Privacy Policy


Privacy Policy for Cotonomy, Inc.

Thank you for visiting our website (the “Site”) and reviewing this Privacy Policy (“Policy”).   This Site is owned, operated and controlled by Cotonomy, Inc (“Cotonomy” or “we,” “our,” or “us”).  Cotonomy respects your privacy and is committed to protecting it through your compliance with this Policy.

This policy (together with our Terms of Use found at  Privacy Policy and any other agreement you enter into in connection with your registration as either a member or an advertiser) describes the personal information that we may collect from you, or that you may provide on this Site or through your use of our web-based software platform which allows consumers to submit personal information about themselves to advertisers, and in turn advertisers can use this information to send targeted advertisements to consumers (the “Exchange”), how that information may be used or disclosed by us, the choices you have regarding our use of the information, and your ability to control our disclosure of it.

Please read the following Policy carefully to understand our practices regarding your personal information and how we will treat it.  By using or accessing the Site or using the Exchange you agree to this Policy.  If you do not agree please do not use our Site or our Exchange.  This Policy may be updated, modified or changed from time to time, and without prior written notice, by posting the revised version of this Policy on this Site.  If at some point in the future, there is a change to our Policy, unless we obtain your express consent, such changes will only apply to information collected after we have posted the revised Policy.  We recommend that you periodically review the Policy for changes.  Your continued use of the Site or the Exchange following any such change, including the submission of any personal information, constitutes your agreement that all personal information collected from or about you from this Site or the Exchange after the revised Policy is posted will be subject to the terms of the revised Policy.

Children’s Privacy and Parental Controls
We do not knowingly collect or solicit personal information from or market to anyone under eighteen (18) years of age.  If you are under eighteen (18) years of age, please do not use the Site, our Exchange, open a user account through the Exchange, or send any information about yourself to us, including but not limited to: your name, address, telephone number or email address.  Our goal is to comply with applicable laws and regulations relating to the collection and use of information from children, including the Children’s Online Privacy Protection Act of the United States and other applicable laws or regulations.  Please be aware that there are parental control tools available online that can be used to prevent children from submitting information online without parental permission or from accessing material that is harmful to minors.  If you believe that we might have received information from or about a child or other person protected under such laws, please contact us immediately at or by mail to Cotonomy, Inc, 4847 Hopyard Road Suite 219 Pleasanton CA 94588 and we will take reasonable steps to remove that information from our database.

Information We Collect From You

We may collect two types of information from you:(i) information that you knowingly and voluntarily supply to us (e.g., through a registration process, sign-ups, or other interaction with the Site or the Exchanges); and (ii) information that is derived through automated tracking mechanisms.

Voluntary Information You Provide to Us

You may choose to voluntarily and knowingly supply us with information and/or you may provide information through a registration process, sign in procedure or payment process, used to access protected information on the Site or through use of the Exchange.Some of this information will identify you personally, either alone or in combination with other information available to us.This Privacy Policy refers to such information as “personal information.”This may include your name or associated company name, email address, postal address, credit card information, and home or work telephone number.In addition, you may also through use of the Site or the Exchange voluntarily and knowingly supply us with information that does not identity you personally but refers to a quality or characteristic about you, for example, your gender, your online shopping habits, or your lifestyle.

Information Collected Using Cookies and Other Web Technologies

Like many websites, our Site or Exchange may use “cookies” or other similar tracking technologies to collect information which will help us to improve the quality of our services and to make it easier for you to navigate the Site and use the Exchange.  This information typically includes your IP address, the address of the web page you were visiting when you accessed the Site or the Exchange, the name of your operating system (such as Windows or Macintosh), the name and version of your browser (e.g., Internet Explorer, Firefox), pages navigated during your visit to the Site or using the Exchange, and the date and time of your visit, among other things.  Although most web browsers automatically accept cookies, most computers allow you to change your browser setting to prevent acceptance of cookies.  You may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser.  Please note that if you choose to erase or block your cookies certain features or parts of the Site or the Exchange may not work property. 

User Contributions

You are responsible for any content, including personal information, that you contribute to be published, displayed or transmitted to others on the Site or through the Exchange (“User Content”).  While we take reasonable precautions to keep any personal information we collect secure and to restrict access to such information in our databases please be aware that no security measures are completely secure or impenetrable.  Additionally, we cannot control the actions of other users of the Site or the Exchange with whom you may choose to share your User Content.  Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.  We are not responsible for circumvention of any privacy settings or security measures contained on the Site or in the Exchange. You understand and acknowledge that, even after removal, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Site or the Exchange.  Proper access and use of information provided on the Site and through the Exchange, including User Content, is governed by our terms of use Consumer Agreement or Advertiser Agreement and any other agreement you enter into in connection with your registration as either a member or an advertiser

and known or suspected violations should be reported to us at or by mail to Cotonomy, Inc., 4847 Hopyard Road Suite 219 Pleasanton CA 94588.

