Privacy is important. Take some time to look this over and contact us if you have

any concerns about our use of your Personal Information in connection with our

services to you.

Coiin, LLC. d/b/a Raiinmaker (the “Company” “we” “us” or “our”), and its affiliates and

subsidiaries, really respects your privacy and we are committed to protecting your

Personal Information.

As an organization that cares about the privacy of your Personal Information, it is our

desire and duty to comply with the various applicable regulations around the world that

govern the collection and processing (using) of your Personal Information.

Protecting the personal rights and privacy of each individual and company that visits or

uses our online “websites” and “mobile applications” (“websites” and “mobile

applications” collectively the “Sites”) is at the center of our concern in our relationship

with you.

Therefore, we recognize the need for appropriate safeguards and management

practices in relation to the collection and use of your Personal Information. We want to

ensure that you understand what information we collect about you and how we use it.

This Privacy Policy sets out the principles the Company follows when we collect and

process your Personal Information through your use of our services or when you

otherwise engage with us though our Sites. It also applies to our suppliers and anyone

who participates in our services.

This Privacy Policy is incorporated into and made part of our Terms of Use. Please read

this Privacy Policy (including our Cookie policy below) and our Terms of Use

( carefully. When you submit Personal Information to us,

you consent to the collection, use and disclosure of your Personal Information as

described in this Privacy Policy.

If you do not agree with any part of this Privacy Policy, Cookie policy, or our

Terms of Use, you must stop using the Sites and our related services and exit the Sites


Our Sites are not intended for children and we do not knowingly collect data relating to


We may amend this Privacy Policy from time to time so please visit this page

occasionally to ensure that you understand any amendments. If we need your consent

to process your Personal Information in a different way, we will seek your permission in


Please use the Definitions provided at the end of this Policy to help you understand the

meaning of some of the terms we use here. If you have any questions regarding this

Policy, contact us at: please write “Questions on your Privacy

Policy” in the subject line of your email.

Who We Are

This Privacy Policy is issued on behalf of the Company as a whole. When we mention

the “Company”, “we”, “us” or “our”, we are referring to the relevant the Company entity

responsible for collecting or processing your data.

Unless specified otherwise in this Privacy Policy, the Company is the controller of your

Personal Information which means that the Company decides why and how your

Personal Information is processed (i.e. used). Unless otherwise stated, the Company

entity you are engaging with will be the controller of your data.

COIIN, LLC. d/b/a Raiinmaker is the legal data controller and responsible for all our


What Personal Information We Collect and How We Collect It

Personal Information” is defined as any personal information that identifies, relates to,

describes, is reasonable capable of being associated with, or could reasonably be

linked, directly or indirectly, with a particular consumer or household from which that

person can be identified. For example, it might include your name, mailing address,

email address, telephone number, credit card number, company, title, biometric

information, website username or website password, and Inferences drawn from any of

the information identified above to create a profile about a consumer reflecting the

consumer’s preferences, characteristics, psychological trends, predispositions,

behavior, attitudes, intelligence, abilities, and aptitudes. It does not include data where

your identity has been removed (de-identified anonymous data).

Some Personal Information is required to provide our services to you. If you do not

provide the Personal Information we ask for, it may delay or prevent us from providing

the services to you.

We collect, store and process your Personal Information by different methods in

connection with your use of our services, such data may include: account data, your

personal profile data, your Personal Information that are provided in the course of the3

use of our services, information that you post for publication on our Sites or through our

services, information relating to transactions, including purchases of services, that you

enter into with us and/or through our website, information that you provide to us for the

purpose of subscribing to our email notifications and/or newsletters, and information

contained in or relating to any communication that you send to us.


