COING, as a data controller, collects and processes personal data relating to interactions on the Website (as defined in
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When we say "you", "your" or "Data Subject" we mean any natural person that shares personal data with us via Website.
When we say "processing" we mean any operation or set of operations which is performed on personal data or sets of personal data. This includes activities such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
When we say "Data Processors" or "processor" we mean any natural or legal person who processes the data on behalf of the Data Controller. In some cases, COING is a Data Processor and in others, Data Controller (as further explained in Section 2). In addition, we may use the services of various service providers to process your data more effectively. In such cases, they are either our processors or sub-processors.
When we say "consent" we mean your explicit consent on the processing of personal data. Persons who are 15 years of age or older may give free consent to the processing of their personal data.
In relation to your personal data processed on or via the Website and the Service, COING may be either a Data Controller
or Data Processor.
2100 Geng Road, Suite 210
Palo Alto, CA 94303
By using the Service, you may disclose, share, record, or otherwise use various types of data via a Workspace as the User Content. The type of User Content is determined by the person that owns the Workspace and not by us. The extent to which personal data is processed while using the Service also depends on the Pumble functionalities that the owner of the Workspace decides to use. In that event, COING is a Data Processor and Data Controller is the owner of the Workspace. Thus, COING does not analyze, disclose or access such data unless a User (including an Enterprise as a User) sends a request for support and, in these cases, the access is limited to enabling the functioning of the Service.
Please also note that we do not collect or process your personal data if you are an End User of Server Pumble. In that case, the Client (the company that has Pumble installed on their server) is responsible for your personal data.
If would like to sign a DPA with us, please contact us at firstname.lastname@example.org for more information.
We may collect and receive information about you in various ways:
Email address, password, time zone and sometimes profile photo, name and personal API key
(if the User decides to provide such personal data).
The User will also obtain the User ID so that we can identify that User in the future.
Such as name, address, bank account and payment card details. The payer may not be the User subscribing to the Paid Plan, so it is possible to receive the information from another User.
i.e., data you decide to share with us.
If you decide to sign up for our newsletter, we use your email address.
(when provided by other Users)
Information necessary for identification
Other personal data
If you send us an inquiry at email@example.com or otherwise request support, we will collect data you decide to share with us.
This newsletter allows us to inform you of the new features of the Service, updates, as well as other news relevant to the company.
Users may invite non-users via Pumble to join the Workspace, in which case they provide the non-user’s email address.
For the prevention and detection of fraud, money laundering or other crimes or to respond to a binding request from a public authority or court.
Processing is necessary for the User’s performance of the Agreement which includes providing Additional Features based on the selected Paid Plan.
Processing of personal data is either necessary to provide a Service or part thereof, or the processing is based on your consent.
Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. You may unsubscribe from receiving a newsletter from us. If you wish to do so, simply follow the instructions found at the end of each email.
Processing is necessary for the performance of the Agreement between us and the User who provided the information and it is also in the User’s legitimate interest.
Processing is necessary for compliance with a legal obligation which the Controller is subject to.
The processing is necessary to comply with legal and regulatory obligations.
If the processing is based on your consent, we keep the information until you withdraw your consent or for one year, whichever date comes first.
We may use your email for this purpose until you unsubscribe or until you delete your User Account.
After sending the message to you we do not keep your personal data unless you decide to become a User, in which case other purposes apply.
We keep this information for a period of one year.
In accordance with the applicable statutory deadlines.
As a processor, COING is permitted to collect, use, disclose and/or otherwise process your personal data only following the instructions of the Customer.
The Customer shares your email address to enable you to access the Service. If you have any questions regarding the legal basis for such personal data processing, please contact the Customer who invited you to the Service.
If you decide to accept the invitation to use the Service, you will be required to create an account. To create the User Account, you will need to share your email address and password. You manage personal data you share via your account such as name and surname, photo, email data (personal email address and/or work email address).
