Effective January 6, 2020
Your Privacy Matters
Cocoricos’ mission is to connect the world’s professionals to allow them to be more productive and successful. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.
Table of Contents:
- Data We Collect
- How We Use Your Data
- How We Share Information
- Your Choices & Obligations
- Other Important Information
Our registered users (“Members or Real Estate Managers”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and develop skills, and find business and career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”).
We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.
Data Controllers and Contracting Parties
If you are in the “Designated Countries”, Golden Chain SAS (“Cocoricos”) will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.
1. Data We Collect
1.1 Data You Provide To Us
You provide data to create an account with us.
To create an account you need to provide data including your name, email address and/or mobile number, and a password. If you register for a premium Service, you will need to provide payment (e.g., credit card) and billing information.
You create your Cocoricos profile (a complete profile helps you get the most from our Services).
You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. Some Members may choose to complete a separate ProFinder profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
You give other data to us, such as by syncing your address book or calendar.
Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or salary), respond to a survey, or submit a resume or fill out a job application on our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).
If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g. times, places, attendees and contacts.
You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.
1.2 Data From Others
Others may post or write about you.
Content and News
You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as professional-related news and accomplishments (e.g., patents granted, professional recognition, conference speakers, projects, etc.) and make it available as part of our Services (e.g. suggestions for your profile, or notifications to others of mentions in the news).
Others may sync their contacts or calendar with our Services.
Contact and Calendar Information
We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, scan and upload business cards, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.
Customers and partners may provide data to us.
We receive personal data (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers and applicant tracking systems providing us job application data.
Related Companies and Other Services
We receive data about you when you use some of the other services provided by us or our affiliates, including Microsoft. For example, you may choose to send us information about your contacts in Microsoft apps and services, such as Outlook, for improved professional networking activities on our Services.
1.3 Service Use
We log your visits and use of our Services, including mobile apps.
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or apply for jobs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
1.4 Cookies and Similar Technologies
We collect data through cookies and similar technologies.
1.5 Your Device and Location
We receive data from your devices and networks, including location data.
When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
If you communicate through our Services, we learn about that.
We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a Cocoricos connection request, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement or Professional Community Policies from our Services.
1.7 Workplace and School Provided Information
When your organization (e.g., employer or school) buys a premium Service for you to use, they give us data about you.
Others buying our Services for your use, such as your employer or your school, provide us with personal data about you and your eligibility to use the Services that they purchase for use by their workers, students or alumni. For example, we will get contact information for “Company Page” administrators and for authorizing users of our premium Services, such as our recruiting, sales or learning products.
1.8 Sites and Services of Others
We get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others’ services with your Cocoricos account.
We receive information about your visits and interaction with services provided by others when you log-in with Cocoricos or visit others’ services that include some of our plugins (such as “Apply with Vave”) or our ads, cookies or similar technologies
We are improving our Services, which means we get new data and create new ways to use data.
2. How We Use Your Data
We use your data to provide, support, personalize and develop our Services.
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.
Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive.
We use your data to authorize access to our Services and honor your settings.
Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts. To do so, you can “connect” with the professionals who you choose, and who also wish to “connect” with you. Subject to your and their settings, when you connect with other Members, you will be able to search each others’ connections in order to exchange professional opportunities.
We use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other nearby Members for you to connect with, calculate the commute to a new job, or notify your connections that you are at a professional event).
It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will your network and basic profile information (e.g., name, profile photo, job title, region). We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.
Visitors have choices about how we use their data.
Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. We also use the data we have about you to suggest skills you could add to your profile and skills that you might need to pursue your next opportunity. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain members on our site, or suggest related learning content to help you towards that new skill. We use your content, activity and other data, including your name and photo, to provide notices to your network and others. For example, subject to your settings, we may notify others that you have updated your profile, posted content, took a social action, used a feature, made new connections or were mentioned in the news.
Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific task) or be hired by you. We will use your data to recommend jobs or mentees, show you and others relevant professional contacts (e.g., who work at a company, in an industry, function or location or have certain skills and connections). You can signal that you are interested in changing jobs and share information with recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.
Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other Members and schedule and prepare meetings with them. If your settings allow, we scan messages to provide “bots” or similar tools that facilitate tasks such as scheduling meetings, drafting responses, summarizing messages or recommending next steps.
2.2 Premium Services
Our premium Services help paying users to search for and contact Members through our Services, such as searching for and contacting job candidates, sales leads and co-workers, manage talent and promote content through social media.
We sell premium Services that provide our customers and subscribers with customized-search functionality and tools (including messaging and activity alerts) as part of our talent, marketing and sales solutions. Customers can export limited information from your profile, such as name, headline, current company, current title, and general location (e.g., Dublin), such as to manage sales leads or talent, unless you opt-out. We do not provide contact information to customers as part of these premium Services without your consent. Premium Services customers can store information they have about you in our premium Services, such as a resume or contact information or sales history.
We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.
We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Vave inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.
We also enable communications between you and others through our Services, including for example invitations and messages between connections.