When you are using our Sites, which may include when you download content or

contact us via our Sites, here is how we generally collect your data:

We collect most of this Personal Information directly from you – via email, by telephone,

text and/or via our Sites. However, we may also collect information:

• From publicly accessible sources (e.g., property records);

• Directly from a third party (e.g., credit reporting agencies, sanctions screening

providers, or customer due diligence providers);

• From a third party with your consent (e.g., your bank);

• From cookies on our Sites; and

• Via our IT systems, including, for example:

o Door entry systems and reception logs;

o Automated monitoring of our Sites and other technical systems, such as

our computer networks and connections, CCTV and access control

systems, communications systems, email and instant messaging


• You may provide Personal Information by completing online registration forms, by

applying for services via our Sites, or when you create or update any of your marketing

preferences; and we may collect your data automatically via cookies, in line with your

cookie consent, web beacons, server logs and other similar technologies, preferences

and settings in your browser.

• For more information on how we use cookies please see our Cookie policy below.

How We Use Your Personal Information

We collect, process or disclose your Personal Information for our legitimate business

purposes. A legitimate interest is when we have a business or commercial reason to

use your information, so long as this is not overridden by your own rights and interests,

for example:

• To provide our services to Site users or to fulfill our contractual obligations.4

• To any member of our group of companies (this means our subsidiaries, our ultimate

holding company, if any, and all its subsidiaries) insofar as reasonably necessary for the

purposes, and on the legal bases, set out in this Privacy Policy.

• To market our services, promotions, blogs or webinars, reports, our service news or

relevant Privacy Policy updates. Depending on which jurisdiction you are in, we may be

required to give you an option to “opt-in” and we will always provide you with an option

to “opt-out” with each marketing communication;

• As required by law or regulation;

• For our business purposes, such as data analysis, audits, fraud monitoring and


• To develop new products, services and offerings, or to enhance, improve or modify our

products and services; or

• To record your usage of our Sites in accordance with our cookie policy.

• To our insurers and/or professional advisers insofar as reasonably necessary for the

purposes of obtaining or maintaining insurance coverage, managing risks, obtaining

professional advice, or the establishment, exercise or defense of legal claims, whether

in court proceedings or in an administrative or out-of-court procedure.

• We may disclose your Personal Information where such disclosure is necessary for

compliance with a legal obligation to which we are subject, or in order to protect your

vital interests or the vital interests of another natural person.

• On certain pages on our Sites or blogs you may see ‘share’ or ‘social buttons’. These

enable you to share or bookmark pages on our Sites and Apps. These may include

buttons for: Twitter, LinkedIn, Pinterest, Facebook, Instagram or other social media

platforms. In order for us to implement these buttons on our Sites and connect them to

the relevant social networks and external sites, there are scripts that are executed from

domains owned by third parties and outside of our control. You should be aware that

these sites are likely to be collecting information about what you are doing all around

the internet, including on our Sites. So, if you click on any of these buttons, these sites

will be registering that action and may use that information. In some cases these sites

will be registering the fact that you are visiting our Sites and Apps, and the specific

pages you are on, even if you don’t click on the button but are already or automatically

logged into their services, like Google and Facebook. We recommend that you check

the respective policies of each of these sites to see how exactly they use your Personal

Information and to find out how to opt out, or delete, such Personal Information if you

wish to.

Promotional Communications

We may use your Personal Information to send you updates, by email, text message,

telephone or post, about our products and/or services, including exclusive offers,5

promotions or new products and/or services. We have a legitimate interest in

processing your Personal Information for promotional purposes (see above “How we

use your Personal Information” and the 2nd paragraph below). This means we do not

usually need your consent to send you promotional communications. However, where

consent is needed, we will ask for this consent separately and clearly. We will always

treat your Personal Information with the utmost respect and never sell or share it with

other 3rd party organizations (outside the Company’s group) for marketing purposes

(except such sharing of Personal Information as maybe set forth in a Promotion’s official

rules as noted below).

We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that

may require registration. By participating in a Promotion, you are agreeing to the official

rules that govern that Promotion, which may contain specific requirements of you,

including, except where prohibited by law, allowing the sponsor(s) of the Promotion to

use your name, voice, likeness or other indicia of persona in advertising or marketing

associated with the Promotion. If you choose to enter a Promotion, your Personal

Information may be disclosed to third parties or the public in connection with the

administration of such Promotion, including, without limitation, in connection with winner

selection, prize fulfillment, and as required by law or permitted by the Promotion’s

official rules, such as on a winner’s list.

