OUR COMMITMENT

Thank you for choosing to be part of our community at COA Sanctuary. We are committed to protecting your personal information and your right to privacy, and to providing a compliant and consistent approach to data protection.

We take your privacy very seriously. At COA Sanctuary we are dedicated to safeguarding the personal information and in developing a data protection system that is safe and effective on both parties.

If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at COA Sanctuary.

This privacy policy applies to all information collected through our website (such as COA Sanctuary, mobile application, (“Apps”), and/or any related services, products, sales, marketing or event sites.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Personal information you disclose to us

COA Sanctuary collects personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.

We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites  (such as making payments,  posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.

The personal information that COA Sanctuary collects will depend on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we sometimes collect, should you choose to volunteer it to us, can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your credit card number, and the security code associated with your payment card. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit COA Sanctuary Sites or Apps.

COA Sanctuary automatically collects certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of COA Sanctuary Sites or Apps, and for our internal analytics and reporting purposes.

By choosing to use COA Sanctuary Sites and Apps, you agree to our discretionary use of cookies for general purposes intended to enhance user experience.

Information collected through our Apps

If you use COA Sanctuary Apps, we may also collect the following information:

  • GeoLocation Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’as settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, calendar, camera, reminders, sms messages, social media accounts, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
  • Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to optout from receiving these types of communications, you may turn them off in your device’s settings.

Information collected from other sources

COA Sanctuary may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

HOW COA SANCTUARY WILL USE YOUR INFORMATION?

COA Sanctuary will use your personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests and purposes, in order to enter into or perform a contract with you and, with your consent, and/or for compliance with our legal obligations as indicated below.

COA Sanctuary will use the information collected:

  • To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
  • To send administrative information to you for Business Purposes and/or Legal Reasons. COA Sanctuary may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • Fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites or Apps.
  • Deliver targeted advertising to you for our Business Purposes COA Sanctuary may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
  • Request Feedback for Business Purposes. COA Sanctuary may use your information to request feedback and to contact you about your use of our Sites or Apps.
  • To protect our Sites for Legal Reasons. COA Sanctuary may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
  • To enable user-to-user communications with your Consent. We may use your information in order to enable user-to-user communications with each user’s consent.
  • To enforce our terms, conditions and policies for Business Purposes and/or for Legal Reasons.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Apps, products, services, marketing and your experience.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

COA Sanctuary will only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

COA Sanctuary only share and disclose your information in the following situations:

  • Compliance with Laws. COA Sanctuary may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests and Legal Rights. COA Sanctuary may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • Business Transfers. COA Sanctuary may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • With your Consent. We may disclose your personal information for any other purpose with your consent.

USING COOKIES AND OTHER TRACKING TECHNOLOGIES

COA Sanctuary may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. By choosing to use COA Sanctuary Sites and Apps, you agree to our discretionary use of cookies for general purposes designed to enhance user experience.

DO WE USE GOOGLE MAPS?

COA Sanctuary may use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. You agree to allow us to obtain or cache your location. You may revoke your consent at anytime. We use information about location in conjunction with data from other data providers.

USING YOUR SOCIAL MEDIA LOGINS?

If you choose to register or log in to our websites using a social media account, COA Sanctuary we may have access to certain information about you.

Our Sites or Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.

COA Sanctuary will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

HOW LONG COA SANCTUARY KEEPS YOUR INFORMATION?

