We are committed to safeguarding your privacy and ensuring that your personal data is protected.  This Privacy Policy explains the types of personal data we collect and how we process and protect that data. 

It applies to personal data processed by us in connection with the services we offer. This includes information collected through use of our website https://coolfiresolutions.com/ (the “Site”), our software application, and other products and services, whether collected online or offline.  

This Privacy Policy also applies to our targeted content, including online offers and advertisements for products and services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications (“Third Party Sites”) based on your use of the internet. These Third Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third Party Sites. 

1. Who is Responsible for what happens with your data?

Coolfire Solutions, Inc. (“Coolfire” or “we”) is responsible for the processing of your personal data on this website. You can contact Coolfire via mail at Coolfire Solutions, Attn: Data Protection Officer, 415 N. 10th Street, 3rd Floor, St. Louis MO 63101 or by email at dataprivacy@coolfiresolutions.com if you have any questions.

2. When Do we ask for your consent?

By using our Site, you acknowledge that we are processing your personal data in accordance with this Privacy Policy. If you do not wish that we process your personal data in this way, please do not use our website or otherwise provide our Site with your personal data. 

We process your data to provide you the Site and our products and services. In certain instances, we may only process your data if you have consented, for example in certain cases where we process your personal data for marketing purposes, use cookies or process your sensitive data. Where we process your data on the basis of your consent, we will ask for your consent explicitly but, in some cases and only where permitted by applicable law, we may infer in a transparent manner consent from your actions. We may also ask you to provide additional consent if we need to use your personal data for purposes not covered by this Privacy Policy or before sharing your personal data with affiliates or subsidiaries of Coolfire for the purposes of marketing.  If you wish to discontinue receiving this information, you may update your preferences by using the “Unsubscribe” link found in the emails that we send to you or by contacting us at dataprivacy@coolfiresolutions.com.

3. How do we respect children’s privacy? 

Our Site is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Site. We do not knowingly collect personal data from children under 16.  If you are under 16, do not use or provide any information on this Site or on or through any of its features/register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at dataprivacy@coolfiresolutions.com.

4. For which purposes do we Process your personal data?

Personal Data means information that can directly or indirectly identify you or other individuals (“Personal Data”). This typically includes information such as your name, address, email address, and telephone number, but can also include other information such as IP address, shopping habits, information about health, information about your lifestyle or preferences such as your hobbies and interests. Please see details in the following paragraphs.

We collect your Personal Data directly when you provide us with Personal Data so that you can register as a customer for our subscription plans, subscribe to our newsletter, receive information or mailings, use our applications, buy a product or service from us, complete a survey, make a comment or enquiry or contact our customer services, engage in building solutions with us, or enter into a partnering arrangement with us and our partners. We may also receive Personal Data about you from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties.

In more detail, we process the following categories of Personal Data for the following purposes:

4.1 Surfing on our Site – with or without Cookies

Which Personal Data do we collect about you? – For this purpose (Surfing on our Site) we process the following Personal Data: Information about the type of browser you use, details of the web pages you have viewed, your IP and device address, device type, operating system, geolocation data, your Cookie ID, hyperlinks that you have clicked, your user name, profile picture, gender, networks and any other information you choose to share when using Third Party Sites (such as when you use the “Like” functionality on Facebook), the websites you visited before arriving at our Site and information collected by cookies or similar tracking devices. 

What is the Purpose of Processing your Personal Data? – We (and third party service providers acting on our behalf or on their own behalf) use cookies and similar technologies to process data about you when you visit our relevant Sites or use our application. Cookies are files that store information on your computer hard drive or browser that mean that we can recognise that you have visited us before. We use cookies and similar technologies (like pixels, fingerprints and other tools) to improve our products and your experience on our Site by evaluating the use of our Site, products and services and understand your browsing and shopping habits, analysing the effectiveness of our advertisements, personalising your website experience as well as evaluating statistics on website activity, evaluating (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you’ve visited it before and what site referred you to it, reviewing the products that you have searched online and ended up purchasing them in store, making our Site easier to use and to better tailor our Site and our products to your interests and needs, identifying that you have visited our Site but did not purchase a product or service, collecting information about your device and linking this to your Personal Data so as to ensure that our Site presents the best web experience for you and supplementing the Personal Data that you provide to us with other information that we hold or that we may receive from commercially available sources, such as public databases and data aggregators, and third parties.  You can view more information on the Cookies used via our Cookie Policy and you can contact us to withdraw your consent to cookies, if applicable, or you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. 