Opting Out of Communications

If you have subscribed to or are otherwise receiving promotional communications,

news, alerts, blog posts, or similar information from us by email or texts, and no longer

want to receive such information in the future, you may opt-out of receiving these emails

or texts by clicking the “unsubscribe” link at the bottom of those emails you receive or

typing “STOP” in texts. Please allow ample time for us to process your request. If you

are having difficulty unsubscribing, please contact us at and

clearly write “Opt-Out -Unsubscribe” in the subject line of your email and include the details of

the communications you desire to stop receiving.

We may ask you to confirm or update your marketing preferences if you instruct us to

provide further products and/or services in the future, or if there are changes in the law,

regulation, or the structure of our business.

Please note that even if you opt-out of receiving emails, you may still receive

communications related to your interaction with us (such as confirmation of a

registration or form submission) or otherwise as required by law. Also note that we may

need to keep Personal Information we have collected about you to respect your

decision to opt-out, for record-keeping, research and other purposes.

What Is the Legal Basis for Processing Your Personal Information6

Under data protection law, we can only use your Personal Information if we have a

proper reason for doing so. We rely on the following main grounds to process Personal

Information of Site and App users, suppliers or other third parties:

Necessary for entering into, or performing, a contract – to perform obligations that

we undertake in providing a service to you, or to take steps at your request to enter into

a contract with us;

Necessary for compliance with a legal obligation – we are subject to certain legal

requirements which may require us to process your Personal Information. We may also

be obliged by law to disclose your Personal Information to a regulatory body or law

enforcement agency;

Necessary for the purposes of Legitimate Interests – we, or a third party, will

process your Personal Information for the purposes of our (or a third party's) Legitimate

Interests, provided we have established that those interests are not overridden by your

rights and freedoms, including your right to have your Personal Information protected.

Our Legitimate Interests include responding to requests and enquiries from you or a

third party, optimizing our Sites and Apps and customer experience, informing you

about our products and services and ensuring that our operations are conducted in an

appropriate and efficient manner;

Consent – in some circumstances, we may ask for your consent to process your

Personal Information;

Necessary to protect the vital interests of you the data subject or of another natural



We will only use your Personal Information for the purposes for which we collected it,

unless we reasonably consider that we need to use it for another reason and that

reason is compatible with the original purpose. If you wish to get an explanation as to

how the processing for the new purpose is compatible with the original purpose, please

contact us at: and clearly write “New Personal Information

Processing Purpose Question” in the subject line of your email.

If we need to use your Personal Information for an unrelated purpose, we will notify you

and we will explain the legal basis which allows us to do so or seek your consent,

providing you with a clear, conspicuous and readily available mechanism for you to

exercise your choice.

Please note that we may process your Personal Information without your knowledge or

consent where this is required or permitted by law.7

How We Share Your Personal Information

We will not sell or rent to anyone the Personal Information provided to us or obtained by


In certain circumstances we will share your Personal Information with other parties. We

share your data with other entities within the Company acting as joint controllers or

processors. We do this to provide sales and marketing, IT, system administration

services, product development and undertake internal reporting. We will also share your

Personal Information across the Company entities to improve our customer service and

to make our services more valuable to you.

We also share your Personal Information with the following third parties:

• Our affiliates, including companies within the Raiinmaker group;

• Service providers we use to help deliver our products and/or services to you,

such as payment service providers, warehouses and delivery companies;

• Other third parties we use to help us run our business, such as marketing

agencies or website and App hosts, cloud services or other digital platform

providers, including, for example: Google Store, Apple App Store, etc.;

• Third parties approved by you, including social media sites you choose to link

your account to or third-party payment providers;

• Credit reporting agencies;

• Our insurers and brokers;

• Our bank(s);

• Campaign creators under promotional “Official Rules Agreements”


We only allow our service providers to handle your Personal Information if we are

satisfied that they take appropriate measures to protect your Personal Information. We

also impose contractual obligations on service providers to ensure they can only use

your Personal Information to provide services to us and to you for specified purposes

and in accordance with our instructions. We may also share Personal Information with

external auditors, e.g. in relation to accreditations and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and

regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as

potential buyers of some or all of our business or during a re-structuring. We will

typically anonymize information, but this may not always be possible. The recipient of

the information will be bound by confidentiality obligations.8

We also collect, use and share de-identified aggregated data such as statistical or

demographic data for our legitimate business purposes. Such aggregated data is not

Personal Information as this data does not directly or indirectly reveal your identity.

