Website Privacy Policy

1. Scope

This Website Privacy Policy ("Policy") describes how Coley, Inc., a Delaware corporation ("Coley," "we," "us," or "our") collects, uses, and shares information from visitors to getcoley.com (the "Site").

2. Information We Collect

2.1 Non-Personal Information (Collected Automatically)

When you visit the Site, we may automatically collect non-personal information, including:

• Browser type and version
• Operating system
• Device type (desktop, mobile, tablet)
• Click-stream data (pages visited, links clicked, time spent on pages)
• Aggregate demographic information
• Traffic patterns and referring URLs
• IP address (which may be truncated or anonymized)
• Language preferences

2.2 Personal Information (Provided Voluntarily)

We collect personal information only when you voluntarily provide it through the Site, such as when you:

• Submit a contact form or inquiry
• Sign up for a newsletter or mailing list
• Begin a subscription purchase process
• Apply for a job
• Otherwise communicate with us through the Site

Personal information may include your name, email address, phone number, date of birth, and any other information you choose to provide.

2.3 Health and Accessibility Information

If you voluntarily provide health-related or accessibility information through the Site (for example, in a contact form describing your needs), we will treat that information with heightened sensitivity and use it only for the purpose for which it was provided.

3. How We Collect Information

• Automatically. We use analytics tools and standard web technologies (cookies, web beacons, log files) to collect non-personal information about how visitors interact with the Site.
• Voluntarily. We collect personal information that you provide directly through forms, email, or other communications on the Site.
• From Other Sources. We may receive information about you from third-party sources, but only with your consent or as otherwise permitted by applicable law.

4. Legal Basis for Processing

We process your information based on the following legal grounds:

• Consent. Where you have given us explicit consent to process your information for a specific purpose (e.g., newsletter signup).
• Contract Performance. Where processing is necessary to fulfill a contract with you or to take steps at your request before entering into a contract.
• Legitimate Interests. Where processing is necessary for our legitimate interests (e.g., improving the Site, preventing fraud, ensuring security), provided those interests do not override your fundamental rights and freedoms.
• Legal Obligation. Where processing is necessary to comply with applicable law.

5. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Site
• Respond to your inquiries and provide customer support
• Send you updates, newsletters, and marketing communications (with your consent or as permitted by law)
• Compile aggregate statistics about Site usage and traffic patterns
• Detect, prevent, and address fraud, abuse, and security issues
• Comply with applicable legal obligations and enforce our terms
• Protect the rights, property, and safety of Coley, our users, and the public

6. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• Law Enforcement and Legal Compliance. We may disclose your information when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Corporate Transactions. In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred as a business asset. We will notify you of any such change in ownership or control.
• Affiliated Companies. We may share information with our subsidiaries and affiliated companies, subject to this Policy.
• Service Providers. We may share information with trusted third-party service providers who assist us in operating the Site, including hosting providers, analytics services, security services, and payment processors. These providers are contractually obligated to protect your information and may use it only for the purposes we specify.

7. Data Storage

Your information is stored and processed in the United States. By using the Site, you consent to the transfer and processing of your information in the United States. If you are accessing the Site from outside the United States, please be aware that your information may be subject to different privacy protections than those in your jurisdiction.

8. Security

We implement industry-standard technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and secure data storage practices.

However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your information.

9. Data Retention

We retain your information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide the Site, comply with legal obligations, resolve disputes, and enforce our agreements. When your information is no longer needed, we will securely delete or anonymize it.

10. Job Applicants

If you submit a job application through the Site, the personal information you provide (such as your resume, cover letter, and contact details) will be used solely for evaluating your candidacy. This information is kept confidential and accessible only to authorized Coley personnel involved in the hiring process. We retain applicant data for a reasonable period after the hiring decision has been made, unless you request earlier deletion.

11. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete personal information
• Delete your personal information, subject to certain exceptions
• Object to or restrict certain processing of your information
• Data portability — receive your information in a structured, commonly used format
• Withdraw consent at any time, where processing is based on consent

To exercise any of these rights, please contact us at privacy@getcoley.com. We will respond to your request within the timeframe required by applicable law.

12. Cookies and Tracking Technologies

The Site uses cookies and similar tracking technologies to improve your experience and collect usage data.

• Essential Cookies. Required for the Site to function properly (e.g., security, accessibility preferences).
• Analytics Cookies. Help us understand how visitors interact with the Site. We may use third-party analytics services such as Google Analytics, which collect information about your use of the Site and report trends without identifying individual visitors.
• Marketing Cookies. Used to deliver relevant advertising, if applicable.

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling cookies may affect the functionality of the Site.

For more information about how Google Analytics collects and processes data, visit Google's Privacy Policy.

13. California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of collection, the purposes for collection, and the categories of third parties with whom we share it.
• Right to Delete. You may request the deletion of your personal information, subject to certain exceptions.
• Right to Correct. You may request that we correct inaccurate personal information.
• Right to Opt-Out of Sale or Sharing. We do not sell or share your personal information for cross-context behavioral advertising as defined by CCPA/CPRA. If this changes, we will update this Policy and provide an opt-out mechanism.
• Right to Non-Discrimination. We will not discriminate against you for exercising your privacy rights.

To exercise your California privacy rights, contact us at privacy@getcoley.com. We may verify your identity before fulfilling your request.

14. Direct Marketing

If you have opted in to receive marketing communications from us, you may opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email we send you
• Contacting us at privacy@getcoley.com

Please note that even after opting out of marketing communications, you may still receive transactional or administrative messages from us (e.g., responses to your inquiries).

15. Minors

The Site is intended for users who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe we have collected information from a minor, please contact us at privacy@getcoley.com.

16. Third-Party Websites

The Site may contain links to third-party websites or services. This Policy does not apply to those third-party sites. We are not responsible for the privacy practices or content of any linked third-party website. We encourage you to review the privacy policies of any third-party site you visit.

17. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will provide at least thirty (30) days' notice by posting the updated Policy on the Site with a revised "Last Updated" date. Your continued use of the Site after the effective date of any changes constitutes your acceptance of the updated Policy.

18. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Coley, Inc.
Los Angeles, CA
privacy@getcoley.com