Privacy Policy

This Privacy Policy describes how Copaly technologies and its affiliates (“Copaly,” “we,” or “us”) collects, uses, stores, shares, and protects your information whenever you use the Copaly Site, mobile application, any API directly or through a third-party application, or buy a Copaly product (collectively, “Copaly Site and Services)

Copaly understands the importance of privacy for our users and only collects the information which is necessary. Your information is only shared with our third-party affiliates when necessary. Within Copaly, access to information is limited to only those in the company who require such information for matters related to compliance, customer support, and verification. Copaly will NEVER sell or rent your personal information to third parties.

This Privacy Policy is subject to change, so please review it from time to time. If Copaly makes changes, Copaly will revise the date at the top of the Privacy Policy. Any changes will become effective when Copaly posts the revised Policy. If Copaly makes any material changes, Copaly will notify you by email or by means of a notice on the Site prior to the changes becoming effective.

By using the Site and Services, you consent to the data and information policies and practices prescribed in this Privacy Policy.

Information we collect

We collect the information you provide to us directly when you use Copaly Site and Services. This information we may collect directly from you includes, but is not limited to, your name, email, phone number, date of birth, address, password, digital currency public key, document scans, government identification number, etc.

If you wish to link a bank account or other payment method, Copaly may collect your account number, routing number, bank card number, or other related account information. As Copaly expands to add additional features, you may be prompted to provide additional information. When we deem it necessary for verification, legal, or other reasons, Copaly may prompt you to provide additional contact information, biographic information, social security number or government-issued information including tax ID number, or financial information.

Collection of Data

Our site uses technologies of third-party partners to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, these partners collect information about your activity on our site(s) to enable us to:

measure and analyze traffic and browsing activity on our site(s);
Opting-Out

Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:

The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

Information Collected Automatically

When you use Copaly Site and Services, the following information is collected automatically: Device

Location

With your permission, Copaly may collect your precise geolocation information and device location in order to offer you location-based services, such as a map of Copaly retailers in your area.

Copaly collects information about your transactions and payment activity on Copaly Site and Services, including the amount, time, date, recipient wallet, and type of trade.

Device

Copaly collects information about the device you use to access Copaly Site and Services, including language, type of device, operating system, mobile phone number, mobile network, and other device identifiers. Copaly also logs information about your activity on Copaly Site and Services, such as access times, pages viewed, other pages visited, and IP address.

Cookies

When you access the Copaly Site and Services, like most websites and apps, we use cookies or other tracking technologies to collect information. Cookies are small data files placed on your computer or other device that allow Copaly to identify you as a Copaly customer and customize the Copaly experience.

We use both session and persistent cookies when you access our website or content. Session cookies are temporary and expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until they expire or you erase them.

You are free to decline our cookies if your browser or browser add-on permits, but removing or disabling cookies may interfere with your use and the functionality of the Copaly Site and Services. Please refer to the help section of your browser or browser add-on for instructions and additional information on blocking, deleting, or disabling cookies.

Information from Third-Parties.

Copaly may collect information on you from third-party services, including, but not limited to, nonpublic personal information from identity verification sources or public databases.

Use of information

Information we collect may be used in the following ways:

Improve and provide a full range of Copaly Site and Services;
Provide information, such as customer service, notifications, and security notices;
To detect and prevent fraud and crime;
To detect and prevent money laundering;
To comply with applicable regulatory requirements;
Send you important information, such as changes in terms, conditions, and policies and/or other administrative information;
Personalize, manage, and improve Copaly Site and Services;
Combine your information with information obtained from elsewhere and others in order to help Copaly understand and improve your needs and personalize and improve Copaly Site and Services and our advertising efforts;
Verify your identity and/or location in order to allow access to your accounts, conduct online transaction, secure your personal information, and in order to prevent fraud and illegal or unauthorized activity, enforce our user agreements, and comply with laws and regulations;
For business purposes, including data analysis, audits, developing and improving products and services, enhancing Copaly Site and Services, identifying usage trends and determining the effectiveness of promotional campaigns;
Resolve disputes and troubleshooting problems;
Respond to your inquiries and fulfill your requests;
Direct marketing and promotional offers on behalf of Copaly and its partners and associates, including via SMS and email; and Fulfill any other purpose for which the information was collected. Copaly will never sell or rent your personal information to any third parties. We will only use or share your information according to the terms of this Policy.