In the preceding 12 months, we may have disclosed for a legitimate business purpose

to one or more third-parties, some of the following categories of Personal Information

that identifies, relates to, describes, is capable of being associated with, or could

reasonably be linked, directly or indirectly, with a particular consumer or household:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier,

online identifier, Internet Protocol address, email address, account name,

social security number, driver’s license number, passport number, or other

similar identifiers);

• Information that identifies, relates to, describes, or is capable of being

associated with, a particular individual, including, but not limited to, his or her

name, signature, social security number, physical characteristics or

description, address, telephone number, passport number, driver’s license or

state identification card number, insurance policy number, education,

employment, employment history, bank account number, credit card number,

debit card number, or any other financial information, medical information, or

health insurance information;

• Characteristics of protected classifications under California or federal law;

• Commercial information (e.g., records of personal property, products or

services purchased, obtained, or considered, or other purchasing or

consuming histories or tendencies);

• Biometric information;

• Internet or other electronic network activity information (e.g., browsing history,

search history, and information regarding a consumer’s interaction with an

Internet Web site, application, or advertisement);

• Geolocation data;

• Audio, electronic, visual, thermal, olfactory, or similar information;

• Professional or employment-related information;

• Education information, defined as information that is not publicly available

personally identifiable information as defined in the Family Educational Rights

and Privacy Act (FERPA); and

• Inferences drawn from any of the information identified above to create a

profile about a consumer reflecting the consumer’s preferences,

characteristics, psychological trends, predispositions, behavior, attitudes,

intelligence, abilities, and aptitudes.

Where Your Personal Information is Held. Information may be held at our offices and

those of our group companies, third-party agencies, service providers, representatives

and agents as described above (see above: “How We Share Your Personal


Some of these third-parties may be based outside the European Economic Area. For

more information, including on how we safeguard your personal information when this

occurs, see the Section below: “Transfers Out of the EEA”.

How Long Your Personal Information Will Be Kept. We will keep your personal

information while you have an account with us or while we are providing products and/or

services to you. Thereafter, we will keep your personal information for as long as is


• To respond to any questions, complaints or claims made by you or on your


• To show that we treated you fairly; or

• To keep records required by law.

We will not retain your Personal Information for longer than reasonably necessary for

the purposes set out in this Privacy Policy. We may retain and use your personal

information as necessary to comply with our legal obligations, resolve disputes, and

enforce our agreements and rights, or if it is not technically reasonably feasible to

remove it. Consistent with these requirements, we will try to delete your personal

information as soon as reasonably practicable upon request. Different retention periods

may apply for different types of Personal Information. If you have a question about our

retention policy for your Personal Information, please contact us at: and clearly write “Personal Information Data Retention

Question” in the subject line of your email.

International Transfers of Data

To deliver services or products to you, it is sometimes necessary for us to share your

personal information outside the European Economic Area (EEA), e.g.:

• With our offices outside the EEA;

• With your and our service providers located outside the EEA;

• If you are based outside the EEA; or

• Where there is an international element to the services or products we are

providing to you.

These transfers are subject to special rules under European and UK data protection

law. We may transfer the Personal Information we collect about you to countries

outside of the country in which the information originally was collected. Those countries

may not have the same data protection laws as the country in which you initially

provided the information. When we transfer your information to other countries, we will

protect that information as described in this Privacy Policy.10


If you are located in the European Economic Area (EEA) this may involve transferring

your Personal Information outside of the EEA. Whenever we transfer your Personal

Information out of the EEA, we ensure a similar degree of protection is afforded to it by

ensuring at least one of the following safeguards is implemented.


