Last Update Published December 2023
Please read the following Privacy Policy Agreement before downloading or using the CoGoCards Software Application(s) or CoGoCards services. This Privacy Policy forms part of our Terms and Conditions which constitute a legal agreement between you and CoGoCards Pty Ltd.
1.0 Our Privacy Policy – Protecting Your Privacy
CoGoCards Pty Ltd accepts and abides by all statutory obligations to protect your privacy which we strongly acknowledge and respect. Additionally, we also seek to demonstrate our moral obligation, and believe we have a social obligation, to uphold your privacy rights in the complex global digital environment. We shall never knowingly release or share, your personal or company information to any party, other than to those you have permitted, or to those with whom we work with directly both internally and externally in confidential product development, and systems management and operations. Through third party web service application providers, our system is ISO certified, and we operate with AICPA SOC 2 Type II compliance. We have ensured that our mobile phone and web applications are highly secure, and we safeguard your privacy with our fullest ongoing commitment utilising the technology that is available to us. This policy statement is designed to deliver full transparency to you, and also states the reasonable limitations of our actions to protect your privacy through world-class third-party web service providers, such as Amazon Web Services. This policy, whilst protecting your privacy, also serves to protect and enforce by fair and reasonable limitation our business equally against accidental errors, or omissions on our behalf, and against malicious acts in the form of any attempt by any party, or entity, or technological capability to compromise the security of the private information we store, process, and manage, that we cannot reasonably have been expected to protect against.
2.0 Contact Us If You Have Any Questions or Concerns
If you encounter any issues affecting your privacy, or the privacy of others from the use of our services, or have any questions, or concerns, or suggestions for us to improve our policy, please email developer@cogocards.com. If you consider the matter to be a fundamental breach of your privacy, or the privacy of others may be at risk, you should escalate your concerns immediately to mobile +61 426 830 018 or to developer@cogocards.com.
3.0 Introduction and Definitions
This Privacy Policy describes how we collect, store, use and protect personal information. The policy explains how we handle information when you use any of our services either digitally, or through communication directly with us by any other means. The policy forms part of our Terms and Conditions which you must agree to before being granted access to our digital services. Agreement to our Terms and Conditions, binds you and your use of our services to this Privacy Policy. Under this policy the terms and definitions used in this Privacy Policy have the same meaning as those in our Terms and Conditions and vice versa. The following definitions which apply in this policy are below to help you understand it:
3.0.1 CoGoCards Pty Ltd – is the registered trading entity to which you have chosen to subscribe for services, whether free or paid, and under which you have agreed to trade in full accordance with this Policy and our Terms and Conditions. In this Policy we may refer to “CoGoCards Pty Ltd” in full by its registered name, or by “our”, “our business”, “CoGo”, “CoGoCards”, and “we”, “us”, “CoGoCards.com”, “Service”, “Product”, “our website”, or any other form of name or description not mentioned here, where the intent is to appropriately identify our business under this Policy.
3.0.2 Services – or “service”, “product”, or “products” means the product and service feature suite that you can access through the CoGoCards.com mobile and web applications to create and manage business cards, share and sub-share your business cards, and create and manage advertising and promotional campaigns. To provide efficient, effective commercial services of value to you, CoGoCards Pty Ltd collects and stores personal information that enables delivery of its services to you.
3.0.3 Privacy – your legal right to keep your personal information private and confidential between yourself and CoGoCards Pty Ltd, and to elect to share it with only those you choose, or to relinquish it as you choose in broader networking endeavours, and or in advertising or any other legal format you choose.
3.0.4 You – are any of the following, or visa-versa if referred to in this Policy as the “user”, “consumer”, “client”, “free user”, “freemium customer”, “buyer”, “paid customer”, “company”, “person”, “adult”, “supervised minor”, “purchaser”, “sole trader”, “business”, “club”, “charity”, “your”, or any other recognised reference to someone, or a commercial business, or not for profit entity that has agreed to our Contract Terms and Conditions of Use.
