Privacy Policy

Effective Date: January, 2024

Overview

Cobana Room Brand (“Cobana”,”Cobana room”,” “we,” or “us”) is dedicated to safeguarding your privacy and ensuring the security of your personal information. This Privacy Policy outlines the procedures by which we gather, utilize, and share your personal information. The scope of this Privacy Policy extends to personal information obtained through our website, www.cobanaroom.com, collectively referred to as the “Sites.” By accessing and using our Sites, you indicate your agreement to abide by our Privacy Policy, subject to periodic amendments. If you do not consent to the terms outlined in this Privacy Policy, we kindly ask that you refrain from using our Sites. Additional details regarding the guidelines governing your usage of our Sites are available in our Terms & Conditions.

INFORMATION WE COLLECT ABOUT YOU

The term “Personal information” pertains to data that can identify, be associated with, or reasonably linked directly or indirectly to you or your household. Publicly available, de-identified, or aggregated information is excluded from this category. The following chart provides an overview of the personal information categories we gather:

Personal Identifiers Name, alias, postal address, phone number, username, and password for our Sites, IP address, email address.

Payment Information We only store information provided by customers for shipping purposes, including: customer name, email, contact phone number, shipping address, and any additional information provided by customers or requested by us for delivery purposes.

Commercial Information Details concerning products or services acquired, obtained, or considered, along with other purchasing or consuming histories or tendencies, and information obtained through promotions.

Internet or Other Electronic Network Activity Information Browser type and language, operating system, website access time, duration of visit, referring website address, browsing and search history on our Sites, webpages viewed immediately before and after our Sites, emails sent to us, and data associated with the use of links in our emails and advertisements, as well as app usage data.

Inferences About You From Any Other Category of Information We Collect Information that reflects your preferences, characteristics, trends, or attitudes.

HOW WE GATHER YOUR PERSONAL INFORMATION

We acquire your personal information through diverse channels, encompassing both direct contributions from you and automatic data collection during your interaction with our Sites. While there may be instances where you can choose the information to provide, certain features of our Sites may necessitate specific details from you. A summary of the sources from which we collect personal information is outlined below, followed by a more detailed explanation of each category:

Personal Identifiers

(1) Directly from you.

(2) Automatically when you engage in specific actions.

(3) Through the use of cookies and tracking technologies.

(4) Via Website Analytics Information.

Payment Information

(1) Directly from you.

(2) For security reasons, we employ a tokenized system that does not retain credit card numbers.

Commercial Information

(1) Directly from you.

(2) Automatically when you engage in specific actions.

(3) Through the use of cookies and tracking technologies.

(4) Via Website Analytics Information.

Internet or Other Electronic Network Activity Information

(1) Directly from you.

(2) Automatically when you engage in specific actions.

(3) Through the use of cookies and tracking technologies.

(4) Via Website Analytics Information.

Inferences About You From Any Other Category of Information We Collect

(1) Automatically when you engage in specific actions.

(2) Through the use of cookies and tracking technologies.

(3) Via Website Analytics Information.

(1) Directly from you: We gather personal information directly from you, and this includes instances when you, or someone acting on your behalf, supplies information to us for the following purposes:

• Making product purchases from us;
• Creating an account with us;
• Subscribing to our email communications/newsletter;
• Inputting search terms on our Sites;
• Utilizing the Wishlist feature on our Sites;
• Posting comments or reviews on our Sites or social media pages;
• Seeking technical support;
• Contacting us via phone, email, text, online chat, or postal mail; or
• Connecting with us through social media.

(2) Automatically when you engage in specific actions: Apart from the information you voluntarily provide, both we and our service providers may automatically gather certain personal information about you in the following situations:

• Browsing or conducting searches on our Sites;
• Downloading materials from our Sites, such as brochures or catalogs;
• Opening an email or text message from us or clicking on links within our emails or texts;
• Engaging in online chat conversations with us;
• Clicking on online advertisements for our products;
• Visiting our social media profiles and sites; or
• Posting or sharing information about us or our products.

Additionally, on occasion, we may acquire personal information from third parties through purchase.