How long do we store your Personal Data? – Please check the Cookie Policy to learn about the storage periods for each cookie. 

What is the Basis for Processing your Personal Data? – Your consent, where required, or our legitimate interests in processing data collected from our Site in order to deliver services. 

Additional Comments: It is always possible for you to visit our Site without disclosing your Personal Data. This requires that you have disabled cookies. Where applicable, you can opt out of the processing of such information via the Cookie Banner displayed on our Site or by contacting us to withdraw your consent to cookies. You can also opt out of the processing of cookies by setting your browser to refuse all or some browser cookies or to alert you when cookies are being sent.. Please note, however, that without cookies you may not be able to use all of the features of our Site or online services.

4.2 Contact with You

Which Personal Data do we collect about you? – For this purpose (Contact with You) we process the following Personal Data: first name, last name, email address, user name, mailing address, and telephone number.  

What is the Purpose of Processing your Personal Data? – We process your Personal Data whenever you contact us and respond to your enquiries and comments. We process your Personal Data that you enter when registering for our subscription plans or applications or placing an order or that you subsequently update or amend in your user account. We process Personal Data to provide you with our products or services that you request from us, including responding to your queries or comments, sending you products that you have requested, and sending you product surveys. We look at the products you subscribe to and that you have viewed on our Site. 

How long do we store your Personal Data? – We store your Personal Data for one year after your last enquiry or the end of your relationship with us as a user, customer, or partner, whichever is later, unless we are required by the law to store them for a longer period. 

What is the Basis for Processing your Personal Data? – Performance of the contract with you (i.e. fulfil your contact request). If you provide to us Personal Data that is considered sensitive (e.g. information on your health or ethnic origin): Your consent.

4.3 Suggestion of our Products and Services; Marketing Communication

Which Personal Data do we collect about you? For this purpose (Suggestion of our Products and Services; Marketing Communication) we process the following Personal Data: first name, last name, title, email address, mailing address, telephone number, details of the web pages you have viewed, your IP and device address, your user name, device type, operating system, and geolocation data.   

What is the Purpose of Processing your Personal Data? We process your Personal Data to provide relevant information to customers and users relating to our products and services based both on customer history and user activity.

How long do we store your Personal Data? We store your Personal Data for one year after your last enquiry or the end of your relationship with us as a user, customer, or partner, whichever is later, unless we are required by the law to store them for a longer period.

What is the Basis for Processing your Personal Data? Our legitimate interests in pursuing direct marketing services to you, and where applicable, your consent.

Additional Comments: You can opt out of receiving such communications from us directly from the communications we send you. 

4.4 Creating and Maintaining User Accounts

Which Personal Data do we collect about you? For this purpose (Creating and Maintaining User Accounts) we process the following Personal Data: first name, last name, email address, and your user name.   

What is the Purpose of Processing your Personal Data? We process your Personal Data to maintain and provide services relating to individual user and customer accounts, including purchase history, product registration, performance data, provide personalized service and communications, and marketing services.

How long do we store your Personal Data? We store your Personal Data for up to one year after you stop interacting with your account, unless we are required by the law to store it for a longer period.

What is the Basis for Processing your Personal Data? Your consent, and our legitimate interests in the transmission of Personal Data within a group of undertakings for internal administrative purposes, including client data.