3.0.5 Personal Information - means any information (including sensitive personal information) relating to an identifiable human person. An identifiable person is one who can be identified, directly or indirectly by reference to an identifier such as a name, address, telephone number, mobile number or e-mail address, an identification number, location information, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. We treat your personal information, and personal sensitive information as confidential. For the purposes of definition and the interpretation of this policy “personal information” includes “business and company information”, and vice versa.
Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you, nor aggregated shared data template information which is defined in section 4.0.7 of this policy.
3.0.6 Business and Company Information - means any information (including sensitive business information) relating to an identifiable legally registered and recognised, trading business entity. An identifiable business is one that can be identified, directly or indirectly, by reference to an identifier such as a registered business name, address, telephone number, mobile number or e-mail address, an identification number, location information, an online identifier, or by one or more factors specific to the physical, economic, legal, cultural, or commercial identity of that business. We treat your business information as confidential. For the purposes of definition and the interpretation of this policy “Business and Company Information” includes “Personal Information”, and vice versa.
4.0 What Data Do We Collect
CoGoCards Pty Ltd collects and stores personal information that enables delivery of its services to you, and we do so in accordance with the legislation that controls the collection and use of personal information in the countries in which we operate. Our commercial activities are designed specifically to comply with all governing legislation, so that you are afforded the best protection of your personal information.
We take all reasonable steps to comply with legislation that requires us to delete, modify, or supress personal information at the request of the user, whilst it is legal to do so, and or, to make it accessible to the statutory authorities of the countries in which we operate for the purposes of lawful compliance, including national and international security directives by authorised agencies of government.
We take all reasonable steps to comply with all third-party software and hardware suppliers’ privacy policies, and where appropriate and permissible by them, include their terms under this Privacy Policy of which they form a part, with the intent that users are afforded the best protection of their personal information in collaboration with some of the best-practise companies in the world such as Amazon Web Services, Google, and Apple Inc.
The personal information we collect and use when you purchase or use our services includes the information you provide to CoGoCards Pty Ltd as part of a subscription undertaking (either paid or free), or when
enquiring, or communicating with us in any other way. We collect and protect the following data:
4.0.1 User Profile Data – including names, addresses, contact details including phone numbers, email addresses including country of residency and user operation, company position descriptors, age, date of birth, social media links and information, registered business entity information which is generally publicly available, user website links, geo-location data, and other information provided by users that is relevant to the provision of our services, including information we provide to users, and username and password login details.
4.0.2 Payment Data – includes the banking details you supply during transactions to pay for services through our third-party transaction gateway providers. Whilst this information is keyed by users into our application to pay for servicers, we do not store this data, but it may be retained by our third-party transaction gateway providers under their terms and conditions.
4.0.3 Networking Data – includes networking performance information which is collected as you utilise our services by sharing your CoGoCards, and when others sub-share your CoGoCards, or when you use other features and products of our services or visit content on our website or our related websites and services. This information allows users to track, and generate reports on, their own networking activity, and any performance metrics made available to users by CoGoCards for services they have subscribed to. This information is available only to the subscriber under their own account and is not available to the general public or other subscribers, or to third parties unless disclosure is required by law.
4.0.4 Internal Business Data – includes networking data, and the collection of various user metrics, and metadata which we use within CoGoCards to help refine and develop our products and services for improved user experiences, and to help create new and valuable user asset content, features, and deliverable benefits to users which value-add to our products and services in the market. We use this information for internal betterment of our business products and services only, and we do not disclose this information, trade it, or sell it to any third parties, unless disclosure is required by law.
