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Privacy Policy

This privacy policy was last modified on 14 August 2020.

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Terms and Conditions for Vendors

Privacy Policy

OUR APPROACH TO PRIVACY

  1. COFE APP UK LTD, COFE DISTRICT LIMITED and any affiliate or related party to these companies and the group of companies (“COFE App“, “we“, “our” or “us“) is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) and information regarding our use of cookies and similar technologies.
  2. We operate an online marketplace for ordering coffee and food products (the “COFE App Service“) which COFE App makes available as a service to vendors through our website at www.cofeapp.com and to end users through our mobile application that is available to download on your device (the “App“).
  3. This Privacy Policy applies to the COFE App Service (including the App).
  4. Please ensure that you have read this Privacy Policy and understood how we collect, store, use and disclose your personal information before accessing or using the COFE App Service.

WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL INFORMATION

COFE App is the controller of the personal information we hold about you in connection with your use of the COFE App Service. This means that we determine and are responsible for how your personal information is used.

PERSONAL INFORMATION WE COLLECT FROM YOU WHEN YOU USE THE SERVICE, AND HOW WE USE IT

  1. We collect personal information that you voluntarily submit directly to us when you use the COFE App Service. This can include information you provide to us when you set up an account on the COFE App Service, fill in a form on the COFE App Service, purchase a product, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of the COFE App Service.
  2. This information may include, for example, your contact and payment details. If you choose not to provide such personal information, we may not be able to provide those parts of the COFE App Service to you or respond to your other requests.
  3. The table at Annex 1 [link to Annex 1 below] sets out in detail the categories of personal information we collect about you and how we use that information when you use the COFE App Service, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.

INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY

  1. We also automatically collect personal information indirectly about how you access and use the COFE App Service, and information about the device you use to access the COFE App Service when you visit our COFE App Service, read our emails, or otherwise engage with us. We use this information to provide you the features and functionality of the COFE App Service, to monitor and improve the COFE App Service and to develop new products and services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar tracking technologies.
  2. The table at Annex 2 [link to Annex 2 below] sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information. For more information on cookies and other tracking technologies we use, please see Section 10 below.
  3. We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
  4. We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the COFE App Service and developing new products and features. We may also share such anonymised and aggregated information with others.

HOW LONG WILL WE STORE YOUR PERSONAL INFORMATION

  1. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
  2. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

RECIPIENTS OF PERSONAL INFORMATION

We may share your personal information with the following (as required in accordance with the purposes set out in Annexes 1 and 2):

  1. Third party food and beverage provider partners: we may share your personal information with third party partners such as food and beverage providers in order to facilitate the orders your place with the COFE App Service.
  2. Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
  3. Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
  4. Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of COFE App, its users or others.
  5. Business Partners:we may also share your personal information with our business partners so that they can provide services, contact you directly with special offers, discounts or other benefits. In any event, we will take reasonable precautions that all third parties listed above are obligated to keep confidential any of the personal data that they receive from us.

MARKETING AND ADVERTISING

  1. From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
  2. Most marketing messages we send will be via the COFE App Service in the form of push notifications. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you. You can unsubscribe from receiving promotional email communications from us by switching marketing push notifications off via the profile settings page on the COFE App Service (you can switch these back on at any time via the same process). We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the COFE App Service, technical and security notices).
  3. We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by updating your preferences via your account profile settings on the COFE App Service

STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

  1. Security,. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

  2. International Transfers of your Personal Information.. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are accessing our COFE App Service from the European Economic Area (“EEA“) (and the UK), your personal information will be processed outside of the <b>EEA</b> (and the UK) including in third party cloud providers based in the United States and Middle East.

In the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission; or (iii) such transfer shall be to a third party that is a member of a compliance scheme recognised by the European Commission as offering adequate protection for the rights and freedoms of data subjects, such as the EU-U.S. Privacy Shield. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.

RIGHTS FOR EEA USERS

  1. If you are accessing our COFE App Service from the EEA, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
    1. Right of access. . The right to obtain access to your personal information along with certain related information.
    2. Right of portability. . You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
    3. Right to rectification. . You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
    4. Right to erasure. . You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
    5. Right to restriction. . You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
    6. Right to withdraw consent. . If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal
  2. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
  3. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
  4. You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here.

