California Consumer Privacy Act Privacy Notice

COTA, Inc. (“COTA”) is committed to maintaining the privacy and security of your personal information in compliance with all applicable laws and our policy.


This Notice of Collection Of Personal Information and Privacy Policy (“CCPA Privacy Notice”) applies to the collection of personal information from California residents through or on our website (www.cotahealthcare.com) and dependent pages (the “Site”) on and after January 1, 2020. This CCPA Privacy Notice supplements our “Privacy Policy” to provide California residents with information and rights required by the California Consumer Privacy Act (CCPA).


This CCPA Privacy Notice describes the types and categories of personal information we collect, the business purposes for which we collect, use and share your personal information, with whom we share it, and your rights in personal information under the CCPA.


For purposes of this CCPA Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CCPA.


By accessing our website or social media pages, including submitting personal information to us, or requesting information concerning our services, you consent to the collection, use, sharing and disclosure of personal information as set forth in this CCPA Privacy Notice, as it may be updated from time to time.


What categories of personal information do we collect about you?
We may collect personal information through or on the Site in various ways including:


      • when you voluntarily provide us with information (e.g., through your communications with us by email or telephone or through our subscribe features, or social media pages);

      • when you communicate with us concerning requests for information regarding our services; and

      • through automated means when you use our Site including by use of “cookies” and other similar tracking technologies.

    We collect the following categories of personal information:


        • Identifiers: This information may include your name and contact details (including mailing addresses, telephone numbers, email addresses, IP address, browser type/identifier, device advertising IDs, and other identifying information you provide to us). For example, we may collect your name and email address when you join our mailing list to receive information on our services.

        • Customer Information under California Civil Code §1798.80(e): This information comprises any information that identifies, relates to, describes or is reasonably capable of being associated with you in our records. Examples include records of services ordered by you. Some personal information in this category may overlap with other categories.

        • Commercial Information: This category includes information concerning the services you purchased.

        • Internet and other electronic history: This category comprises electronic information concerning your use of the Site. This information may include information we automatically collect as you browse the Site, including your IP address, device type or client/user identifier, browser type/identifier, operating system, pages visited and other similar information. We may use services provided by third parties using third party cookies, tracking technology or session replay software to provide us with information concerning your activity on our Site. We use information from cookies and tracking technologies (e.g., pixels, web beacons, tags) in order to improve and customize your browsing experience, for analytics and metrics about your visits to our Site (e.g., the information concerning the length of your visit to our Site, where your visit originated from) and for marketing our products to you. Other cookies are necessary for the Site to function properly or enhance the Site’s performance and functionality. By using our Site, you consent to the use of all first- and third-party cookies and tracking technologies. If you do not want cookies placed in your browser, you may be able to turn that feature off or permit certain types of cookies by changing the settings on your browser. Please consult your Internet browser’s documentation for information on how to do this.

        • Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes: We may accumulate the information you provide to develop a consumer profile concerning your behavior and interests, including for our marketing and advertising purposes, and to improve our services.

      In the past twelve (12) months, depending on the individual circumstances, we have collected the following categories of personal information: Identifiers, Customer Information under section 1798.80(e) of the California Civil Code, Commercial Information, Internet History, Geolocation Data and Personal Profile.


      Our Business Reasons For Collecting And Using Your Personal Information
      Depending on the individual circumstances, we collect and use personal information for the legitimate business purposes of COTA. These purposes include to provide you with information concerning our services, to fulfill the purpose for which you provided us with your personal information, to communicate with you, to market our services to you, to improve the functionality and effectiveness of our Site, to protect the security of our Site, to protect against fraud, and to comply with applicable law, rules or regulations.


      Who we share your personal information with
      We do not sell your personal information to third-parties.


      In some instances, we may retain other companies and individuals to perform functions on our behalf, including, but not limited to, web hosting platforms, web analytics, and customer service providers. Such third parties may be provided with access to your personal information to perform the functions for which they have been retained. COTA requires its service providers who provide services on our behalf to maintain the privacy and security of your personal information.


      We may share your personal information with third party advertisers for marketing purposes. We may share your email address with third parties who provide marketing services on our behalf to compile lookalike audiences for targeted advertising. The use of your email for this purpose will not result in you being sent advertisements by the third party.


      We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.


      In the past twelve (12) months, depending on the individual circumstances, we have shared the following categories of personal information: Identifiers, Customer Information under section 1798.80(e) of the California Civil Code, Commercial Information, Internet History, Geolocation Data and Personal Profile with the following categories of third parties: service providers and third-party businesses.


      Your rights regarding your personal information
      Under the California Consumer Privacy Act, you have the following rights in personal information held by us:


          • You have the right to request that we disclose the personal information we collect, use, disclose and share. You may request (i) the categories of personal information that we have collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting or sharing your personal information; (iv) the categories of third parties with whom we share your personal information; and (v) the specific pieces of personal information that we have collected about you.

          • You have the right to receive your personal information in a portable format that allows you to transmit the information to another entity.

          • You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to complete the transaction for which the personal information was collected, perform on a contract with us, or to comply with a legal obligation.

          • You have the right not to receive discriminatory treatment for the exercise of any of these rights. We will not discriminate against you or refuse to provide you services because you have exercised your rights.

        You may submit verifiable requests concerning any of your rights by contacting us by telephone at (866) 648-3833 or by e-mail to info@cotahealthcare.com. We will use reasonable methods for verifying that the person making a request to know, data portability or a request to delete is the individual about whom we have collected personal information. This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you will be required to submit the request to delete, and then separately confirm that you want your personal information deleted. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.


        We will (i) confirm receipt of requests to know, data portability or to delete within 10 business days of the request; and (ii) generally respond to requests to know, data portability or to delete within 45 calendar days of the request. If we need additional time to respond to your request beyond the 45 calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional 45 calendar days to respond to your request.


        Reasonable Safeguards To Protect Your Personal Information
        We are committed to maintaining the security of your personal information in compliance with all applicable laws and our policy. We take commercially reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.


        Access By Persons With Disabilities
        Persons with disabilities who need assistance accessing this CCPA Privacy Notice may contact us as provided for above, and depending on your individual needs, the Company will grant reasonable requests to furnish this policy in an alternative format.


        Our Site is not intended for use by children under 13 years of age. No one under age 13 may provide any information to us through the Site. We do not knowingly collect or use personal information from children under 13. If you are under 13, do not access, use or provide any information on the Site or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us. We do not sell any personal information, including the personal information of minors under 16 years of age.


        California Shine the Light Law/Online Privacy Protection Act
        California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided below.


        We do not presently respond to “Do Not Track” requests. We do not control and are not responsible for third party tracking technologies that may be used on our Site. Such third parties may serve you content based on tracking you across different websites. You consent to potentially encountering third party tracking technologies when you use our Site.


        Revisions to This CCPA Privacy Notice
        We may update this CCPA Privacy Notice at any time by posting the amended version on this Site including the effective date of the updated version. By accessing the Site after we post such changes to this CCPA Privacy Notice, you are deemed to have accepted such changes. Please check this CCPA Privacy Notice regularly and before you submit additional personal information via the Site.


        Contact Us
        If you have questions or comments regarding this CCPA Notice and Privacy Policy or if you would like to exercise your rights, please send us an email to info@cotahealthcare.com or telephone us at (866) 648-3833


        Effective Date: February 28, 2022
        Last Updated: February 28, 2022