LEGAL STATEMENT

Privacy Policy

Privacy Policy

Last updated: January 2024

INTRODUCTION

Cooke & Associates, Inc. (“we” or “us”) respects and understands concerns about confidentiality and privacy, and we take reasonable steps designed to ensure that the personal information you give us is handled in a safe and responsible manner. This Privacy Policy applies to Cooke & Associates, Inc. and the data collected through this website, www.cookepi.com and offline. In this Privacy Policy, we describe the information that we collect about you through our websites (collectively our “website” or “websites”) and offline and our use and disclosure of that information. Certain companies within the Cooke & Associates, Inc. family may have privacy policies that are different from this one. Please review their respective websites for the applicable policy.

If you are visiting our websites from outside the United States, please see the section at the end of this Policy entitled “Non-U.S. Residents” for links to the privacy policies for CAI entities based outside the United States.

By visiting or using any of our services on any of our websites, you agree that your personal information will be handled as described in this Privacy Policy. We suggest that you refer to this Privacy Policy on a regular basis as it may change, at any time in our sole discretion. We will provide notice of material changes by noting that the Privacy Policy is new or otherwise notifying registered users to the extent required by applicable law. Your use of our website, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Use including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Privacy Policy.

California Residents: For California residents, please see the section at the end of this Policy entitled “Important Additional Privacy Information for California Residents” (“the California Section”), which discusses the forms of personal information that we collect about California residents not only through our websites but also in any offline interactions with such residents, how we use that information, and California residents’ rights with respect the personal information we collect.

If any other section in this Privacy Policy can be read to be in conflict with the California Section, then the California Section controls with respect to California residents.

The Information We Collect About You

We collect information about you directly from you, from other individuals and entities, and automatically through your use of our websites. As set forth below, we primarily collect the following information about you: name, contact information, and other identifiers; customer records/purchase history; usage data (e.g., information about how you use our services online); and professional/employment related information. Please note that our services are provided almost exclusively to business customers, and, as such, much of the information that we collect about you pertains to our business relationship with your employer. If you are applying for a position with us, please see our Career Page.

Information We Collect Directly From You:

The type of information that we collect from you depends upon your interaction with us. In particular, we collect the following information from you during your interactions with us:

Signing Up for Our Newsletter: we collect your email address, and, in some circumstances, your name.

Customer Service: if you contact us, whether through our Websites, by phone, chat, or other means, we collect your name, contact information, and information about the reason that you contacted us. If you call our call center, your call may be recorded for quality assurance and customer service purposes. We do not always associate a call recording with a particular customer’s account.

Request a Quote/Consultation: we collect your name, professional or employment related information (such as your business contact information), service request, and any other information that you choose to provide to us.

Purchases: on some Websites, you may make a purchase directly through that Website; if you make a purchase through our Websites, we collect your name, billing information, and payment card information. We retain information about the types of purchases that you make with us.

Social Media: if you post to any of our social media accounts, we may comment on or contact you in response to your post. If you maintain an account with us, we do not typically associate this information with your account.

Ethics/Incident Reporting: on certain of our Websites, you may file a report if you have concerns regarding an action taken by an employee or contractor with our company. We collect the information that you choose to submit as part of your report.

Trade Shows/Events: at certain trade shows, we offer the opportunity to provide us with your contact information to learn more about our services.

Make an Appointment/Contact Us Regarding Employment: you may create an appointment to meet with us at an upcoming job fair or similar event. You also may forward information about the job fair/employment to your friends. Our use of the information collected in the context of an employment inquiry is governed by our job applicant notice, not this one.

We collect additional information from our clients during the account creation process and throughout your relationship with us. The information may include:

Account creation/sign-up process: If you sign up for a service with us, we will collect information from you during the account creation process. Most of our services are offered to business customers; if your company obtains a service from us, then we will obtain the name of the designated representatives for the company (for payment, service, support), contact information for those persons, services purchased, information about trouble tickets submitted and resolution of the same, and any other information provided by your employer.

Customer Portal: we offer customer portals on certain of our Websites; in some circumstances, we work with you offline to set up the portal credentials, and, for other accounts, you may set up your account access directly online. In doing so, we collect identifying information such as your business contact information and chosen password. We also collect user information about access to the portal, such as log in/out times and user IDs of persons logging in. Certain of our portals permit persons who interact with our customers to access the portal. For example, we may provide a portal to a homeowners’ association and residents in that community may request a parking permit through that portal. In those circumstances, any information that we collect about the end user is in our capacity as a service provider to our customer, and the customer controls the scope of the information that we collect from you.

Information We Collect About You from Other Sources:

We collect information about you from your employers and your friends. For example, your employer may provide us with a list of employees authorized to use our services/log into our portals. If your friend forwards a job opportunity to you or information about a job fair, then we will collect your contact information. From time to time, we may purchase a list of prospective customers, which would contain business contact information.

Information We Collect Automatically:

We automatically collect usage data regarding your use of our websites through cookies, web beacons, and other technologies (referred to generally as usage data): your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit or use our websites; and the referring URL, or the webpage that led you to our website. We may also collect your approximate city through collection of your IP address. Typically, we do not combine this information with other information that we have collected about you, including, other personal information. Please see the section “Cookies and Other Tracking Technologies” below for more information.

Information We Collect in Our Capacity as a Service Provider:

Our services are provided predominantly to businesses. Our customer directs the scope of information that we collect about you and the purpose of that collection.

Our Use of Your Information

We use your information, including your personal information, for the following purposes:

For customer services purposes, including to respond to your inquiries, to make an appointment with you.