4.0.5 General Summary Metrics Data (GSMD)– CoGoCards does collect, refer to, report on, and utilise aggregated general summary metrics data for external and internal marketing and sales purposes. We gather GSMD from user profile data, networking data, and payment (subscription type and revenue only) data. The purpose and use of aggregated GSMD analytics, is to help us fine-focus marketing and advertising strategy and investment expenditure, develop market relevant communications and promotions in conjunction with general media advertising platforms such as Google, Meta, Television and Radio, to assist in targeted sales campaigns, based on general summary information such as, for example, age, gender, business size and industry type, location, and web site page visitation and frequency. The use of personal data which could cause a person to be identified to the public, directly or indirectly by reference to an identifier such as a name, address, telephone number, mobile number, e-mail address, or business name does not form part of the data used in collection and use of GSMD.
4.0.6 Cookies Data and Web Beacons – CoGoCards uses session cookies (which expire once you close your browser) and persistent cookies (which remain on your device until you delete them) to determine if you are logged into your account on your device, and to recognises repeat visitors. We send cookies to your device, which are small text files used commonly by nearly all web site applications, to uniquely identify your browser and improve the quality of performance of our service on your device. Cookies store some information about your preferences and past actions, and if you disable cookies through your web browser some of our services may not work. We do not store any cookies outside of the CoGoCards.com domain. From time to time we may allow authorised third parties to set cookies or use web beacons on our products and services for the purpose of GSMD analytics. Web beacons are generally a small single pixel image file which are embedded in a web
page application or email to transmit information back to CoGoCards to determine whether a user ha
clicked a web page or opened an email. Web beacons are used only in GSMD analytics to help us improve our services and user experiences.
4.0.7 Aggregate Shared Data Template - Our business product and service in its digital form is fundamentally a traditional ‘business card’ composed and created and shared in a digital format over mobile phones. As such the CoGoCards digital business card format is designed and defined as an ‘Aggregate Shared Data Template”, which users subscribe to (free or paid) to utilise under our Terms and Conditions, for the purposes of networking and advertising their own businesses, or own person, or other legal entity. Because of the nature of our products and services, the image and text assets on CoGoCards, including your business logo, profile picture, name, email and business address, phone number, and position title, (supplied in part or in full) are defined under this Privacy Policy and our Terms and Conditions, as publicly available information collected for the purposes of digital display, printing, pin-boarding, sharing, sub-sharing, viewing, transmission, and advertising on and within the CoGoCards application. Therefore, for the purposes of interpretation by the user, and use of our product and services under our Terms and Conditions, users should be aware that the front and or rear image(s) and text elements of CoGoCard(s) is defined as Aggregate Shared Data, and as such, is not personal information, and can be accessed by the general public on the CoGoCards platform. This policy provision is in place to help users avoid accidental disclosure of information on their CoGoCard which they may not wish to disclose publicly. Equally, the intent of the definition of Aggregate Shared Data Templates, is to help users disclose relevant information on their CoGoCards that it freely permits, for the enablement of effective engagement with our product and services, so that commercial opportunities can be realised on our publicly available business and social networking and advertising platform.
5.0 How Long Do We Keep Your Data
Your user profile data is retained by CoGoCards for the period a user has an active subscription, and if it elapses or is cancelled, your profile data is deleted after thirty (30) days to help protect your privacy. Cookie’s data can be deleted by users at any time under their own browser control. GSMD is deleted if it is not required by CoGoCards or may be kept in perpetuity if it wishes to retain historical reportable general summary information for sales and marketing purposes.
6.0 How Do We Keep Your Information Secure
CoGoCards has reasonable and appropriate security procedures and assets in place to ensure your personal information is not accidentally released, disclosed, misused, altered, lost, destroyed, or maliciously accessed or used in an unauthorised or illegal way. We limit access to your personal information to those directly employed by CoGoCards Pty Ltd who have a genuine business need to access it. Those employees processing or accessing your personal information do so in an authorised manner under our privacy protection protocols and are subject to a duty of confidentiality under their terms of employment, and under the law.
We use recognised international standard (ISO) third party security protection, carrying AICPA SOC2 cyber-security certifications to ensure the best protection of your personal information.
