PRIVACY POLICY

Effective Date: October 30, 2018.   

1. Introduction and Overview.

This Privacy Policy describes how Cooler Screens, Inc. (“Cooler Screens,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your interaction with any online service location and any coolers in any retail location that posts a link to this Privacy Policy or makes this Privacy Policy available to you, including our website at www.coolerscreens.com (“Website”) and our cooler display technologies (“Smart Coolers”) (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection). 

If you have any questions, please contact us as set out in the “Contact Us” section below.

2. Information Collection.

A. Information Collected through our Smart Coolers.

We work with retailers to deploy Smart Coolers in their stores. The Smart Coolers are equipped with computerized cameras that record videos and images of consumers who walk by or stand in proximity to the Smart Coolers. The cameras are connected to software provided by our Service Providers. Depending on the jurisdiction, the software may process facial images of consumers in real-time to determine gender, age or age range, number of consumers, and/or how consumers interact with the Smart Coolers. We do not save the videos or images beyond this processing. The software develops statistics concerning the environment where the particular Smart Cooler is located. We use those statistics for purposes of understanding consumer trends and purchase behavior, which may be used to inform advertising campaigns and product placement.

Cooler Screens does not collect or retain any information that individually identifies consumers.

B. Information Provided through the Website.

We collect information you provide when you use the Website, including when you request a demo or contact us. The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information you provide include the following:

  • Contact Data, including your first and last name, email address, postal address, and phone number.

  • Company Data, including your company’s name and postal address, and your title. 

  • Content, including content within any messages you send to us (such as feedback and questions to customer support). 

You may choose to voluntarily submit other information to us through the Website that we do not request, and, in such instances, you are solely responsible for such information. 

C. Information Collected Automatically through the Website.

We automatically collect information in connection with your use of the Website. Some examples of information we automatically collect include the following:

  • Website Use Data, including data about the features you use, the pages you visit, any associated emails and advertisements you view, the time of day you browse, and your referring and exiting pages.

  • Device Connectivity and Configuration Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.

We use various current – and later – developed technologies to automatically collect information (“Tracking Technologies”), including the following:

  • Log Files, which are files that record events that occur in connection with your use of the Website. 

  • Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Website. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. 

  • Pixels(also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us track our conversions, bring you advertising both on and off the Website, and provide you with additional functionality.  

For further information on Tracking Technologies and your rights and choices regarding them, see the “Third Parties” and “Your Rights and Choices” sections below.

3. Use of Information.

We use information we collect in accordance with the practices described in this Privacy Policy, including to: 

  • Manage our Service.

  • Perform services requested by you.

  • Respond to your comments, questions, and requests, and provide customer service.

  • Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

  • Prevent and address fraud, breach of policies or terms, and threats or harm. 

  • Monitor and analyze trends, usage, and activities.

  • Conduct research, including focus groups and surveys. 

  • Improve the Service or other Cooler Screens websites, apps, marketing efforts, products and services.

  • Fulfill any other purpose disclosed to you or with your consent. 

Notwithstanding the foregoing, we will not attempt to identify individually any individuals from the information collected through the Smart Coolers, unless required by law or legal obligation.

However, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy, including as follows:

  • Service Providers. We share information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as camera technology, data analytics, marketing and advertising, website hosting, and technical support. Service Providers are prohibited from using information about you for any purpose other than to provide this assistance, although we may permit them touse information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

  • Investors.We share information with our investors. For example, we share information with our affiliates for customer support and technical operations.

  • Retailers.We share information with our retailer customers in connection with us providing Smart Coolers in their stores. For example, we share information for purposes of understanding how consumers interact with their products and helping them with product placement. We will not share information that identifies you personally, unless required by law or legal obligations. 

  • Media Buyers. We share information, such as headcount, with media buyers to help them manage and optimize their digital marketing campaigns.

  • Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business. 

  • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or any third party. 

  • Consent. We may share information to fulfill any other purpose disclosed to you or with your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) with third parties except as prohibited by applicable law.For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below 

5. Third Parties.

Our Website may contain content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service, a Third Party Service, or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use. 

6. Your Rights and Choices. 

A.  Tracking Technology Choices.

  • Cookies and Pixels.Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. 

  • Do Not Track.Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly. 

B. Communications.

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or Cooler Screens’ ongoing business relations. Please note that your opt-out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.  

C. Your California Privacy Rights.

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set out in the “Contact Us” section below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Cooler Screens is not required to respond to requests made by means other than through the provided email address or mail address.

7. Children.

The Service is intended for a general audience and not directed to children under thirteen (13) years of age. Cooler Screensdoes not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Cooler Screenshas collected such information in a manner not permitted by COPPA, please contact us as set out in the “Contact Us” section below, and wewill remove such data to the extent required by COPPA. 

8. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to helpprotect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. 

9. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. 

10. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.  

11. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

Through our online form: www.coolerscreens.com/contact-form

By email: legal@coolerscreens.com

By mail: 111 East Wacker Drive, Suite 420, Chicago, Illinois 60601