To provide our services to you, including to fulfill your orders, and to communicate with you about your use of our services.

Where permitted by applicable law or with your consent, to send you email communications, including email marketing about our products and services that we offer as well as the products and services of our affiliates.

To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the websites.

For marketing and promotional purposes. We use your email address to send you information about products and services that we think may be of interest to you, including information about our affiliates’ products and services, to the extent permitted by applicable law. We also may use the information that we learn about you to assist us in advertising our products and services on other websites.

To determine the relevance and success of our advertising campaigns. We may count ad impressions of unique visitors, verify quality of the ad impressions, and take similar measures to determine relevance and success of our online advertising.

To better understand how users access and use our Websites (such as which pages users visit most); to improve our Websites, and for other research and analytical purposes (such as evaluating product demand per market).

To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.

Debugging to identify and repair errors and overall Website maintenance and improvement.

To comply with legal obligations, as part of our general business operations, and for other business administration purposes.

Where we believe necessary to detect, investigate, prevent or take action regarding security incidents, illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

Our Disclosure of Your Information

We share your information, including your personal information, with the following persons and in the following circumstances:

Service providers: we disclose your personal information to service providers for a business purpose. These entities include service providers that host our website; assist us in advertising, measuring the success of our advertising campaigns; maintaining or improving our products and services; and for any other purpose as described above in the section above regarding our use of your personal information.

Our affiliates: where permitted by applicable law or with your consent, we may share your information with our affiliated entities for their own marketing purposes.

Our customers: if you contact us online about a matter pertaining to one of our customers (e.g., you visited a building staffed with our security guards), then we may forward your information to the customer.

Business Transfers: if we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.

In Response to Legal Process: we also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. We may disclose this information to law enforcement, regulators, or other parties as required to satisfy these purposes.

To Protect Us and Others: we may disclose the information we collect about you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms or this Policy, or as evidence in litigation in which we are involved. We may disclose this information to law enforcement, regulators, or other parties as required to satisfy these purposes.

Our Use of Cookies and Other Tracking Technologies

We and entities we engage (to assist us with website analytics, marketing, evaluating the success of our marketing campaigns, and targeted advertising) use cookies and other tracking technologies to track information about your use of our Websites. Typically, we do not combine this information with other personal information we collect from you.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Websites, while others are used to enable a faster log-in process or to allow us to track your activities at our Websites. There are two types of cookies: session and persistent cookies.

Session Cookies

Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Websites.

Persistent Cookies

Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on certain of our Websites and on sites operated by other entities.

Disabling Cookies

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Websites who disable cookies will be able to browse certain areas of the Website, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Websites to, among other things, track the activities of visitors to our Websites, help us manage content, and compile statistics about Website usage. We and our vendors also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Analytics

We use automated devices and applications, such as Google Analytics, to evaluate usage of our

Website

We also may use other analytic means to evaluate the services offered on our Website. We use these tools to help us improve our services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track

Currently, our systems do not recognize web browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Vendor Ad Network section.

Vendor Ad Networks

We use vendors such as network advertisers to serve advertisements on websites other than this Website or other media (e.g., social networking platforms). This enables us and these vendors to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each vendor’s specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you.

Users in the United States may opt out of many vendor ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. To opt-out and for additional information, please go to: optout.aboutads.infoand optout.networkadvertising.org.

Security

We cannot ensure that information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), third parties may unlawfully intercept or access files, transmissions or private communications. Therefore, although we use industry standard practices to protect information, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

Contacting Us

If you have any questions about this Privacy Policy, or if you would like to review, change, or remove your personal information, you can e-mail us at information@cookepi.com. Additionally, you can contact us by writing to:

Cooke & Associates, Inc.,
696 San Ramon Valley Blvd. #361
Danville, CA 94526

Important Additional Privacy Information for California Residents

Under the California Consumer Privacy Act (“CCPA”), we are required to notify California residents about the personal information that we collect about them, whether online or offline, and how we handle their personal information.

Except for the Right to Opt-Out and the Right of Non-Discrimination, this section does not apply to California residents with whom we communicate in the context of our business relationship (e.g., when we are providing a product or service to our customers). This section also does not apply to personal information we collect about job applicants, employees, or our independent contractors.

A. Categories of Personal Information Under the CCPA

While our collection, use, and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated data above).

Categories of Personal Information Collected and Disclosed

The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, much of which is collected in our capacity as a service provider to a business, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use, and disclose personal information, please see the Our Use of Your Information and the Our Disclosure of Your Information sections above.

Do We “Sell” Personal Information?

Under the CCPA, a “sale” includes disclosing or making available personal information to a third party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third-party ad companies (through third-party tags on our Website) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” certain categories of personal information as follows: identifiers; customer records; commercial information; and usage data. We share these categories with third-party advertising networks, social networks, and data analytics providers (such as when we allow third-party tags to collect browsing history and other information on our Website to improve and measure our ad campaigns).

Sources of Personal Information

As further described in the Information We Collect About You section above, we may collect personal information from the following sources:

  • Directly from the individual
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Internet service providers
  • Operating systems and platforms
  • Data brokers
  • Business customers

B. California Residents’ Rights

CCPA Rights

In general, with the exception of our use of business contact information in our capacity of providing services to you, you have the rights listed below. With regard to information that we obtain about you and use in furtherance or providing a service that you or your employer has purchased, you have the right to opt-out of the sale of your personal information and the right to non-discrimination.

Cooke & Associates