In the course of the use of the Service we may process system usage data, IP address, work position, chat correspondence, application integration data, navigational data (including website usage information such as interactions with Pumble, and other electronic data submitted, stored, sent, or received by the Data Controller via the Service.
COING does not undertake analysis of any special categories of personal data (including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation) and Pumble functionalities are not meant to be used for the processing of any such personal data. However, if you decide to provide such personal data to us or Data Controller via the Service, you will be deemed to have consented to such processing of the data.
COING will never:
We take administrative, technical, organizational and other measures to ensure the appropriate level of security of personal data we process. Upon assessing whether a measure is adequate and which level of security is appropriate, we consider the nature of the personal data we are processing and the nature of the processing operations we perform, the risks to which you are exposed by our processing activities, the costs of the implementation of security measures and other relevant matters in the particular circumstances.
Some of the measures we apply include access authorization control, information classification (and handling thereof), protection of integrity and confidentiality, data backup, firewalls, data encryption and other appropriate measures. We equip our staff with the appropriate knowledge and understanding of the importance and confidentiality of your personal data security.
COING utilizes external processors for certain processing activities. We use information audits to identify, categorize and record all personal data that is processed outside the company, so that the information, processing activity, processor and legal basis are all recorded, reviewed and easily accessible.
We have strict due diligence procedures and measures in place and review, assess and background check all processors prior to forming a business relationship. We obtain company documents, certifications, references and ensure that the processor is adequate, appropriate and effective for the task we are employing them for.
We audit their processes and activities prior to contract and during the contract period to ensure compliance with the data protection regulations and review any codes of conduct that oblige them to confirm compliance.
This is the list of processors and sub-processors with whom we share your personal data:
|The Rocket Science Group, LLC (MailChimp)||Email services based on Cloud||USA|
|Amazon Web Services, Inc.||Cloud Infrastructure (IaaS)||USA|
|SendGrid, Inc.||E-mail services based on Cloud||USA|
|Stripe, Inc.||Payment provider||USA|
|Zendesk, Inc.||Email and chat support||USA|
We may also share your personal data with our outside accountants, legal counsels and auditors.
Please keep in mind that, subject to your instructions to us while using the Service, your data may be shared with third parties in the following situations:
The period for which we store your personal data depends on a particular purpose for the processing of personal data, as
explained in detail in Section 4. We retain personal data for as long as we reasonably require it for legal or business
purposes. In determining data retention periods, we take into consideration the applicable law (see Section 22 of the
personal information, or when you request us to delete your information, where this is legal, we will securely delete or
However, as an exception to the retention periods in Section 4 the data may be processed to determine, pursue or defend claims and counterclaims.
Given that transparency is one of our cornerstone principles, we grant Data Subjects certain rights in relation to their
personal data. These rights may be exercised by Data Subject when COING operates as a Data Controller.
In the event COING receives a request for exercising any of these rights directly from a Data Subject, we are obliged to notify the owner of the relevant Workspace before responding to such a request.
You can send us a request for a copy of the personal data we hold about you.
We have ensured that appropriate measures have been taken to provide such in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data Subject and with prior verification as to the subject's identity. Information is provided to the Data Subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.
If the personal data we have about you is incorrect, you have the right to request that we correct those data. Where notified of inaccurate data by the Data Subject, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the personal data in question to them.
You have the right to request from us that your personal data is deleted in certain circumstances including:
However, this right does not apply where, for example, the processing is necessary:
If the accuracy of the personal data is contested, you consider the processing is unlawful but you do not want it erased, we no longer need the personal data but you require it for the establishment, exercise or defense of legal claims or you have objected to the processing and verification, you can exercise your right to the restriction of the processing.
Where you have provided personal data to us, you have the right to receive such personal data back in a structured, commonly used and machine-readable format, and to have those data transmitted to a third-party Data Controller without hindrance but in each case only where:
If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
If you have any concerns or requests in relation to your personal data, please contact us at firstname.lastname@example.org and we will respond as soon as possible but not later than within 30 days.
publish the new rules on the Website and, if we have your email, we will notify you directly.