• We will only transfer your Personal Information to countries that have been deemed to

provide an adequate level of protection for Personal Information by the European

Commission. For further details, see European Commission: Adequacy of the protection

of Personal Information in non-EU countries.

• Where we use certain service providers, we may use specific contracts or standard data

protection contract clauses approved by the European Commission which give Personal

Information the same protection it has in Europe. For further details, see European

Commission: Model contracts for the transfer of Personal Information to third countries.

Data Security

Where Personal Information is requested, the Company uses industry standard

physical, technical, and administrative controls to protect your Personal Information by:

• Not collecting or retaining excessive amounts of data;

• Protecting Personal Information from loss, misuse, unauthorized access and disclosure.

Any employees, agents, contractors or third parties who are so authorized act on our

instructions are subject to a duty of confidentiality;

• Keeping Personal Information up to date;

• Storing and destroying Personal Information securely;

• Ensuring that appropriate administrative, technical and physical safeguards are in place

to protect Personal Information. These measures include measures to deal with any

suspected data breach; and

• Regularly reviewing our information collection, storage and processing practices,

including physical security measures.

While we operate to industry standards, we are also aware that the transmission of

information via the internet is not completely secure. You should keep in mind that the

Sites are run on third-party software, hardware, and networks, any component of which

may, from time to time, require maintenance or experience problems or breaches of

security beyond our control. Thus, we cannot guarantee the security of your data

transmitted to our Sites and any transmission is at your own risk.11

While we take steps to protect your Personal Information and keep it secure, you also

play a role in protecting your information. You must maintain the security of your online

transactions by not sharing your passwords and account information with any

unauthorized parties. Where we have given you (or where you have chosen) a

password which enables you to access any of our online services or electronic

resources, you are responsible for keeping this password confidential. We advise you

not to share your password with anyone.

You should note that this website may include links to third-party sites and Apps, plug-

ins and other applications. Clicking on those links or enabling those connections may

allow third parties to collect or share data about you. We do not control these third-party

sites and apps and are not responsible for their content or privacy statements. When

you leave our Sites, we encourage you to read the privacy notice of every website and

app you visit.


Overview: Like most websites & Apps, we may employ “cookies” or similar

technologies. This Cookies Policy tells you about the use of Cookies and similar

technologies on the Company’s Sites.

When you first access the Sites from certain jurisdictions, you will receive a message

advising you that cookies and similar technologies are in use. By continuing to browse

the Sites, you signify that you understand and agree to the use of these technologies,

as described in this Cookies Policy.

You do not have to accept cookies and consent can be withdrawn at any time (see How

to Control Cookies below). You can change your browser settings to refuse or restrict

cookies, and you may delete them after they have been placed on your device at any

time. If you do not accept or delete our cookies, some areas of our Sites that you

access may take more time to work or may not function properly.

What are Cookies? Cookies are small files containing a string of characters which we

may store on your computer or mobile device when you visit the Sites. When you visit

the Sites again, the cookies allow us to recognize your browser. Cookies may store your

preferences and other information but cannot read data off your hard disk or read

cookie files created by other sites (Cookies are also delicious snacks can be great for

dipping into coffee or tea).

We may use cookies to deliver content tailored to your interests. We may use

information collected with cookies to statistically analyze usage of our Sites and to

improve and customize our content and other offerings.12

Types of cookies we use on our Sites include:

Session cookies: These temporary cookies expire and are automatically erased

whenever you close your browser window. We may use session cookies to grant

our users access to content and to enable actions such as remembering form or

payment information as you are in the process of entering it.

Persistent cookies: These cookies usually have an expiration date in the distant

future and remain in your browser until they expire, or you manually delete them.

We may use persistent cookies to better understand usage patterns so we can

improve our Sites for our users. For example, we may use a persistent cookie to

associate you with your account or to remember your choices on a Site.

Third-party cookies: We may permit third-party service providers to place cookies

through our Sites to provide us with better insights into the use of the Sites or user

demographics or to provide relevant services to you. These third parties may collect

information about a user’s online activities over time and across different websites when

he or she uses our Sites. For example, we may use a third-party tool to analyze usage

patterns of the Sites. Such a tool may generate a cookie to capture information about

your use of a Site which the third-party provider uses to compile reports on website

activity for us and to provide other related services. The third-party provider may use a

portion of your IP address to identify its cookie. We do not control the use of third-party

cookies or the resulting information, and we are not responsible for any actions or

policies of such third parties.