(3) Through the use of cookies and tracking technologies: Both we and our service providers employ cookies and other tracking technologies, such as web beacons, tracking pixels, and HTTP referrers, to gather and store information regarding your interactions with our Sites. This includes details about your browsing and purchasing activities, as well as the tracking of conversions resulting from our advertisements. Cookies, which are small files transferred to a computer’s hard drive via a web browser, enable the recognition of the user’s browser by the site’s or service provider’s systems, capturing and remembering specific information. In essence, cookies and tracking technologies are utilized to enhance the functionality of our Sites, such as storing your browsing preferences for future visits and identifying repeat visitors. They also aid in optimizing our chat functionality, understanding how our Sites are utilized, and presenting users with content or advertising based on their browsing activities. These technologies may be employed by third parties, including search engines, maps, and social media networks, who may collect and provide us with your personal information. If you prefer not to have cookies placed on your device, you can configure your browser to reject cookies before accessing our Sites. Instructions for adjusting your browser settings can be found in your browser’s Help menu. It’s important to note that disabling cookies may impact the proper functioning of some features on our Sites. Moreover, emails sent by us and our marketing service providers may contain tracking tools providing insights into whether you’ve opened an email or clicked on links within it. Details on how to unsubscribe from our marketing emails can be found below.

(4) Via Website Analytics Information: We utilize Google Analytics to ensure the functionality of our website and enhance the user experience on our Sites. This software may capture various information, including your IP address, location, age, gender, browser type and language, operating system, access time, duration of visit, pages viewed within our Sites, search terms entered, and other activities performed during your visit. Additionally, it records the pages you access immediately before and after visiting our Sites, your frequency of site usage, aggregated usage and performance data, application errors, and debugging information. Google Analytics, owned and operated by Google LLC, manages the data collected, and its handling is governed by Google’s privacy policy. To manage your preferences regarding Google Analytics cookies, you can visit https://tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-out Browser Add-on. This provides you with the option to control the information gathered through Google Analytics.

HOW WE UTILIZE YOUR PERSONAL INFORMATION

We employ your personal information for the following objectives:

Type of personal information or data	Purpose(s) for which we use this information
Personal Identifiers	To engage in communication with you regarding our products and your orders. To fulfill orders and facilitate the delivery of your purchases. To identify and prevent fraudulent activities that may affect you and/or us. To display relevant advertisements while you are browsing the web or using social media. To contact you for gathering insights into your product preferences and soliciting feedback to enhance our business. To communicate with you about updates related to our Sites, policies, and other aspects of our business.
Payment Information	Fulfill orders
Commercial Information	To engage in communication with you regarding our products and your orders. To fulfill orders and facilitate the delivery of your purchases. To offer you suitable products, recommendations, and updates. To enhance your ability to discover relevant products more efficiently. To provide customer service and support. To refine our marketing and advertising strategies. To identify and prevent fraudulent activities that may impact you and/or us. To display pertinent advertisements while you are browsing the web or using social media. To contact you for insights into your product preferences and feedback to improve our business. To communicate with you about updates related to our Sites, policies, and other aspects of our business.
Internet or Other Electronic Network Activity Information (including Geolocation Data and information collected via website analytics or through cookies and other tracking technologies)	Facilitating convenient login experiences on our Sites for you. Offering suitable products, recommendations, and updates. Enhancing the efficiency of locating relevant products. Assisting you in finding authorized dealers that sell our products. Displaying pertinent advertisements while you browse the web or use social media, and refining our marketing campaigns. Enhancing our Sites, configuring default options, and providing an improved website experience. Improving our marketing and advertising strategies. Safeguarding the security of our Sites. Identifying and preventing fraudulent activities that may affect you and/or us.
Inferences Derived From Other Categories of Personal Information We Collect	Offering you suitable products, recommendations, and updates. Enhancing the efficiency of locating relevant products. Providing customer service and support. Improving our Sites, configuring default options, and delivering an enhanced website experience. Enhancing our marketing and advertising strategies. Safeguarding the security of our Sites. Identifying and preventing fraudulent activities that may impact you and/or us.
Publicly Available Information	Any purpose
Aggregated/De-identified Information	We have the option to aggregate and/or de-identify your personal information, rendering it no longer associated with you. Such aggregated/de-identified information may be utilized and shared for any purpose at our sole discretion.