COA Sanctuary will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

KEEPING YOUR INFORMATION SAFE

COA Sanctuary have implemented appropriate technical and organizational security measures designed to protect the security of any personal information COA Sanctuary will process according to the following policies and procedures:

    • Data Protection – our main policy and procedure document for data protection has met the standards and requirements to protect your privacy. Accountability and governance measures are in place to ensure that COA Sanctuary understands and adequately disseminates and evidence of COA Sanctuary obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
    • Data Retention & ErasureCOA Sanctuary have updated our retention policy and schedule to ensure that COA Sanctuary meets the “data minimization” and “storage limitation” principles and that personal information is stored, archived and destroyed compliantly and ethically. COA Sanctuary have dedicated erasure procedures in place to meet the new “Right to Erasure” obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
    • Data BreachesCOA Sanctuary breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. COA Sanctuary procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
    • International Data Transfers & Third-Party DisclosuresCOA Sanctuary has robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules, standard data protection clauses or approved codes of conduct for those countries without. COA Sanctuary  carries out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
    • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
    • Legal Basis for ProcessingCOA Sanctuary will review all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to.
    • Privacy Notice/PolicyCOA Sanctuary will ensure that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
    • Obtaining ConsentCOA Sanctuary will ensure that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information.
    • Direct MarketingCOA Sanctuary will include clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
    • Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; COA Sanctuary have developed stringent procedures and assessment templates for carrying out impact assessments.

 

  • Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), COA Sanctuary  have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance.
  • Special Categories Data – where we obtain and process any special category information, COA Sanctuary will do so in complete compliance with requirements and have high-level encryptions and protections on all such data.

DO WE COLLECT INFORMATION FROM MINORS?

COA Sanctuary does not knowingly collect data from or market to children under 18 years of age.

COA Sanctuary does not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at COA Sanctuary.

WHAT ARE YOUR PRIVACY RIGHTS?

You may review, change, or terminate your account at any time.

PROMOTIONS

COA Sanctuary may run promotions on our websites that require submission of personally identifiable information by participants. COA Sanctuary may use the information collected so we can determine, for example, how many visitors to our website participated in the promotion. Promotions are subject to change without notice.

DISCLAIMER OF RELIABILITY

COA Sanctuary makes no representations or warranties regarding the condition or functionality of this website, its suitability for use, or that this web service will be uninterrupted or error-free.

DISCLAIMER OF DAMAGES

By using the COA Sanctuary website, you assume all risks associated with the use of the site, including any risk to your computer, software or data being damaged by any virus, software, or any other file that might be transmitted or activated via COA Sanctuary website or your access to it. COA Sanctuary shall not be liable for any damages of any kind (general, special, incidental or consequential damages, including, without limitation, lost revenues or lost profits) resulting from the use or misuse of the information contained in the COA Sanctuary website.

DISCLAIMER OF ENDORSEMENT

Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply endorsement, recommendation, or favoring by COA Sanctuary. The views and opinions of authors expressed herein do not necessarily state or reflect those of COA Sanctuary and shall not be used for advertising or product endorsement purposes.

COPYRIGHTS AND TRADEMARKS

Copyright (c) 2020 COA Sanctuary. All Rights Reserved

All material on this website is copyrighted by COA Sanctuary, except for some material that is copyrighted by others and used here by permission. Copyrighted material may not be copied, reproduced or otherwise used for commercial purposes without the written permission of the copyright holder. This site also contains some trademarks, which may not be appropriated by persons other than the trademark owner and may not be used contrary to trademark law. If you wish to request permission to use materials in a manner otherwise prohibited herein, please contact COA Sanctuary.

ACCOUNT INFORMATION

If you would at any time like to review or change the information in your account or terminate your account, you can: Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may: Access your account settings and update preferences.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy-to-access information via our website, of an individual’s right to access any personal information that COA Sanctuary  processes about them and to request information about:

  • What personal data we hold about them
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from them, information about the source
  • The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
  • The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
  • The right to lodge a complaint or seek judicial remedy and who to contact in such instances

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHT

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Sites or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

COA Sanctuary will update this policy as necessary to stay compliant with relevant laws.

COA Sanctuary may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

Information Security & Technical and Organizational Measures
COA Sanctuary takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process. COA Sanctuary has security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: SSL for data collection forms, access controls and restrictions to minimize who can access data, password policy, encryption, security training for staff, and restricted physical access to servers.

CONTACT US ABOUT THIS POLICY

If you have questions or comments about this policy, you may contact COA Sanctuary