COOKIES AND SIMILAR TECHNOLOGIES USED ON OUR APP

  1. Our App uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our App. This helps us to provide you with a good experience when you browse our App and also allows us to monitor and analyse how you use and interact with our App so that we can continue to improve our App. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.
  2. Cookies are pieces of code that allow for personalisation of our App experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.
  3. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
  4. [We use the following types of cookies:
    1. Strictly necessary cookies. . These are cookies that are required for the operation of our COFE App Service. They include, for example, cookies that enable you to log into secure areas of our COFE App Service, use a shopping cart or make use of e-billing services.
    2. Analytical/performance cookies. . They allow us to recognise and count the number of visitors and to see how visitors move around our COFE App Service when they are using it. This helps us to improve the way our COFE App Service works, for example, by ensuring that users are finding what they are looking for easily.
    3. Functionality cookies. . These are used to recognise you when you return to our COFE App Service. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
    4. Targeting cookies. . These cookies record your visit to our COFE App Service, the pages you have visited and the links you have followed. We will use this information to make our COFE App Service and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.
    5. Third party cookies. . Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our COFE App Service. These third parties are responsible for setting out their own cookie and privacy policies.]
  5. Please see Annex 3 for more information about the cookies we use on the COFE App Service.
  6. The cookies we use are designed to help you get the most from the COFE App Service but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our COFE App Service. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
    1. Cookie settings in Internet Explorer
    2. Cookie settings in Firefox
    3. Cookie settings in Chrome
    4. Cookies settings in Safari web and iOS.
  7. For mobile users, you have controls in your device Operating System that enables you to choose whether to allow cookies or share your advertising ID with COFE App or our advertising service providers. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest-based ads’.
  8. If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative’s online sources at www.networkadvertising.org. We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Section 12 below.
  9. Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

TRACKING TECHNOLOGIES USED IN OUR EMAILS

  1. Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.
  2. Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display “remote images”, “remote content” or “images” by default.
  3. Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

INTEREST BASED ADVERTISING

  1. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the COFE App Service. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the COFE App Service over time so that they may play or display ads on the COFE App Service, on other websites, apps or services you may use (including Facebook), and on other devices you may use.
  2. Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect, or we may share, mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device’s IP address, information about other applications on your device, your location, information about your use of the COFE App Service, email address or hashed data and information about which advertisements you have seen or clicked on.
  3. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
  4. We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the COFE App Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
  5. We and our third-party partners may also link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to the COFE App Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as user ID) with third party advertising partners to help recognise you across devices. We and our partners can use this cross-device linkage to serve interest-based advertising and other personalised content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.
  6. You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device by selecting “limit ad tracking” (iOS) or “opt out of interest based ads” (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
  7. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:
    1. the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices
    2. the DAA’s resources at www.aboutads.info/choices; and/or
    3. Your Online Choices at www.youronlinechoices.eu.
  8. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices’ online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.
  9. Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.
  10. Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.

Control Over your Information

You may update your profile information, such as your contact information, and may change some of your data sharing preferences on your Account page/by emailing us at hello@cofeapp.com.

LINKS TO THIRD PARTY SITES

The COFE App Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

OUR POLICY TOWARDS CHILDREN

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the COFE App Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

CONTACTING

Please contact hello@cofeapp.com if you have any questions, comments and requests regarding this Privacy Policy.

NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the COFE App Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

CONTACTING US

Please contact hello@cofeapp.com if you have any questions, comments and requests regarding this Privacy Policy.

ANNEX 1 – PERSONAL INFORMATION YOU PROVIDE TO US

Category of personal information How we may use it Legal basis for the processing Recipients of personal information
Contact information such as your first name, last name, address (home and billing address), phone number and e-mail address.
We may use this information to process any orders that you make by using the COFE App Service, including for the purposes of invoice creation and in order to e-mail e-receipts to you.
The processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you.
We may share this information with: Mixpanel; Google Analytics / Firebase; Swifty Beaver; [Adjust]. [INSERT ANY ADDITIONAL RECIPIENTS].
We also use this information to set up and authenticate your account.
The processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you.
We use this information to tailor how the COFE App Service is displayed to you (such as the language in which it is provided to you).
The processing is necessary for our legitimate interest, namely tailoring the COFE App Service so that it is more relevant to our users.
We may use this information to deal with enquiries and complaints made by or about you relating to the COFE App Service.
The processing is necessary for our legitimate interests, namely administering the COFE App Service, and for communicating with you effectively to respond to your queries or complaints.
We may use this information to communicate with you, including sending service-related communications.
The processing is necessary for the performance of a contract with you.
We may use this information to send you unsolicited marketing communications in accordance with your preferences.
We will only use your personal information in this way to the extent you have given us consent to do so.
We may use this information when you choose to participate in promotions or contests that we run. We ask those who enter into promotions or contests to provide this information so that we can contact you in relation to the promotion or contest, for example, we will notify you if you win a prize.
The processing is necessary for our legitimate interests, namely administering the promotion or contest, and for communicating with you effectively to respond to your queries or complaints.
We may use this information to contact you provide us with feedback, for example, when you participate in online surveys. We use such information in order to administer and improve the COFE App Service.
We will only use your personal information in this way to the extent you have given us consent to do so.
Chat and comments. When you contact us directly, e.g. by email, phone, or when you participate in a chat on the COFE App Service, we will record your comments and opinions
We may use this information to operate, maintain and provide to you the social features and functionalities of the COFE App Service.
The processing is necessary for the performance of a contract with you.
We share this information with [***] and [***], for the provision of customer support, for example, in order to facilitate a live chat or phone call session.
We may use this information to operate, maintain and provide to you the social features and functionalities of the COFE App Service.
The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.
We may use this information to develop new products and features available through the or otherwise improve the COFE App Service.
The processing is necessary for our legitimate interests, namely developing and improving the COFE App Service.
Payment and transaction information, such as your credit card, payment authentication code, billing address, and other information such as date and time of your transaction.
We may use this information to process the payments you make or receive through the COFE App Service.
The processing is necessary for the performance of a contract.
We may share this information with [Oracle] and [MyFatoorah], in order to identify you so that you can make and receive payments through the COFE App Service.
Location information, such as your GPS coordinates when you place an order through the COFE App Service.
We may use this information for operational purposes. Our COFE App Service works on showing you beverage and food vendors according to a specific radius and GPS coordinates are required in order to ensure that the list we show you is accurate.
The processing is necessary for our legitimate interest, namely tailoring the COFE App Service so that it shows you beverage and food vendors that are in / near your particular location.
We may share this information with:Mixpanel;[***].
Information received from third parties, such as social networks. If you interact with the COFE App Service through a social network, we may receive information from the social network such as your name, profile information, user ID, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.
We may use this information to authenticate you and allow you to access the COFE App Service.