We, along with third-party vendors such as Google use first-party cookies (such as the

Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or

other third-party identifiers together to compile data regarding user interactions with ad

impressions and other ad service functions as they relate to our Sites and Apps.

How to Control Cookies

You do not have to accept cookies and consent can be withdrawn at any time, although

you may not be able to use certain features on the Sites. You can do this by activating

the settings on your browser that allows you to refuse all or some cookies.

Please follow the links below to helpful information for the most popular browsers:

Microsoft Internet Explorer:


Google Chrome:


Mozilla Firefox:


Apple Safari:


In addition, you can exercise advertising cookie choices by visiting:


•; or


Web Beacons

As well as cookies, we use other technologies to recognize and track visitors to our

Sites. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic

image (typically a one-pixel tag) that is delivered through a web browser or HTML e-

mail, typically in conjunction with a cookie.

Web beacons allows us, for example, to monitor how users move from one page within

our Sites to another, to track access to our communications, to understand whether

users have come to our Sites from an online advertisement displayed on a third-party

website, to measure how ads have been viewed, and to improve Site performance.

To learn more about cookies and web beacons, visit

“Do Not Track” Browser Settings

We do not use technology that recognizes a “do-not-track” signal from your web

browser, because we do not track users other than for aggregate statistical purposes.

Data Retention

Where we collect your Personal Information, the length of time for which we retain it

depends on the type of data, the purpose for which we use that data and our

accounting, regulatory and legal data retention obligations. We do not retain Personal

Information in an identifiable format for longer than is necessary.

To determine the appropriate retention period for Personal Information, we consider the

amount, nature, and sensitivity of the Personal Information, the potential risk of harm

from unauthorized use or disclosure of your Personal Information, the purposes for

which we process your Personal Information and whether we can achieve those

purposes through other means, and the applicable legal requirements.14

We will retain your Personal Information on our systems unless we have not had any

meaningful contact with you (or, where appropriate, the company you are working for or

with) for two or more years (or for such longer period as we believe in good faith that the

law, statute or relevant regulators require us to preserve your data). After this period, it

is likely your data will no longer be relevant for the purposes for which it was collected

and we will delete or destroy it.

In some circumstances we may anonymize your Personal Information (so that it can no

longer be associated with you) for research or statistical purposes in which case we

may use this information indefinitely without further notice to you.

Children’s Privacy

As noted above, our Sites and all related services are not directed to or intended for use

by minors. Consistent with the requirements of the US Children’s Online Privacy

Protection Act, if we learn that we have received information directly from a child under

age 13 without his or her parent or legal guardian’s verified consent, we will use that

information only to respond directly to that child (or his or her parent or legal guardian)

to inform the child that he or she cannot use our Sites and any related services.

Subsequently, we will make commercially reasonable efforts to delete such information.

Your Legal Rights

Under certain circumstances, by you have the right to:

Request access to your Personal Information (commonly known as a “data subject

access request”). This enables you to receive a copy of the personal information we

hold about you and to check that we are lawfully processing it;

Request correction of the Personal Information that we hold about you. This enables

you to have any incomplete or inaccurate information we hold about you corrected;

Request erasure of your Personal Information. This enables you to ask us to delete

or remove personal information where there is no good reason for us continuing to

process it. You also have the right to ask us to delete or remove your Personal

Information where you have exercised your right to object to processing. Note, however,

that we may not always be able to comply with your request of erasure for specific legal

reasons which we will notify to you, if applicable, at the time of your request;

Object to processing of your Personal Information where we are relying on a

Legitimate Interest (or those of a third-party) and there is something about your

particular situation which makes you want to object to processing on this ground. You

also have the right to object where we are processing your Personal Information for

direct marketing purposes;15

Request the restriction of processing of your Personal Information. This enables

you to ask us to suspend the processing of Personal Information about you, for example

if you want us to establish its accuracy or the reason for processing it; and/or

Request the transfer of your Personal Information to another party.