DISCLOSURE OF YOUR PERSONAL INFORMATION

The following outlines our practices regarding the disclosure of your personal information to third parties. When we disclose your personal information, we ensure that our contractors, business partners, and service providers use the information in compliance with the terms outlined in this Privacy Policy.

Cookies, Tracking Technologies, and Website Analytics

We employ cookies, tracking technologies, and website analytics that may grant third parties access to the disclosed personal information. Third parties, including search engines, maps, and social media networks, are authorized to place cookies on the browsers of individuals visiting our Sites who accept the use of cookies. This data enables our third-party partners to assess the effectiveness of advertising and deliver tailored advertisements on other websites, potentially constituting a sale or sharing of personal information for cross-context behavioral advertising.

Service Providers and Contractors

We disclose personal information to service providers and contractors for various business purposes, including but not limited to:

• Auditing and Ad Impression: Counting ad impressions, verifying ad positioning and quality, and auditing compliance with specifications and standards.
• Security and Fraud Detection: Detecting and preventing security incidents, protecting against malicious activity, and prosecuting those responsible.
• Functionality & Debugging: Identifying and rectifying errors impairing intended functionality.
• Short-Term/Transient Use: Utilizing personal information for short-term, non-personalized advertising within the current interaction with the business.
• Services on Our Behalf: Maintaining or servicing accounts, providing customer service, processing orders, verifying customer information, processing payments, analytics, storage, or similar services.
• Advertising and Marketing Services: Providing advertising or marketing services on our behalf.
• Research & Development: Internal research related to technological development and demonstration.
• Quality Control & Improvement: Verifying, maintaining, and enhancing our products and services.

As Necessary

We may disclose personal information as necessary for:

• Legal Compliance: Complying with legal processes and responding to requests from public and government authorities.
• Enforcement: Enforcing our terms and conditions, protecting our operations, rights, privacy, safety, or property, and/or that of others.
• Remedies and Limiting Damages: Pursuing available remedies or limiting potential damages.
• Insurers and Professional Advisers: Disclosing to insurers and professional advisers for risk management, obtaining professional advice, or defending against legal claims.
• Business Transactions: Disclosing in connection with reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other disposition of our business, assets, or stock.

The chart below outlines the categories of personal information that we disclose for business purposes.

Type of personal information	Purpose(s) for which we disclose this information
Personal Identifiers	Used for Auditing and Ad Impression Employed in Security and Fraud Detection Utilized in Functionality & Debugging Involved in Short-Term / Transient Use Disclosed for Services on Our Behalf Utilized in Advertising and Marketing Services Employed in Research & Development Used for Quality Control & Improvement of Products and Services Disclosed As Necessary
Payment Information	Services on Our Behalf As Necessary
Commercial Information	Auditing and Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products and Services As Necessary
Internet or Other Electronic Network Activity Information (including Geolocation Data and data acquired through website analytics or via cookies and other tracking technologies)	Utilized for Security and Fraud Detection
Functionality & Debugging	Services on Our Behalf Advertising As Necessary
Inferences From Other Categories of Personal Information We Collect	Advertising As Necessary

VIDEO CONTENT

Content on our Sites may be subject to the regulations of the Video Privacy Protection Act (“VPPA“). Certain cookies and tracking technologies mentioned earlier may grant others access to your personal information (or personally identifiable information as defined by the VPPA). If the VPPA is applicable to our Sites or any content therein, your use of our Sites explicitly implies consent to our practices, including those pertaining to video content or governed by the VPPA.

DURATION OF PERSONAL INFORMATION RETENTION

We will retain your personal information for the duration necessary to fulfill the purposes for which it was collected. In determining the appropriate retention period, we take into account factors such as the quantity, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for processing the information, the feasibility of achieving those purposes through alternative means, and relevant legal requirements.