We may use this information to help match you with other users in accordance with the functionality of the COFE App Service.


We may use this information to tailor the way this is displayed to you (such as the language in which it is presented to you).
The processing is necessary for the performance of a contract with you.


The processing is necessary for the performance of a contract with you.


The processing is necessary for our legitimate interests, namely tailoring the COFE App Service so that it is more relevant to our users.
We may share this information with:Mixpanel;[***].
Your preferences, such as preferences set for notifications, marketing communications, how the COFE App Service is displayed and the active functionalities on the COFE App Service.
We use this information to provide notifications, send news, alerts and marketing communications and provide the COFE App Service in accordance with your choices.
The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications, and that this is displayed in accordance with the user’s preferences.
We may share this information with [Adjust] [Google Analytics / Firebase] and [Mixpanel], to ensure that [we comply with your preferences with respect to the types of emails and messages we send to you].
We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.
The processing is necessary for compliance with a legal obligation to which we are subject.
All personal information set out above.
We may use all the personal information we collect to operate, maintain and provide to you the features and functionality of the COFE App Service, to communicate with you, to monitor and improve the COFE App Service and business, and to help us develop new products and services.
The processing is necessary for our legitimate interests, namely to administer and improve the COFE App Service.
As described above and in Section 6.

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information How we may use it Legal basis for the processing Recipients of personal information
Your IP address.
We may use this information to detect fraud or suspicious activity in relation to your account.
The processing is necessary for our legitimate interests, namely to protect our business and your account from fraud and other illegal activities.
We may share this information with:[Mixpanel], [Google Analytics / Firebase] and [Swifty Beaver] in order to [protect our business and your account from fraud and other illegal activities, to provide us with data analytics and error correction services].
We may use this information to localise features of the COFE App Service.
The processing is necessary for our legitimate interest, namely localising features of the COFE App Service and tailoring the COFE App Service so that it is more relevant to our users.
For our internal analytical purposes.
The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the COFE App Service, to improve the COFE App Service generally, to localise features of the COFE App Service and tailor the COFE App Service so that it is more relevant.
Where you have given us your consent to send you marketing communications, we will use this information during the e-mail marketing process.
The processing is necessary for our legitimate interests, namely to administer the marketing communication.
Information about how you access and use the COFE App Service. For example, how frequently you access the COFE App Service, the time you access the COFE App Service and how long you use it for, the approximate location that you access the COFE App Service from, the site from which you came and the site to which you are going when you leave our COFE App Service, the COFE App Service pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the COFE App Service from multiple devices, and other actions you take on the COFE App Service.
We may use information about how you use and connect to the COFE App Service to present the COFE App Service to you on your device.


We may use this information to determine products and services that may be of interest to you for marketing purposes.


We may use this information to monitor and improve the COFE App Service and business, resolve issues and to inform the development of new products and services.
The processing is necessary for our legitimate interests, namely to tailor the COFE App Service to the user.


The processing is necessary for our legitimate interests, namely to inform our direct marketing.


The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the COFE App Service and to improve the COFE App Service generally.
Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the COFE App Service. This information can include details about the type of device, Internet service provider and type of Internet access, platform type, device type, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), operating systems (including operating system versions), browsers and applications connected to the COFE App Service through the device, your mobile network, your IP address and your device’s telephone number (if it has one). When you access our COFE App Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
We may use information about how you use and connect to the COFE App Service to present the COFE App Service to you on your device.


We may use this information to determine products and services that may be of interest to you for marketing purposes.


We may use this information to monitor and improve the COFE App Service and business, resolve issues (such as bugs), to identify and fix any device / version / Internet type specific issues with the COFE App Service, and to inform the development of new products and services.
The processing is necessary for our legitimate interests, namely to tailor the COFE App Service to the user.


The processing is necessary for our legitimate interests, namely to inform our direct marketing.


The processing is necessary for our legitimate interests, namely to inform our direct marketing.

ANNEX 3 – COOKIES

Third party Product Persistent / session Type of cookie Purposes / Additional information
[Google]
[Google, Google Ads & DoubleClick]
[Persistent]
[Third party – analytics / advertising / marketing.]
[For analytics, marketing and advertising purposes. Note you may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices. . You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.]