4.5 Subscription Plans 

Which Personal Data do we collect about you? For this purpose (Subscription Plans) we process the following Personal Data: first name, last name, email address, product usage history and performance detail, certain workspace details (when you choose to share such data with us), geolocation data (if permitted by users), user role, and bank account number, credit card number, debit card number, or any other financial information necessary to bill you for the applicable subscription plan. Within your workspace, you are the data controller, meaning that you will determine the purposes and means of the processing of Personal Data within your workspace. Coolfire will act as a data processor of Personal Data within your workspace. 

What is the Purpose of Processing your Personal Data? We process this Personal Data to provide you with and facilitate delivery of our subscription plans and to provision the workspace that corresponds to the subscription plan you select. We also process this Personal Data to provide you with services related to your subscription plan and workspace, such as support services or to assist you with onboarding, customization, or training. 

How long do we store your Personal Data? We store your Personal Data for up to two years after you stop interacting with your account, unless we are required by the law to store it for a longer period.

What is the Basis for Processing your Personal Data? Performance of the contract with you, or in order to take steps at your request prior to entering into a contract, and our legitimate interests in the transmission of Personal Data within a group of undertakings for internal administrative purposes, including client data and, where applicable, your consent.

4.6 Product development, engineering, performance, and enhancement. 

Which Personal Data do we collect about you? For this purpose we process the following Personal Data: first name, last name, email address, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, geolocation data (if permitted by users), and product usage history and performance detail, including access details, device data and log files/actions within apps for product use analysis, product performance, enhancement and product development.

What is the Purpose of Processing your Personal Data? We process this Personal Data to learn about the usage, and improve the performance and features, of our products and services, and improve research and product development. We also process this Personal Data when you engage in product development or partnering arrangements with us and our partners. 

How long do we store your Personal Data? We store your Personal Data for up to two years after you stop interacting with your account, unless we are required by the law to store it for a longer period.

What is the Basis for Processing your Personal Data? Our legitimate interests in processing data collected from our services or products in order to deliver services, to design our products and services and to continuously improve them, and where applicable, your consent.

4.7 Performance of Relevant Administrative Services Requested or Necessary to Facilitate our Relationship. 

Which Personal Data do we collect about you? For this purpose (Performance of Relevant Administrative Services) we process the following Personal Data: first name, last name, email address, mailing address, user name, commercial information, including credit card information, payment details, product preference, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

What is the Purpose of Processing your Personal Data? We will process your Personal Data for the purposes of performing administrative services requested or necessary to facilitate our relationship (e.g., facilitating payments or deliveries of products, services, information or materials) and to fulfill requests you have made (e.g., registration).

How long do we store your Personal Data? We store your Personal Data for two years after your last enqiury or the end of your relationship with us as a user, customer, or partner, whichever is later, unless we are required by law to store the Personal Data for a longer period in which case we store the Personal Data for the period required by applicable law.

What is the Basis for Processing your Personal Data? Performance of the contract with you, or in order to take steps at your request prior to entering into a contract, and our legitimate interests in the transmission of Personal Data within a group of undertakings for internal administrative purposes, including client data and, where applicable, your consent.

4.8 Prevention of harm to us, our products or services or a person or property (e.g., fraud prevention) or defend ourselves against claims or potential claims

Which Personal Data do we collect about you? For this purpose (Performance of relevant administrative services) we process the following Personal Data: first name, last name, email address, mailing address, user name, commercial information, including credit card information, payment details, product preference, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and relevant information about (i) the harm or potential harm, (ii) the claim or potential claim or (iii) the situation or circumstances giving rise to harm, potential harm, claim or potential claim.

What is the Purpose of Processing your Personal Data? We will process your Personal Data to identify and prevent potential fraudulent acts in connection with the use of our products or services, and to prevent harm to Coolfire or any of its affiliates or subsidiaries, their products or services or to any person or property (e.g., fraud prevention) and/or in the bringing or prosecution of a claim or potential claim against you.  In addition, we may process your Personal Data for the purposes of defending Coolfire or any of its affiliates or subsidiaries against claims or potential claims made against one or more of them.