PUBLIC FORUMS, REVIEWS, AND TESTIMONIALS

Our Sites offer features allowing customers to provide reviews and share their experiences with our products. While participation in these features is optional, if you choose to use them, exercise good judgment when posting in these communities or sharing information, photos, or videos. It’s important to note that any personal information submitted in reviews, testimonials, communities, or forums may be read, collected, or utilized by others, potentially resulting in unsolicited messages to you. Despite our safety and privacy controls, we cannot guarantee immunity from inappropriate or illegal conduct by third parties. To maintain a welcoming environment for all users, please report any offensive or unwelcome conduct to us. We may enlist the assistance of service providers in delivering these community services to you.

OUR PRODUCTS AND WEBSITES ARE NOT INTENDED FOR CHILDREN

Our products and Sites are not designed for, nor targeted to, children under the age of eighteen (18). We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have obtained information from a child under the age of 18, we will promptly delete such information in accordance with the Children’s Online Privacy Protection Act (“COPPA”) or other applicable laws, such as the California Privacy Rights Act. If you are a parent or guardian and believe that your child under the age of 18 has provided us with personal information without your consent, please contact us at support@cobanaroom.com.

EMAIL COMMUNICATIONS

To opt-out of our marketing communications, you can click the “unsubscribe” link provided in every commercial email we send or send a request to unsubscribe to support@cobanaroom.com. Even if you choose not to receive marketing email communications, please note that we may still send you emails related to your account or specific transactions with us. Unsubscribing from our marketing communications will not impact the service we provide to you.

TEXT MESSAGES AND ALERTS — OPTING IN AND OUT

You have the option to opt-in to receive text/SMS messages and alerts on the mobile phone number(s) you provide to us. Upon opting in, we may send you text messages for purposes such as (i) account-related notifications, (ii) fraud prevention, and (iii) emergency alerts, utilizing auto-dialed technology. We will not contact you via text messages or alerts for marketing purposes without obtaining your prior express written consent. Opting in for text messages and alerts is not mandatory for using and enjoying our Sites or products. Standard text messaging charges may apply if you choose to opt-in. For more details regarding our text messaging and alerts, feel free to contact us at support@cobanaroom.com or 1-315-997-0795. If you wish to opt-out of our text messages and alerts, you can do so at any time using any reasonable means. To directly opt-out, simply send us a text message from your mobile phone with any of the following keywords: STOP, STOP ALL, END, QUIT, CANCEL, or UNSUBSCRIBE, and we will promptly unsubscribe you from text communications. Upon opting out, you will no longer receive any additional text messages via your mobile phone. Please note that opting out may result in our inability to contact you with important messages about your account. However, in case of emergencies or account-related queries, we will make every effort to reach you through alternative means, such as email or a landline phone.

DO NOT TRACK

At present, we lack the technology to automatically acknowledge and respond to “Do Not Track” (DNT) signals transmitted by web browsers, mobile devices, or other mechanisms. If you are a California resident seeking to delete your personal information, kindly refer to the instructions for submitting such requests provided below.

INFORMATION SECURITY

We have instituted suitable and sensible physical, technical, and administrative safeguards to mitigate the risk of unauthorized access, use, and disclosure of your personal information. Nonetheless, perfect security is unattainable, and we cannot assure the absolute security of your personal information. We encourage you to contribute to the security of your personal information by preserving the confidentiality of any credentials used to access your account and promptly reporting any suspected unauthorized activity to us.

YOUR CALIFORNIA PRIVACY RIGHTS

If you reside in California, your entitlement to make certain requests regarding your personal information is outlined below. Please be aware that, when submitting a request, you will be required to provide information for identity verification before any action is taken. While you may appoint an authorized agent to submit the requests on your behalf, you must still directly verify your identity with us before your request can be processed.

Right to Opt-Out of the Sale or Sharing of Your Personal Information

California residents possess the right to opt-out of the sale of their personal information. As detailed in the “How We Disclose Your Personal Information” section above, some of our practices may qualify as a sale or sharing (for cross-context behavioral advertising) of personal information. You can exercise your right to opt-out by emailing support@cobanaroom.com.