If you want to review, verify, correct or request erasure of your personal information,

object to the processing of your Personal Information, or request that we transfer a copy

of your Personal Information to another party, please contact us by email at: and clearly write “Personal Information Request” in the subject

line of your email.


You will not have to pay a fee to access your Personal Information (or to exercise any of

the other rights). However, we may charge a reasonable fee if your request for access

is clearly unfounded or excessive. Alternatively, we may refuse to comply with the

request in such circumstances.


We may need to request specific information from you to help us confirm your identity

and ensure your right to access the information (or to exercise any of your other rights).

This is another appropriate security measure to ensure that Personal Information is not

disclosed to any person who has no right to receive it.


In the limited circumstances where you may have provided your consent to the

collection, processing and transfer of your personal information for a specific purpose,

you have the right to withdraw your consent for that specific processing at any time. To

withdraw your consent, please send us an email at: – and

write “Personal Information Consent Withdrawal” clearly written on the subject line of

your email. Once we have received notification that you have withdrawn your consent,

we will no longer process your information for the purpose or purposes you originally

agreed to without undue delay, unless we have another legitimate legal basis for doing



We try to respond to all legitimate requests within 45 days of our receipt of your written

request. Occasionally it may take us longer if your request is incomplete and we need to

write to you for more information or is particularly complex or you have made several

requests. In these cases, we will notify you and keep you updated.



Additional disclosures related to collection, use, and disclosure of Personal


If you are a California consumer, the California Consumer Privacy Act (“CCPA”)

requires companies, as applicable, to disclose the following information with respect to

our collection, use, and disclosure of Personal Information.

Categories of Personal Information Collected: In the preceding 12 months, we may

have collected the following categories of Personal Information: identifiers,

characteristics of Protected Classifications under California or U.S. Law, professional

and employment-related information, educational information, commercial information,

internet and electronic network activity, inferences drawn about your preferences, and

other categories of Personal Information that related to or is reasonably capable of

being associated with you. For examples of precise data points we collect, please see

What Personal Information We Collect and How We Collect It” Section above.

Business or Commercial purpose for collecting and using data: We collect

Personal Information for business purposes described in the “How We Use Your

Personal Information” Section above.

Categories of Third Parties With Whom We Share Personal Information: We may

share your personal information with the third parties as described in the “How We

Share your Personal Information” Section above.

Sale of Personal Information (as defined by the CCPA): We do not sell the Personal

Information we collect.

Your Consumer Rights

• California consumers have the right to request access to their Personal Information,

additional details about our information practices, and deletion of their Personal

Information (subject to certain exceptions). California consumers also have the right to

opt out of sales of Personal Information, if applicable. California consumers may make a

rights request by calling us at: 1-800-219-3307 or by contacting us by email at: and clearly write “California Consumer Personal Information

Request” in the subject line of your email.

Once we receive your request, we may verify it by requesting information sufficient to

confirm your identity. If you would like to use an authorized agent registered with the

California Secretary of State to exercise your rights, we may request evidence that you

have provided such agent with power of attorney or that the agent otherwise has valid

written authority to submit requests on your behalf. We will not discriminate against you

if you choose to exercise your rights under the CCPA.17


In the EU, if you consider that our processing of your personal information infringes data

protection laws, you have a legal right to lodge a complaint with a supervisory authority

responsible for data protection. You may do so in the EU member state of your principal

residence, your place of work or the place of the alleged infringement.

Please see “How to make a Complaint” below.

How to Make a Complaint

Data privacy laws are constantly evolving, and we endeavor to maintain best practices.

However, we recognize that we may not always get it right and if you are not satisfied in

the way we handle your Personal Information, or you wish to discuss our processes

then we would like to hear from you.


If you believe that there is something which we have not done correctly with your

Personal Information then we would appreciate the chance to deal with your concerns

before you approach a Supervisory Authority, so please contact us in the first instance

at: and please clearly write “EU Data Complaint” in the subject

line of your email.