7.0 Withdrawal of Consent to Use Personal information
You may withdraw your consent for CoGoCards to process your personal information at any time, by cancelling your subscription which effects an immediate withdrawal of consent for us to use your personal information. If you are a business with multiple employees managed on the CoGoCards application, you can also deactivate specific users as required, which also effects an immediate withdrawal of consent to use their personal information and your related business information which is specific to that employee. Additionally, you can notify us in writing to withdraw your consent by emailing developer@cogocards.com. If you withdraw your consent to use personal information, you will not be able to use the CoGoCards application and services. You may review, update, correct, or delete your personal information at any time from within the CoGoCards application itself, or by emailing us at developer@cogocards.com.
8.0 Legal Basis for Processing and Storing Your Personal Information
CoGoCards will only collect and process your personal information where we have a lawful basis to do so in the supply and management of our products and services. This legal basis includes:
8.0.1 Consent – where you have given your formal consent under our Terms and Conditions to process and use your personal information.
8.0.2 Contract – where our use of your personal information is necessary for performance of a contract that we have with you such as a subscription for services.
8.0.3 Legal Obligation – where use and processing of your information is required by us to comply with the law.
8.0.4 Legitimate Interests – Where our use of your personal information is necessary for our legitimate interests, or the legitimate interests of our approved and certified third-party suppliers, such as Apple, Google, and Amazon, so that we can effectively manage, operate, process, and administer our business and the supply of our products and services to you.
9.0 Legal Transfer of Your Personal Information
We may share or transfer your personal information as part of a sale of CoGoCards Pty Ltd, or re-structure, divestment in part or in full, or merger or acquisition by another company. The information will only be shared or transferred in an authorised manner under our Terms and Conditions and this Privacy Policy. As part of any form of commercial business transaction process or negotiations, the parties shall be bound by the reasonable enforceability of our Terms and Conditions and Privacy Policy with you and us and shall remain therefore subject to a duty of confidentiality as part of the terms of any discussions, negotiations, and or transaction, and under the law. Prior to such transfer you will be notified through our web site services.
We may transfer your information to certified third party suppliers under contract arrangements with those suppliers, who may hold (store) your personal information in secure data centres outside of your country of residence, for the purpose of managing and distributing data storage loads for performance optimisation, efficient operations, redundancy protection, information security, and other legitimate interests requiring the sensible location, re-location, transfer, or other confidential movement of your personal information.
We may transfer or provide your personal information to authorities if we are legally required to do so under the laws of the country in which you reside, and or, to international security agencies, or other government law enforcement agencies in countries within or outside of the country of your residence, that require us under local, national, or international laws to share your information or surrender it in part or in full in accordance with the law.
We may transfer and or disclose your information to protect and defend the rights or property of CoGoCards Pty Ltd, to prevent or investigate possible wrongdoing in connection with our products and services, to protect the personal safety of users of our services or the public, and to protect against legal liability.
10.0 Advertising & Marketing
From time to time we may send you marketing and advertising communications about our products and services which might be of interest to you, where we have your consent to do so, or it is in our legitimate business interests to do so. You may at any time unsubscribe from marketing and advertising communications by emailing us in writing to developer@cogocards.com or by using ‘unsubscribe’ links in any of the communications you receive from us.
We may also use aggregate information on our website for marketing and advertising purposes to help us generate business activity through image-based demonstration and display of aggregated information including aggregate shared data templates.
11.0 Voice and Conversation Recording
We do not record conversation when you contact us by telephone, or when we contact you, for any purpose. We will take missed-call voice message recordings of telephone calls made to us by users to enable customer service call backs to you. These recordings are permanently deleted once the call back has been made.
12.0 Your Rights
Under national and international data protection regulations we seek the fullest level of active compliance, and so reasonably act, behave, and conduct our business and supply of our products and services according to those laws which broadly enforce some of the toughest privacy and security laws in the world. In summary your rights include:
12.0.1 Fair and reasonable processing of your personal information, transparency over its content and how we use your personal information, and your reasonable access to a copy of your personal information it if you request it, provisioned to you in a structured, commonly used format.