Protection & Storage of Information

Protection and security of your personal information is important to us. Copaly protects your information, including any non-public personal information that can be used to identify you, such as your government-issued ID number, by using reasonable physical, technical, and administrative security measures. This includes limiting access of your information to employees with only information they need to know to reduce the risks of alteration, disclosure, loss, misuse, and unauthorized access. All of our procedural safeguards are designed to comply with generally accepted standards and applicable laws and regulations. Copaly will store and protect your information securely during and after the life of your Coplay account in compliance with our legal obligations. If you have any questions or concerns about our security measures, you may contact us through our Support Page.

Sharing of Information

Copaly may share the information we collect from you in the following ways.

Copaly will sometimes need to share your information with third-party identity verification services in order to prevent fraud and confirm the validity of information provided against public records. By using Copaly Site and Services, you acknowledge and consent that these service providers may retain and use your information to perform services for Copaly and improve their own services, solely related to identity verification and fraud prevention services.
Copaly will sometimes need to share information with service providers performing legal, marketing, and other services on our behalf, sometimes related to the analysis and improvement of the Copaly Site and Services experience.
Copaly may need to share your information to complete a routine third-party financial, legal, or technical audit of Copaly’s operations.
Copaly may need to share your information with local and foreign law enforcement, government officials, or other third parties when compelled to do so by a subpoena, court order, or other legal procedure, or when we believe in good faith that disclosure is necessary to prevent any physical harm, financial loss, to report suspected illegal activity, or to investigate potential violations of our User Agreement.
In the event of a merger, acquisition, or other purchase of Copaly’s assets by another company, that company will have access to the information you have provided to Copaly. We will require that the new entity follow the procedures of this Privacy Policy and notify you of any such change in applicable policy.
We will only share your information with other third parties with your direct consent or direction to do so, unless we are lawfully permitted to do so without your consent.
Copaly may also share, with affiliates or non-affiliated third parties, anonymized, de-identified information which cannot be reasonably used to identify you.

Transborder Transfers of Personal Data

We may transfer your personal data from the country where it was collected to any third party in a foreign country that may not have data protection laws similar to those of the country of collection, for cloud storage purposes or for any other legitimate purpose.

Privacy of children under 18

You must be at least eighteen (18) years old to use Copaly Site and Services. Copaly does not intentionally collect any information from or about any individual under the age of 18.

How to access and edit your information

You can access, review, and edit your personal information from the Settings or Account page after you log in to your Copaly account. If you are unable to edit the information from your account, please contact us through our Support Page for assistance. Copaly may provide you with a copy of the information we keep on you upon request; however, not all information on your account will be made available, such as full government identification number, in order to protect your identity and privacy against fraud. If you close your Copaly account, we will retain your account information in our databases for the required number of years to comply with the various laws and financial service regulations governing Copaly.

Contact us with questions

Please contact Copaly directly through our Support Page with any questions or concerns regarding this Privacy Policy.

Disclaimer

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL COPALY, ITS AFFILIATES AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS OR CONTRACTORS BE LIABLE FOR ANY INCIDENTAL, INDIRECT, SPECIAL, PUNITIVE, CONSEQUENTIAL OR SIMILAR DAMAGES OR LIABILITIES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF DATA, INFORMATION, REVENUE, PROFITS OR OTHER BUSINESSES OR FINANCIAL BENEFITS) ARISING OUT OF COPALY SERVICES, ANY PERFORMANCE OR NON-PERFORMANCE OF COPALY SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM PROVIDED BY OR ON BEHALF OFCOPALY AND ITS AFFILIATES, WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY EVEN IF COPALY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES EXCEPT TO THE EXTENT OF A FINAL JUDICIAL DETERMINATION THAT SUCH DAMAGES WERE A RESULT OF COPLAY GROSS NEGLIGENCE, FRAUD, WILLFUL MISCONDUCT OR INTENTIONAL VIOLATION OF LAW. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU.

NOTWITHSTANDING THE FOREGOING, IN NO EVENT WILL THE LIABILITY OF COPALY, ITS AFFILIATES AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS OR CONTRACTORS ARISING OUT OF SERVICES OFFERED BY OR ON BEHALF OF COPALY AND ITS AFFILIATES, ANY PERFORMANCE OR NON-PERFORMANCE OF COPALY SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM, WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY, EXCEED THE AMOUNT OF THE FEES PAID BY YOU TO COPALY UNDER THESE TERMS IN THE TWELVE-MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM FOR LIABILITY.eight