We use data from partners providing APIs in order to facilitate access to the platform or the promotion of their profile with their friends.
Vave collects information via its partners Google, Hotjar, Mailchimp or Drift relating to the applications, browsers and devices that you use to access Google services. This data allows us to provide functionality, such as automatic product updates.
The information we collect includes unique identifiers, type and settings of the browser, type and settings of the device, operating system, data relating to the mobile network (such as the name of the operator and phone number) and the application version number.
We collect this information when a Vave service contacts our servers from your device, for example when you access the site. If you use an Android device with Google apps installed, your device periodically contacts Google servers to provide us with information about your device and connections to our services, such as the type of device you are using, the operator name, error reports, and applications you have installed.
We collect information relating to your activity within our services. These allow us, for example, to recommend opportunities / training that may interest you. The activity information we collect may include the following:
- The profiles or opportunities you are looking for
- The pages you open
- Your profile information: Full Name, Address, Description, Opportunities completed or in progress, and Telephone Number
- Purchasing activity
- The people with whom you communicate or share content.
- When you want to invite your contacts, you may have to import your contact list from Google, Outlook, Linkedin or by importing a csv file.
We promote our Services to you and others.
In addition to advertising our Services, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services.
2.6 Developing Services and Research
We develop our Services and conduct research.
We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.
We seek to create economic opportunity for Members of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends, such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.
Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
2.7 Customer Support
We use data to help you and fix problems.
We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).
2.8 Insights That Do Not Identify You
We use data to generate insights that do not identify you.
We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.
2.9 Security and Investigations
We use data for security, fraud prevention and investigations.
We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members,Visitors or others.
3. How We Share Information
3.1 Our Services
Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.
Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). As detailed in our Help Center, your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.
Posts, Likes, Follows, Comments, Messages
Our Services allow viewing and sharing information including through posts, likes, follows and comments.
- When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
- In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
- Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
- When you follow a person or organization, you are visible to others and that “page owner” as a follower.
- We let senders know when you act on their message, subject to your settings where applicable.
- Subject to your settings, we let a Member know when you view their profile.
- When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).
Your employer can see how you use Services they provided for your work (e.g. as a recruiter or sales agent) and related information. We will not show them your job searches or personal messages.
Your employer may offer you access to our enterprise Services such as Cocoricos, or Vave. Your employer can review and manage your use of such enterprise Services.
Depending on the enterprise Service, before you use such Service, we will ask for permission to share with your employer relevant data from your profile or use of our non-enterprise Services. For example, users of “Signal Radar” will be asked to share their “social selling index”, a score calculated in part based on their personal account activity. We understand that certain activities such as job hunting and personal messages are sensitive, and so we do not share those with your employer unless you choose to share it with them through our Services (for example, by applying for a new position in the same company or mentioning your job hunting in a message to a co-worker through our Services).
Subject to your settings, when you use workplace tools and services (e.g., interactive employee directory tools) certain of your data may also be made available to your employer or be connected with information we receive from your employer to enable these tools and services.
3.2 Communication Archival
Regulated Members may need to store communications outside of our Service.
Some Members (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by and to those Members outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.
3.3 Others’ Services
You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.
Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your Cocoricos contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.
Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile data of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.
3.4 Related Services
We share your data across our different Services and Cocoricos affiliated entities.
3.5 Service Providers
We may use others to help us with our Services.
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
3.6 Legal Disclosures
We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Cocoricos, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. To learn more see our Data Request Guidelines and Transparency Report.
3.7 Change in Control or Sale
4. Your Choices & Obligations
4.1 Data Retention
We keep most of your personal data for as long as your account is open.
We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.
4.2 Rights to Access and Control Your Personal Data
You can access or delete your personal data. You have many choices about how your data is collected, used and shared.
We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you (for Vave, please contact us).
For personal data that we have about you, you can:
- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
Residents in the Designated Countries and other regions may have additional rights under their laws.
4.3 Account Closure
We keep some of your data even after you close your account.
If you choose to close your Cocoricos (or Vave) account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Professional Community Policies), enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
Information you have shared with others (e.g., through InMail, updates or group posts) will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
5. Other Important Information
We monitor for and try to prevent security breaches. Please use the security features available through our Services.
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please visit our Safety Center for additional information about safely using our Services, including two-factor authentication.
5.2. Cross-Border Data Transfers
We store and use your data outside your country.
We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.
5.3 Lawful Bases for Processing
We have lawful bases to collect, use and share data about you. You have choices about our use of your data.
At any time, you can withdraw consent you have provided by going to settings.
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Cocoricos Services you have requested) and “legitimate interests.”
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
5.4. Direct Marketing and Do Not Track Signals
Our statements regarding direct marketing and “do not track” signals.
We currently do not share personal data with third parties for their direct marketing purposes without your permission.
5.5. Contact Information
You can contact us or use other options to resolve any complaints.
If you have questions or complaints regarding this Policy, please first contact Cocoricos online. You can also reach us by physical mail. If contacting us does not resolve your complaint, you have more options.