Right to Limit the Use of Your Sensitive Personal Information

California residents have the right to request that a company restrict the use or disclosure of their sensitive personal information to what is necessary for providing expected services or goods, including other authorized purposes under California law. Since we do not collect, use, or disclose any sensitive personal information, this right does not apply to you.

Right to Know / Request More Information

If you are a California resident, you hold the right to know, to the extent applicable: (1) the categories of personal information we have collected about you; (2) the categories of sources from which the personal information was collected; (3) our business or commercial purposes for collecting your personal information; (4) the categories of third parties to which we sold your personal information; and (5) the specific pieces of personal information we have collected about you. Additionally, you have the right to know the list of all third parties to whom we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (also known as the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. For California residents, as we disclose your personal information as described above, you have the right to request that we disclose to you: (1) the categories of personal information that we collected about you; (2) the categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, categorized by each category of personal information for each category of third parties to whom the personal information was sold; and (3) the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. To request the information above, please email us at support@cobanaroom.com or call us at 1-315-997-0795. As part of your request submission, you will need to verify your identity before any action is taken. We will provide you with the necessary information for verification.

Right to Correct Inaccurate Information

California residents also retain the right to request correction of personal information collected or maintained by us. If you believe that any of the personal information we hold about you is inaccurate, you have the right to submit a correction request. Upon receiving such a request, we will make commercially reasonable efforts to correct the information as directed by you. To submit a request for correction, please email us at support@cobanaroom.com or call us at 1-315-997-0795. In conjunction with your request submission, you will need to verify your identity before any action is taken. We will provide you with the necessary information for verification.

Right to Request Deletion of Your Personal Information

California residents also possess the right to request the deletion of their personal information collected or maintained by us. We will inform you of any personal information that can be deleted from our records, and we will instruct any service providers who may have collected personal information about you to delete it from their records as well. Certain circumstances may prevent us from deleting your personal information or directing service providers to do so. For instance, if we need to: (1) retain your personal information to complete a transaction or provide services; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug, or repair errors; or (5) comply with a legal obligation. To submit a request for the deletion of your personal information, please email us at support@cobanaroom.com or call us at 1-315-997-0795. As part of your request submission, you will need to verify your identity before any action is taken. We will provide you with the necessary information for verification.

Verification of Requests to Know, Correct, or Delete Personal Information

Upon receipt of a request to know, correct, and/or delete information, we will take reasonable steps to confirm that the person submitting the request is the individual to whom the information relates (or their authorized agent) and to prevent unauthorized access or deletion of information. The specific verification steps may vary based on the nature of the request, including the type, sensitivity, and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood of fraudulent or malicious actors seeking the information, the robustness of personal information provided for identity verification, the nature of our business relationship with you, and available technology for verification. We will strive to minimize the need for additional information for verification purposes, but if necessary, we may request additional information if we cannot verify your identity based on the information already in our possession. Any additional information obtained will be used solely for the purpose of verification and will be promptly deleted after processing the request, unless otherwise required by law. The following outlines the general verification processes we employ:

Password Protected Accounts

If you have a password-protected account with us, we may utilize existing authentication practices to verify your identity, requiring re-authentication before disclosing or deleting data. In cases of suspected fraudulent or malicious activity, additional verification may be necessary before complying with a request to know, correct, and/or delete.

Verification for Non-Accountholders

For individuals without or unable to access a password-protected account, verification typically involves the following:

• For requests to know categories of personal information, we will verify identity to a reasonable degree by matching at least two data points provided by you with reliable data points in our possession.
• For requests to know specific pieces of personal information, we will verify identity to a reasonably high degree by matching at least three data points provided by you with reliable data points in our possession. Additionally, a signed declaration under penalty of perjury is required, confirming that the requester is either the individual whose information is the subject of the request or their authorized representative. Signed declarations will be retained as part of our records.
• For requests to correct or delete personal information, we will verify identity to a reasonable or reasonably high degree, depending on the sensitivity of the personal information and the risk of harm associated with unauthorized deletion. Our determination of the appropriate standard will be made in good faith.