By choosing to visit our Site or provide information to us, you agree that any dispute

over privacy or the terms contained in this Privacy Policy will be governed by the laws of

the State of Wyoming and the United States of America without reference to conflict of

laws principles. You also agree to abide by any limitation on damages contained in our

Terms of Use (, or other agreements that we have with


Definitions of Terms used in this Policy

Consent means your agreement which must be freely given, specific, informed and be

an unambiguous indication of you, the Data Subject’s wishes, by which you, by a

statement or by a clear positive action, signifies agreement to the Processing of

Personal Information relating to you.18

Data Controller means the person or organization that determines when, why and how

to process your Personal Information. It is responsible for establishing practices and

policies in line with the GDPR. For example, we are the Data Controller of all Personal

Information relating to our Company personnel and Personal Information used in our

business for our own commercial purposes.

Data Subject means a living, identified or identifiable individual about whom we hold

Personal Information. Data Subjects may be nationals or residents of any country and

may have various legal rights regarding their Personal Information.

EEA means the 27 countries in the EU, and Iceland, Liechtenstein and Norway.

Explicit Consent means consent which requires a very clear and specific statement

(that is, not just action).

General Data Protection Regulation (GDPR) means the European Union General

Data Protection Regulation ((EU) 2016/679). Applicable Personal Information is subject

to the legal safeguards specified in the GDPR.

Legitimate Interest means the interest of our business in conducting and managing our

business to enable us to give you the best service/product and the best and most

secure experience. We make sure we consider and balance any potential impact on you

(both positive and negative) and your rights before we process your Personal

Information for our legitimate interests. We do not use your Personal Information for

activities where our interests are overridden by the impact on you (unless we have your

consent or are otherwise required or permitted to by law).

Personal Information means any information identifying a Data Subject or information

relating to a Data Subject that we can identify (directly or indirectly) from that data alone

or in combination with other identifiers we possess or can reasonably access. Personal

Information includes Special Category (Sensitive) Personal Information and

pseudonymized Personal Information but excludes anonymous data or data that has

had the identity of an individual permanently removed. Personal Information can be

factual (for example, a name, email address, location or date of birth) or an opinion

about that person’s actions or behavior.

Privacy Notices or Privacy Policy Notices means separate notices setting out

information that may be provided to Data Subjects (such as you) when the Company

collects information about them. These notices may take the form of general privacy

statements applicable to a specific group of individuals (for example, website privacy

policy notices) or they may be stand-alone, one-time privacy statements covering

Processing related to a specific purpose.19

Processing or Process means any activity that involves the use of your Personal

Information. It includes obtaining, recording or holding the data, or carrying out any

operation or set of operations on the data including organizing, amending, retrieving,

using, disclosing, erasing or destroying it. Processing also includes transmitting or

transferring Personal Information to third parties.

Special Category or Sensitive Personal Information: information revealing racial or

ethnic origin, political opinions, religious or similar beliefs, trade union membership,

physical or mental health conditions, sexual life, sexual orientation, biometric or genetic

data, and Personal Information relating to criminal offences and convictions.

Changes to this Privacy Policy

We may occasionally amend this Privacy Policy to reflect our activities and user

feedback, and we reserve the right to make changes to this Privacy Policy at any time.

The provisions contained in this Privacy Policy supersede all previous notices or

policies regarding our privacy practices with respect to the Sites.

Please check the “Last Updated” legend at the bottom of this Privacy Policy to see

when this Policy was last revised.

We encourage you to check frequently to see the current Privacy Policy to be informed

of how we are committed to protecting your information and providing you with improved

content on our Sites in order to enhance your experience.


We welcome your questions and comments about this Privacy Policy or how we

process your Personal Information. Please contact us using the information below, and

we will respond to you as soon as reasonably possible.

Contact Details - Our full details are:

Name of legal entity: Coiin, LLC.

Address: 30 N. Gould St., Sheridan, Wyoming 82801 USA

ATTN: Privacy Department

Email address:

Toll Free Number: 1-800- 219-330720

Thanks for taking the time to review our Privacy Policy!

Last Updated: January 13, 2022