How long do we store your Personal Data? We store your Personal Data for two years after your last enquiry or the end of your relationship with us as a user, customer, or partner, whichever is later, unless (i) we are required by law to store the Personal Data for a longer period in which case we store the Personal Data for the period required by applicable law or (ii) unless we reasonably anticipate litigation with regard to the matter in which case we would retain relevant Personal Data until such time as the litigation is concluded or is no longer reasonably anticipated.

What is the Basis for Processing your Personal Data? Our basis for processing is (i) a legal obligation to which we are subject or (ii) the processing is necessary for the purposes of our legitimate interests in protecting our business, products, services or a person or property or to defend ourselves against claims or potential claims.

5. Who IS Receiving your personal data?

We employ other companies and people (“Third Parties”) to perform tasks on our behalf and we need to share, and may internationally transfer, your information with them to provide products or services to you or they may need to collect information on our behalf. We do not sell, trade, or rent your Personal Data to Third Parties without prior permission from you. Further, we will not otherwise provide your Personal Data to Third Parties without prior permission from you, provided however, those Third Parties do not include our subsidiaries, affiliates, licensees, partners, hosting partners, other parties who assist us in operating our products and services, or organizations providing services to support our functions, such as our mail and email processing companies, payment processing companies, market research firms, lead-generation and outreach companies, and other service providers. 

We may share your data in an aggregate format, as well as aggregate usage information, with Third Parties for both advertising and promotional purposes. Further, we cooperate with all law enforcement inquires, and with all Third Parties, to enforce applicable intellectual property or other legal rights.

In addition to disclosures described above, we may disclose or transfer Personal Data in connection with, or during negotiations of, any merger, acquisition, spin-off, sale of company assets, product lines or divisions, any financing or any similar transaction. We may also disclose Personal Data to prevent damage or harm to us, our services or any person or property, if we believe that disclosure is required to meet national security or law enforcement requirements, or in response to a lawful request by public authorities. 

5.1 Our Service Providers

Coolfire engages various service providers to operate and provide our products and services and otherwise assist us in running our business, including Amazon Web Services, Mongo, GitHub, HubSpot, Intercom, Pendo, Google, Slack, QuickBooks, MineralTree. For example, Pendo collects application ID on devices and product and platform usage data on Coolfire’s behalf to allow Coolfire to gather analytics and evaluate user behaviour, however, Pendo does not share this data with any 3rd party data broker or ads service and the data is collected solely for Coolfire’s understanding of the app usage and our ability to target the relevant users with app-related messages.

5.2 Other Recipients (controllers)

In certain instances, such as in partnering agreement and joint ventures, Coolfire may act as a joint controller with you or a third party.

5.3 Sharing your Site Usage Information 

Coolfire may share details regarding your use of the Site with Third Parties that provide services to us relating to Site usage, such as HubSpot and Google.

6.0 WHERE DO WE TRANSFER YOUR PERSONAL DATA? 

When Coolfire transfers Personal Data to countries other than the country where it was provided, we do so in compliance with applicable data privacy laws and/or regulations, including, as applicable, the European Union General Data Protection Regulation 2016/679 (the “GDPR”). We will not transfer Personal Data subject to the GDPR and relating to you to a country outside the European Economic Area (“EEA”) unless: (1) the country or recipient is covered by an adequacy decision of the European Commission under GDPR Article 45; (2) appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the European Commission’s Standard Model Clauses for transfers of Personal Data outside the EEA); or (3) one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary) if the transfer is necessary to perform, or to form, a contract to which we are a party; the transfer is necessary for the establishment, exercise or defense of legal claims; you have provided your explicit consent to the transfer; or the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.

7.0 HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data is fulfilled and once our statutory obligations to preserve records have expired. In addition, Coolfire may retain anonymized Personal Data (data that is no longer in a form identifying or making identifiable the individual to which the Personal Data relates).