If no reasonable method exists to verify your identity, we will clearly state so in response to a request to know or delete personal information, providing an explanation for the absence of a reasonable verification method.

Right to Non-Discrimination for Exercising Your Privacy Rights

Should you decide to exercise any of the privacy rights granted by the California Privacy Rights Act, you are entitled to receive fair treatment from us without facing discrimination. In accordance with California law, we will not refuse to provide our services to you, apply varying prices, or offer a different standard or quality of service unless such distinctions are directly related to the value of your personal information.

YOUR RIGHTS IF YOU ARE A RESIDENT OF COLORADO, CONNECTICUT, VIRGINIA, UTAH, TEXAS, OREGON, FLORIDA, OR MONTANA

If you reside in Colorado, Connecticut, Utah, Virginia, Texas, Oregon, Florida, or Montana, certain additional rights may apply to you, as outlined below. The rights of residents in Colorado, Connecticut, and Virginia are currently in effect, while the rights of residents in Utah will become applicable on December 31, 2023. Residents in Florida, Oregon, and Texas will have these rights effective from July 1, 2024, and residents in Montana from October 1, 2024. Please note that these rights may have exceptions and verification mechanisms.

• The Right to Know: You have the right to know if we are processing your personal information. If you are an Oregon resident, you also have the right to know the categories of your processed personal information and the specific third parties to which it has been disclosed.
• The Right of Access: You can access your personal information and obtain a copy of it in a readily usable format, if feasible.
• The Right to Correct Inaccuracies: You may request corrections for inaccuracies in your personal information. Utah law does not provide for this right.
• The Right to Delete: You can request the deletion of your personal information, except when retention is required by law or contractual obligation.
• The Right to Data Portability: You have the right to receive a copy of your data in a portable and, if feasible, readily usable format.
• The Right to Opt-Out: You may choose to prevent your personal information from being:
  • Used in targeted advertising.
  • Sold.
  • Used for profiling purposes that may produce legal or similarly significant effects. (Utah law does not provide for this right.)
• The Right to Non-Discrimination for Exercising Your Rights: If you exercise your rights, you have the right not to receive discriminatory treatment from us.
• Rights Regarding Sensitive Personal Information: We do not collect sensitive personal information. If our practices change.
  • If you are a resident of Utah or Oregon, we will not process that information without clear notice and an opt-out opportunity.
  • If you are a resident of Colorado, Connecticut, Florida, Montana, Texas, or Virginia, we will not process sensitive personal information without your consent.

For individuals aged 13 to 16, we will not process personal information for targeted advertising, profiling, or selling without consent. You can submit requests via email to support@cobanaroom.com or by calling us at 1-315-997-0795. Information requests under “Right of Access” will be securely transmitted. If we cannot fulfill your request, we will provide reasons within 45 days, and you can appeal. If the result is the same, you can seek assistance from your state attorney general.

NEVADA PRIVACY NOTICE

According to Nevada law, residents of Nevada have the right to opt-out of the “sale” of “covered information” to third parties. This covered information includes, but is not limited to, name, address, social security number, and online service activity. However, our use of your personal information does not fall under the definition of sales as per Nevada law, and therefore, no opt-out action is required.

NON-U.S. VISITORS

Our Sites are designed for a U.S. audience, and this Privacy Policy aligns with U.S. laws and regulations. It may not be entirely consistent with or as comprehensive as the laws of other countries. If you are situated outside the United States, please be aware that any information you provide will be transferred to the United States. By submitting information, you explicitly authorize its transfer.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Privacy Policy at our discretion and at any time. It is your responsibility to review our Privacy Policy before using our Sites or submitting personal information to us.

HOW TO CONTACT US

If you have any comments or questions regarding the collection and usage of your personal information, you can reach us via email at support@cobanaroom.com or by calling us at 1-315-997-0795.

WHAT’S NEW

We have recently updated our Privacy Policy to include information about the types of personal information we collect, its uses, additional rights for residents of various states, and a disclosure for the Video Privacy Protection Act (VPPA).