Cofy Privacy Policy

Introduction

This Privacy Policy describes how Cofy, MB and its corporate affiliates (collectively, "Cofy," "we", "us" or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, and other activities described in this Privacy Policy (collectively, the "Service")).

Cofy provides a business-to-business ("B2B") sales engagement platform designed to help its enterprise customers manage personalized email outreach campaigns with built-in compliance tools. For data processing activities where we act at the direction of and on our relevant customer's behalf, this Privacy Policy does not apply to such personal information. Our use of personal information that we process on the relevant customer's behalf may be governed by our agreements with such customers.

Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, familial or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise customer or in their professional capacities and not their individual capacities.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe" or "European" and should be understood accordingly) below.

Index

• Personal information we collect
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfers
• Children
• Changes to this Privacy Policy
• How to contact us
• Google API Services — Limited Use Disclosure
• Recipient rights and unsubscribe
• Notice to European users

Personal information we collect

We may collect personal information from or about you from a variety of sources. Below, we describe the various manners in which we may collect such personal information. We may combine your personal information that we obtain from various sources.

Information you provide to us or that we generate about you.

Personal information you may provide to us through the Service or otherwise or that we may generate about you, includes:

• Contact data, such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.
• Demographic data, such as your city, state, country of residence, and postal code.
• Account data, such as the username and password that you may set to establish an online account on the Service, information about where you found us, the email address(es) from which you conduct the outreach campaigns, and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data, such as reviews, comments, questions, messages and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.
• Financial data, such as your financial account numbers or payment card information, including corporate payment card information.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources.

We may obtain personal information about you from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Private sources, such as data providers (including licensors) and social media platforms.
• Customers
• Service Providers that provide services on our behalf or help us operate the Service or our business.
• Marketing partners, such as joint marketing partners.

Automatic data collection.

We, our service providers, and our business partners may automatically log information about you, your device, and your interaction over time with the Service, our communications and other online services. The information collected automatically may include:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, language settings, and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails).

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

• Service delivery and operations. We may use your personal information to: provide and operate the Service and our business; establish and maintain your user account on the Service; enable security features of the Service; communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and provide support for the Service, and respond to your requests, questions and feedback.
• Service personalization. We may use your personal information to: understand your needs and interests; personalize your experience with the Service and our Service-related communications; and remember your selections and preferences.
• Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect.
• Marketing and advertising. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, and develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
• Compliance and protection. We may use your personal information to: comply with applicable laws, lawful requests, and legal process; protect our, your or others' rights, privacy, safety or property; audit our internal processes; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity.
• With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
• Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing. For data obtained through Google APIs specifically, we delete all associated Google user data within 30 days of the user disconnecting their Google account or revoking access (see our Google API Limited Use Disclosure for details).

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Affiliates. Our corporate parent, subsidiaries, and affiliates.
• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for compliance and protection purposes.
• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Cofy, financing of Cofy, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). In the event of a merger, acquisition, or sale of assets, user information may be transferred as part of that transaction. We will notify users of any such change in ownership or control of their personal information.

Your choices

In this section, we describe the rights and choices available to all users.

• Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
• Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Cookies and other tracking technologies. You can manage cookies via your browser settings.
• Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in Lithuania and may use service providers that operate in other countries. Your personal information may be transferred to other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Email: david@getcofy.com

Phone: +3706010401

Address: Cofy, MB — Kalvariju 112, LT-08211 Vilnius, Lithuania

Google API Services — Limited Use Disclosure

Cofy's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically, Cofy:

• Only requests access to the Google API scopes that are necessary for the application to function — specifically, composing and drafting outreach emails, sending emails on the user's behalf, reading replies to outreach campaigns, and managing campaign-related messages and labels within the user's mailbox. The full Gmail scope is required because narrower scopes do not cover all required operations (compose + send + read + label management) within a single OAuth grant.
• Does not use Google user data for serving advertisements, including retargeting, personalized, or interest-based advertising.
• Does not allow humans to read Google user data unless: (a) we have the user's affirmative agreement, (b) it is necessary for security purposes (such as investigating abuse), (c) it is necessary to comply with applicable law, or (d) our use is limited to internal operations and the data has been aggregated and anonymized.
• Does not transfer or sell Google user data to third parties except as necessary to provide or improve user-facing features, to comply with applicable law, or as part of a merger, acquisition, or asset sale with notice to users.
• Does not use Google user data for email warming, email deliverability manipulation, or any purpose that circumvents Google's abuse or safety restrictions.

Cofy does not provide email warming or email deliverability manipulation services for Google accounts (Gmail / Google Workspace). Any deliverability features offered by Cofy for other email service providers are explicitly not available for and do not apply to Google accounts. Users may not use Cofy to perform email warming or to circumvent Gmail's spam filters or sending limits.

For a video walkthrough demonstrating exactly how Cofy accesses and uses data from Google APIs, please see our Google API Limited Use Disclosure page.

Recipient rights and unsubscribe

Every outreach email sent through the Cofy platform includes a clearly visible, one-click unsubscribe link. When a recipient clicks the unsubscribe link:

• The recipient is immediately and automatically removed from all future outreach campaigns by that sender.
• The recipient's email address is added to a global suppression list maintained by Cofy, ensuring they will not receive further outreach emails from the same Cofy account.
• Unsubscribe requests are processed automatically and honored immediately — no manual review or delay.

Cofy requires all users to include a valid physical mailing address and accurate sender identification in every outreach email, in accordance with the CAN-SPAM Act, GDPR, and other applicable anti-spam regulations.

If you have received an unwanted email from a Cofy user and the unsubscribe mechanism did not work, please contact us at david@getcofy.com and we will ensure you are removed promptly.

Notice to European users

General

Where this Notice to European users applies. The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy). Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR) — i.e., information about individuals from which they are either directly identified or can be identified.

Controller. Cofy is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called UK GDPR (as and where applicable, the "GDPR")). See the "How to contact us" section above for our contact details.

Our GDPR Representatives. Our EU representative appointed under the EU GDPR is EDPO. You can contact them by using EDPO's online request form or by postal mail to Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

Our UK representative appointed under the UK GDPR is EDPO. You can contact them by using EDPO's online request form or by postal mail to 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use.

• Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity").
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests").
• Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
• Where we have your specific consent to carry out the processing for the purpose in question ("Consent").

We have set out below, the legal bases we rely on in respect of the relevant purposes for which we use your personal information:

• Service delivery and operations — Contractual Necessity.
• Research and development — Legitimate Interest.
• Service improvement and analytics — Legitimate Interests; Consent (for optional cookies).
• Direct marketing — Legitimate Interests; Consent (where required by applicable law).
• Compliance and protection — Compliance with Law; Legitimate Interest.

Retention. We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. When we no longer require the personal information we have collected about you, we will either delete or anonymize it. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold: Access; Correct; Delete; Transfer; Restrict; Object; Withdraw Consent.

Exercising These Rights. You may submit these requests by email to david@getcofy.com or our EU or UK representative's postal address provided above. We may request specific information from you to help us confirm your identity and process your request.

Your Right to Lodge a Complaint with your Supervisory Authority. If you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. For users in the European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en. For users in the UK: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are a Lithuania-based company and many of our service providers, advisers, partners or other recipients of data are also based in Lithuania or the EU. Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by implementing appropriate safeguards such as Standard Contractual Clauses or relying on adequacy decisions. You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.