8.0 What are your rights?

If certain requirements are fulfilled, you have the right to obtain from us:

• Confirmation as to whether or not we process Personal Data from you and, where that is the case, access to the Personal Data,
• Rectification of inaccurate Personal Data,
• Erasure of Personal Data,
• Restriction of processing of Personal Data, and 
• Receive the Personal Data which you have provided to us and transmit those data to another data controller without hindrance. 

You may exercise any of these rights by contacting us via email at dataprivacy@coolfiresolutions.com or writing to us at:  Coolfire Solutions, Attn: Data Protection Officer, 415 N. 10th Street, 3rd Floor, St. Louis MO 63101.  

We will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law and/or regulation governing the use of the given personal information.  In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as to ensure proper authentication or to verify the Coolfire entity to which the information was provided.

9.0 Can you withdraw your CONSENT to the processing of personal data?

You may withdraw your consent to some or all of our processing of your Personal Data by contacting us via email at dataprivacy@coolfiresolutions.com or writing to us at:  Coolfire Solutions, Attn: Data Protection Officer, 415 N. 10th Street, 3rd Floor, St. Louis MO 63101.

We will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law and/or regulation governing the use of the given personal information.  In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as to ensure proper authentication or to verify the Coolfire entity to which the information was provided.

10.0 Can you complain with the APPLICABLE LEGAL authorities?

You also have the right to lodge your complaints with the applicable legal authorities, including, without limitation, the applicable European Union (“E.U.”) supervisory authority(ies) (if you are an E.U. citizen).

11.0 Do you have to provide your personal data to order on the sites?

Typically, to evaluate or subscribe to our product, you will need to provide some Personal Data. For example, subscribing to our product will require at least your first name, last name, and an email address. Our products and services are designed around user-specific personalization, so not all of the products and services require you to provide Personal Data. If you do not subscribe to a product, log into an account, or consent to cookies, where required, then you will not need to provide any Personal Data. However, you may not be able to use all of the features of the Site, our products, and our services.

12.0 How do we protect your personal data?

We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data. The safety and security of your information also depends on you. For example, you are responsible for keeping your username and password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information using the internet or any mobile application is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to or through our Site, products, or services. Any transmission of Personal Data is at your own risk. 

Our Site may contain links to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites. Once you have left our Site, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement for the website you visit.

13.0 Your California Privacy Rights

• California Civil Code Section 1798.83 permits our visitors 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 email us at dataprivacy@coolfiresolutions.com or write to us at: Coolfire Solutions, Attn: Data Protection Officer, 415 N. 10th Street, 3rd Floor, St. Louis MO 63101.
• Do Not Track (DNT) is a privacy preference that users can set in their web browsers. At this time, our Site does not support DNT codes.  However, except in the case of analytics cookies, remarketing and other features of Google Display Advertising described herein or in our Cookie Policy, our Site limits tracking to the uses described above and our Site does not track your use across multiple websites other than the affiliated websites included within this Privacy Policy, however, other websites to which we link may track you in this way.  Please review their privacy policies to understand how you may be tracked.

14.0 Can We Change our Privacy Policy?

As we continue to provide additional services and as the privacy laws and regulations evolve, it may be necessary to revise or update this Privacy Policy.  If we make any material changes to this Privacy Policy, including, any material changes to how we collect, use, process, and/or share your information, we will prominently post a notice of such changes on the website(s) covered by this Privacy Policy. To the extent required by applicable law, we will contact you with regard to changes to this Privacy Policy.

15.0 HOW CAN YOU CONTACT US?

If you have questions about this Privacy Policy or any subject discussed herein, please feel free to contact us at one of the following:

• By email at dataprivacy@coolfiresolutions.com or
• By mail at  Coolfire Solutions, Attn: Data Protection Officer, 415 N. 10th Street, 3rd Floor, St. Louis MO 63101

In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as to ensure proper authentication or to verify the Coolfire entity to which the information was provided.