESS, CORRECTION, OR DELETION OF PERSONAL INFORMATION
If you would like to submit a request about your personal information, we encourage you to do so by emailing support@cotl.pet.
After you submit the request, you will be asked to verify your email address and may also be asked to provide additional information to verify your identity. Cotl will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. If this is not possible, Cotl may request you submit additional information for verification, such as proof of residency or redacted government-issued identification.
You may also designate an authorized agent to make a request on your behalf. To designate an authorized agent, you must provide Cotl with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney. You will also be required to submit both your and the authorized agent’s valid government-issued identification.
HOW TO APPEAL A DENIAL OF A REQUEST FOR ACCESS, CORRECTION, OR DELETION OF PERSONAL INFORMATION
If Cotl denies your request about your personal information, you may submit an appeal of the decision by emailing support@cotl.pet.
Once an appeal is submitted, the request and Cotl’s response will be reviewed. In connection with this review, Cotl may request that you submit additional information regarding your request. We will notify you of the outcome of the appeal within 60 days.
SELLING, SHARING, AND USE OF PERSONAL INFORMATION FOR TARGETED ADVERTISING
Cotl does not "sell" this information for money. However, we engage in routine online activities with third parties in ways that could be considered a "sale" or "sharing" as defined under applicable law. If you would like to opt-out of the use of your personal information for these purposes, you can submit this request through the email below.
INFORMATION FOR CUSTOMERS AND VISITORS OUTSIDE THE UNITED STATES
Cotl’s site, products, and services are only intended for residents of the United States. If you do not reside in the United States, please do not use the site, products, or services.
CHANGES TO THIS POLICY
We may update this privacy policy to reflect changes to our practices at any time without prior notice to you. We encourage you to review this page periodically for the latest information on our privacy practices.
If you have any questions regarding our Privacy Policy, please contact us by emailing support@cotl.pet.