12.0.2 Requirements from you to correct personal information mistakes, errors, or omissions.
12.0.3 Requirement from you to erase personal information concerning you in certain circumstances.
12.0.4 Object to any use by us of your personal information for marketing or advertising purposes which you determine you do not accept, and wish to be removed, or the transmission of information ceased.
12.0.5 Request the cessation or restriction of the processing and use of your personal information under certain circumstances.
12.0.6 Ability to lodge a dispute for any possible misuse of your personal information which you feel has occurred, or may occur, with the recognised Data Protection Authority in your country of residence.
12.0.7 Provision to you of a copy of your personal information in a structured, commonly used format free of charge, once per year if you require it, or more often at your expense.
12.0.8 Right to non-discrimination. We will not discriminate against you in any manner prohibited by law for exercising your personal information rights.
12.0.9 Protection of your personal information against the sale of it to third parties, both now and in the future, without providing you with notice and an opportunity to opt-out of such sale as required by law.
12.1 How to Exercise Your Rights
If you would like to exercise any of your rights, or have any questions or concerns, please email us at developer@cogocards.com. We will need to verify your identity before we can discuss information with you about your rights. We will provide details for the verification process on receipt of your communication to us.
13.0 Limitation of Liability
We exercise reasonable industry leading efforts to safeguard the security and confidentiality of your personal information, and payment data; however, processing, storage, transmissions, and communications protected by industry standard technology cannot be guaranteed to be secure. We will not be liable for unauthorised disclosure or theft of personal information and payment data that occurs through no fault of CoGoCards including, but not limited to, errors in transmission, access to your account by anyone but you, use of your user ID and password by a third party, your failure to comply with your security obligations, and the unauthorised acts of CoGoCards employees.
14.0 Access to Services by Minors
Our services do not address anyone under the age of eighteen (18) years old, without parental consent, and we will never knowingly collect, process, or store the personal information of children under the age of 18. If a user, parent, or guardian becomes aware that a minor has gained unauthorised access to, and or becomes subscribed to our services, then you are obliged under our Terms and Conditions and this Privacy Policy to notify us by emailing developer@cogocards.com. If we become aware that any unauthorised minor under the
age of 18 years old, has provided us with personal information, or subscribed to our services, we will take appropriate action to report and record the instance for legal protection against liability, and then delete the information from our files and any storage device. We will take to record the date of such deletion. If we become aware of any wrongdoing in respect to information which is processed, accessed, stored, or used which belongs to any person under the age of 18, we will immediately notify appropriate law enforcement agencies in the jurisdiction of the country in which the instance has occurred, and make accessible to such agencies the personal information of the minor and any other related information that we have collected which may reasonably be connected to any wrongdoing.
In some CoGoCards applications, certain services are designed specifically for use by educational institutions, and other recognised (registered) social, charitable, sporting, and community institutions, which permits access to CoGoCards by children under the age of 18. This can only be authorised by the minor’s lawful parent or guardian, and sub-sharing cannot be enabled.
15.0 Inappropriate and Explicit Content
We undertake to reasonably moderate all content under high standards of social and moral responsibility, and in accordance with the law. We may do the following if we identify inappropriate and or explicit content, and you will be notified of our actions:
15.0.1 Deactivate and delete a user account.
15.0.2 Permanently ban a user from accessing our services.
15.0.3 Suspend a user account pending an internal review by CoGoCards.
15.0.4 Notify law enforcement agencies, and transfer your personal information if there is, or may be wrongdoing that we reasonably believe has or may occur, or that we detect, intercept, or suspect.
15.0.5 Modify your subscription access and or subscription type to limit functionality.
15.0.6 Activate content display and feature functionality locks (parental controls) to prevent viewing by minors.
16.0 Changes to This Privacy Policy
This privacy policy was published on our web site in December 2023. From time to time we may make changes to this policy and will inform you via our website. You will be subject to, and deemed to have been made aware of, and to have accepted any changes in any revised Privacy Policy by your continued use of CoGoCards products and services.