February 1, 2016
Cola operates under the following Privacy Principles:
- The most fundamental privacy principle we follow is that anything you post to Cola is private to you and the people you’re messaging. That is, viewing the messages and files shared within a conversation requires being a member of that conversation.
- Cola is the custodian of data on behalf of the users of Cola. We don’t own an individual’s communication data. Individuals and members of conversations own their data.
- At Cola we believe that transparency is critical. We make our product easy to use, with settings and options that are easy to find and understand. This is good for privacy, good for the product, and good for Cola users.
- At Cola, privacy goes hand in hand with security and confidentiality. Each is as important as the other and if one is missing, Cola’s relationship with its users is compromised. We take security and confidentiality very seriously.
This policy describes how Cola treats your information, not how other companies, organizations and third parties treat your information. If you are using Cola in a workplace or on a device issued to you by your employer or organization, that company, organization, or a third party supplying Cola Bubbles likely has its own policies regarding storage, access, modification, deletion, and retention of communications and content which may apply to your use of Cola. Content that would otherwise be considered private to you or to a limited group of people may, in some cases, be accessible by others. Please check with your employer, organization, or administrator about the policies it has in place regarding your communications and related content on Cola. More on this below.
In this policy we talk about Cola users and how Cola protects their privacy.
- Information we collect and receive
We collect different kinds of information. Some of it is personally identifiable and some is non-identifying or aggregated. Here are the types of information we collect or receive:
- Conversation information. When you installed Cola, we collected your phone number and user name.
- Account and profile information. The only information we require to create your Cola account is a phone number. Optional information you can enter into your profile includes information such as your first and last name. Any information you add to your profile is visible to other people in your conversation.
- Log data. When you use Cola, our servers automatically record information, including information that your mobile app sends when you’re using it. This log data may include your Internet Protocol address, the date and time of your request, information about your mobile device configuration, and language preferences, and cookie data. Log data does not contain message content and is not routinely deleted.
- Device information. In addition to log data, we may also collect information about the devices on which you’re using Cola, including what type of device it is, what operating system you’re using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you’re using and its settings.
- Geo-location information. Precise GPS from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your device may be used to determine approximate location.
- Cola usage information. This is information about which users, conversations, people, features, content, and links you interact with within Cola and what integrations with related services you use.
- Third-party Cola Bubbles. If you use a third party Cola Bubble, we will connect its services to ours as required.
- Depending on settings and selections, users may be able to add third party Cola Bubbles to a conversation.
- If you add a third party Cola Bubble to a conversation, the third party provider of the Bubble may share certain information about your account with Cola. Cola is not responsible for how creators of third party Cola Bubbles may use and collect data through third party Cola Bubbles.
- Communication content that you send and receive within Cola. This includes:
- The message content itself. This content can include messages, pictures, and video among other types of files.
- When messages or files were sent and by whom, when or if they were seen by you, and where you received them (in a group conversation or 1:1 conversation).
- Information from partners or other third party Cola Bubble providers. Cola may receive information from partners or others that we could use to make our own information better or more useful. This might be aggregate level information about which IP addresses go with which zip codes or it might be more specific information.
- How we use your information
We use your information for the following:
- Providing the Cola service. We use information you provide to authenticate you and deliver message content to you and from you.
- Understanding and improving our products. To make the product better we have to understand how users are using it. We have a fair bit of data about usage and we intend to use it many different ways to improve our products, including research. This policy is not intended to place any limits on what we do with usage data that is aggregated or de-identified so it is no longer tied to a Cola user.
- Investigating and preventing bad stuff from happening. We work hard to keep Cola secure and to prevent abuse and fraud.
- Communicating with you
- Solving your problems and responding to your requests. If you contact us with a problem or question, we will use your information to respond to that request and address your problems or concerns.
- In-product communications. We may use the information you provide to contact you through Cola using in-product messaging tools. For example, if, after, a few weeks of using Cola we notice that your notification setting is set to notify you of all messages, we may send you a message that suggests you change this in case you are getting too many notifications. We may also send you messages about new Cola Bubbles or third-party Cola Bubbles that may enhance your experience.
- Cola and text messages. We may send you service and administrative Cola and text messages, such as when we notice that you are nearing a message or other limit. We may also contact you to inform you about changes in our services, our service offerings and important service related notices, such as changes to this policy or security and fraud notices. These messages are considered part of the service and you may not opt-out of them. In addition, we sometimes send texts or Cola messages to users about new product features or other news about Cola.
- Message Deletion
Cola retains messages and message data until the conversation containing the data is deleted by all participant apps using Cola.
- Sharing and Disclosure
There are times when communications and related content and other user information may be shared by Cola. This section discusses only how Cola may share user information. Cola may share information:
- With consent, to comply with legal process, or to protect Cola and our users. When we have your consent or if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Cola; or to detect, prevent, or otherwise address fraud, security or technical issues. If we receive a law enforcement or other third party request for information we will provide prior notice to the subject of the request where we are legally permitted to do so.
- Third party Cola Bubbles. If you use a third-party Cola Bubbles, Cola may share information about you or other members of a conversation with the provider of the Cola Bubble. Cola is not responsible for how the provider of the Cola Bubble may collect and use your data.
- We may also share aggregated or de-identified information with our partners or others for business or research purposes. This policy is not intended to prohibit the disclosure and use of aggregated or de-identified data.
Cola takes reasonable steps to protect information you provide to us as part of your use of the Cola service from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store and the current state of technology. We encrypt the transmission of your information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. However, no electronic transmission or digital storage mechanism is ever fully secure or error free.
- Children’s information
Cola is not directed to children under 13. No one under 13 is allowed to create an account or use the Services. By using the Services, you state that you can form a binding contract with Cola — meaning that if you’re between 13 and 17, your parent or legal guardian has reviewed and agreed to these Terms.
We may change this policy from time to time, and if we do we’ll post any changes on this page. If you continue to use Cola after those changes are in effect, you agree to the revised policy. If the changes are material, we may provide more prominent notice or seek your consent to the new policy.
- Contacting Cola
795 Folsom Street, First Floor
San Francisco, CA 94107