How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, in the following ways:

  • to validate the accuracy of information registered members provide;
  • to respond to your queries and requests;
  • to assist you with managing your account and passwords;
  • to process applications submitted by you and communicate with you about transactions you have requested;
  • to undertake, with your consent, any other promotional activities such as providing information about special events;
  • to communicate with you about our products and services and other information related to our business that may be of interest to you;
  • to send you any compensation you have earned;
  • to build our contact database;
  • to market the services of Cotonomy;
  • to collect and provide statistical information to our Advertisers;
  • to sell information you provide through the Exchange to our Advertisers;
  • to provide you with effective customer service and/or technical support; or
  • to improve the design of our Site.

If you are a registered member then you have agreed to the terms of a Member Agreement or the Advertiser Agreement located at Consumer Agreement or Advertiser Agreement, and you have agreed that advertisers will receive personal information and/or de-identified information that you provide through your use of the Exchange. Registered members’ information will be used to help advertisers send advertisements to the kind of audience they want to target.  We may also provide the advertisers with aggregated or de-identifiable information about our users (for example, we may report to them that 200 women under age 30 clicked on their advertisement on a given day).  If we collect personal information from you, you will receive notice when this information might be provided to any third party for any reason other than as set forth in this Policy, and you will have an opportunity to request that we not share such information.  See “Contacting Us; Opt-Out” below.

Additional Disclosure of Your Information

We may disclose personal information that you provide via the Site or the Exchange to the following third parties:

  • Our subsidiaries and affiliates.
  • To third party advertisers who have joined the Exchange in order to obtain information you have voluntarily and knowingly provide though the Exchange.  Such information includes but is not limited to gender, age, zip code, lifestyle information, and online purchasing habits.  Advertisers will not be given Member’s names, personal email addresses, or home addresses (expect zip code).
  • Contractors and service providers we use to support and assist our business.
  • To a buyer in the event of a merger, divestiture, restructuring, reorganization, dissolution or any other form of sale of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Cotonomy about its customers is among the assets transferred.

Additionally, Cotonomy may share your personal information to comply with legal requirements, cooperate with law enforcement, prevent fraud and other crimes, and protect legal rights.  There are circumstances in which we may share the personal information we collect on this Site or through the Exchange without notifying you when we, in good faith, believe disclosure is necessary to comply with the law or regulatory requirement; to comply with a subpoena or court order; to cooperate with law enforcement or other governmental investigations (without necessarily requiring the law enforcement or governmental agency requesting the information to formally serve us with a subpoena); to prevent or investigate a possible crime, such as fraud or identity theft; to enforce a contract; to protect the legal rights, property or safety of Cotonomy, our subsidiaries, affiliates, officers, directors, agents, and employees, licensors, suppliers, partners, successors, agents, and other users or the public in general or to protect your vital interests.  We also reserve the right to report to appropriate law enforcement or governmental agencies any activities that we, in good faith, believe to be unlawful without providing notice to you.

How Long We Retain Your Personal Information
Any personal information we collect will be kept only as long as we need it for the purpose for which it was originally collected (or to which you have subsequently consented) or for other legitimate purposes (such as regulatory compliance), or as permitted by applicable law.  

External Links
For your convenience, we may provide links to websites owned and operated by unrelated third parties.  Such third party sites should have their own privacy policies, which we recommend you review prior to interacting with such site.  This Policy applies only to the personal information collected through this Site and our Exchange and you agree that Cotonomy has no liability with respect to such third party sites or their practices related to collection, use and privacy or information.

Data Security Commitment
We take reasonable precautions to keep any personal information we collect secure.  All personal information is subject to restricted access to prevent unauthorized access, modification or misuse.  To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have industry standard measures in place to safeguard and secure information and data we collect through the Site or the Exchange.  It is important that you understand, however, that no website or database is completely secure or “hacker proof” and we cannot guarantee security of the information you submit to us.  You are responsible for taking personal steps to protect your personal information against unauthorized disclosure or misuse, for example, by protecting your password from unauthorized use or disclosure. 

Contacting Us; Opt Out
At your request and where the law requires us to do so, we will make good faith efforts to confirm what personal information we hold about you, update your information, remove your information, fulfill specific opt-out requests, and/or correct any inaccuracies in such personal information if you contact us at to submit such requests.  We may decline to process a request that is unreasonable, jeopardizes the rights or privacy of others, is impractical or for which access is not otherwise required.

Who to Contact
Please contact us at or write to us at Cotonomy, Inc., 4847 Hopyard Road Suite 219 Pleasanton CA 94588 if you have any comments or questions about this Privacy Policy or to report any violations of the Privacy Policy.  We will endeavor to respond to you within 24 to 48 hours in most cases.

Governing Law
This Policy and our privacy notices are governed under the laws of the State of California without regard to its conflict of law provisions.

California Residents: If you reside in California and have provided personal information to us, you may request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following addresses: email at or write to us at Cotonomy, 4847 Hopyard Road Suite 219 Pleasanton CA 94588.