Privacy Policy

Last Updated: June 13, 2021

This privacy policy (“Privacy Policy“) explains how CoBe Labs Ltd. (“CoBe“,”CoBe Labs” “we“, “our” or “us“) collect, use and share information about you. We have created this Privacy Policy in keeping with our commitment to protecting your privacy, to comply with global data protection laws and regulations, and to keep you informed about our personal information protection practices. This Privacy Policy forms part of our Terms of Use. This Privacy Policy applies to CoBe Labs collection and use of personal information belonging to you or other persons, such as in the following use cases:

  • When you browse or visit our service, website or platform (collectively, the “Service”), whether through a third party platform or otherwise;
  • When you subscribe for a free trial to our Service and when you subscribe for an account;
  • When you subscribe to our distribution list(s), newsletter(s) and/or blog(s);
  • When you contact us (e.g. customer support, need help, submit a request);
  • When you attend a marketing event and provide us with your personal data;
  • When we use the personal data of our service providers (e.g. contact details);
  • When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn).

We make every effort to provide a Service that lives up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What Information We Collect, Why We Collect It, And How It Is Used
  2. How We Protect And Retain Your Information
  3. How We Share Your Personal‎ Data
  4. ‎Your Privacy Rights
  5. ‎Use By Children
  6. ‎Interaction With Third Party Products
  7. Log Files
  8. ‎Analytic Tools and Third Party Software
  9. Your Choices
  10. ‎ California Notices
  11. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Service or by other means. Please check the “Last Updated” notice at the top of this to see when the Policy has been most recently updated. Your continued use of our Service constitutes acceptance of any changes to this Policy.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

When you browse, or visit, our Service, we collect data about you through cookies, analytic tools and log files. A “cookie” is a small text file that may be used, for example, to collect information about activity on our Service. Certain cookies and other technologies may serve to recall personal data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. For more information, please read our cookie policy available at: https://www.cobelabs.com/cookies.We collect this data in order to analyze trends, administer the Service, track users’ movement around the Service, and gather demographic information. We use anonymous identifiers in order for us to present you with customized information, and in order to track users. We also use Google Analytics to maintain and improve the Service and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

When you sign up for a free trial to our service, when you sign up and subscribe for an account and when you use our Service through a third party’s website or platform, we currently do not ask you for any Personal Data. We may in the future request you for some Personal Data for certain services, such as your full name, email address and phone number. We also may determine your IP address. Please note that at the moment, if you reach our service without being referred by a clinic, we will need to collect your email address. We do not share this information with third party platforms or websites, except if you approach us online through a clinic or other entity, we will share this information with this clinic or other entity, and if you are using our Service through a third party website or platform, the abovementioned information may be exposed to such third party, and subject to its privacy policy. Please note that any information you share with a third party website or platform through which you use our Service, we will be exposed to that information, subject to the website or platform privacy policy.

If you wish to subscribe to our newsletter, you must provide us with your email address. We collect this information to send you our newsletter and send you marketing communications.

When you contact us (e.g. customer support, need help, submit a request), you will need to provide us with the information, such as name, email address, country, and any messages or other information you wish to share with us. We use this information to answer your questions and to provide support (e.g. to solve problems, bugs or issues). We may in the future share this information with third party platforms, such as ZenDesk, which may assist us with customer support.  We also use your name and e-mail details that you provide us with in order to send you marketing communications.

When we use the Personal Data of our service providers, we collect the Personal Data they provide to us, such as: full name, email address, phone number, company name, job title, country, and any other data our service providers may choose to share with us. We collect this information in order to communicate with and perform the applicable agreement with our service providers. Please note that some of the abovementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

Finally, please note that we do not intend to collect identifier information and we aim to delete it, in accordance with local data retention laws. However, we do collect Anonymous Information, such as age, gender, and approximate locations, for the purposes of research and analytics and in order to improve our service experience and personalization.

  1. HOW WE PROTECT AND RETAIN YOUR INFORMATION
  • Security. Information that is transmitted via the internet may not always be fully secure. While we have implemented appropriate technical, organizational and security measures designed to protect your personal data, please note that we cannot guarantee that information you share will not be compromised as a result of unauthorized penetration to our, or other’s, servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your information including user IDs and passwords, please make sure to take appropriate measures to protect this information.
  • Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
  1. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may also share your personal data as follows:

  • as needed to enforce CoBe Labs’ Terms of Use, policies and any other contractual relationships with our customers;
  • when we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our Service or products against possible attacks, or protect the property and safety of CoBe Labs, our customers or the public;
  • as required by law, such as to comply with a subpoena, warrant, regulatory oversight or similar legal process;
  • with the professional(s) who referred you to our Service;
  • to third parties for research, including by academics, which will often be on an anonymized or de-identified basis; or
  • to third parties which host the Service, such as Amazon Web Services.
  1. YOUR PRIVACY RIGHTS.
    Rights:  You may have certain rights under applicable privacy laws, such as accessing, correcting and deleting Personal Data, objecting to processing of Personal Data, withdrawing of consent to processing Personal Data. To the extent such privacy laws apply to you, we will respect your rights and comply with such laws.

    You can exercise your rights by contacting us at info@cobelabs.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes. We reserve the right to charge an appropriate administrative fee where permitted by law. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.                                                   
  1. USE BY CHILDREN
    We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of thirteen (13). If you are under the age of thirteen (13), do not provide any personal data to us without involvement of a parent or a guardian. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at: info@cobelabs.com.
  1. INTERACTION WITH THIRD PARTY PRODUCTS
    You may need to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect personal data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
  1. LOG FILES
    We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser, third party direct messaging platform, or mobile device may send to us. We use such information to analyze trends, administer the Service, track users’ movement around the Service, and gather demographic information.
  1. ANALYTIC TOOLS AND THIRD PARTY SOFTWARE
    • Google Analytics. The Service uses a tool called “Google Analytics” to collect information about use of the Service. Google Analytics collects information such as how often users visit this Service, what pages they visit when they do so, and what other Services they used prior to coming to this Service. We use the information we get from Google Analytics to maintain and improve the Service and our products. We do not combine the information collected through the use of Google Analytics with Personal Data we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Service is restricted by the Google Analytics Terms of Service, available at https://marketingService.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
    • MailChimp. We currently use software called “MailChimp”, an email marketing and analytics platform to understand the use of our services. MailChimp’s terms of use (available at: https://mailchimp.com/legal/terms/) and privacy policy (available at: https://mailchimp.com/legal/privacy/) also apply to the use of MailChimp.
      We reserve the right to remove or add new analytic tools or other third party software.                                                
  2. Your Choices
    You have certain choices about your personal data. Where you have consented to the processing of your personal data, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-personal data regarding your activities on our services and for other legal purposes as described above. We will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
  3. California Notices
    • California Privacy Rights. California Civil Code Section 1798.83 permits our customers who 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 info@cobelabs.com. Please note that we are only required to respond to one request per customer each year.
    • Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
    • California Do Not Track Notice: We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Site.
  1. How to contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@cobelabs.com.