Last Updated: March 25, 2021
At Black’s Business Systems, Inc. d/b/a CoCounsel (“CoCounsel,” “us,” “our,” or “we”), we recognize that your privacy is important – both to you and to us. This CoCounsel Notice of Privacy Practices (“Notice” or “Privacy Notice”) has been compiled to disclose our privacy practices to you, and inform you about how your Personal Information is being used when you access and use our Platform and Services (each term as defined in our Terms and Conditions of Service). “Personal Information,” also known as “Personal Data,” and as used in this Privacy Notice, means information that can be used on its own or with other information to identify, contact, or locate you, or to identify you in context. This includes your name, physical address, email address, telephone number, payment card information, account username, and other identifying information. It also includes other information that may be associated with your Personal Information, such as your location, IP address, preferences or interests. Importantly, we may collect Personal Information directly from you when you visit our Platform.
Please read this Privacy Notice carefully so that you have a clear understanding of how we collect, use, otherwise handle and protect your Personal Information in connection with your use of the Platform or the Services. You may also wish to review our Terms and Conditions of Service, into which this Privacy Notice is incorporated by reference.
We may collect certain information from you when you use our Services, including our Platform. We collect and obtain your information in a few ways: there is information that you choose to give to us, information we obtain through your use of our Services – including our Platform – and information we obtain from third parties. Each of these is detailed below:
We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and/or Services. Examples include when you (i) fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply identification and other verification information, (ii) access or use the Platform, such as to make requests for or accept CoCounsel Services, pay for CoCounsel Services, post comments or reviews, or communicate with other users, (iii) link your account on a third party site (e.g. Facebook) to your Account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you, and (iv) communicate with CoCounsel. Some of this information may comprise “Demographic Information,” which may include, but is not limited to, your zip code, hometown, gender, age/birth date, browsing history information, searching history information, and registration history information. Some Demographic Information may not directly reveal your identity; however, at times the combination of various types of data, including Demographic information, may enable you to be identified, and may therefore qualify as Personal Information.
We also receive, store and process information, including Personal Information, when you access or use our Platform.
When you use certain features of the Platform, we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. information on the device used to access the Platform, such as your mobile device, GPS-based functionality on your mobile devices when used to access the Platform, or specific features of the Platform). If you do not want your device to provide us with location-tracking information, you may be able to disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
We may also receive, store and process information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with CoCounsel or logged in to your Account, such as your IP address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.
CoCounsel uses “cookies” and other similar technologies, such as mobile application and other device identifiers, on the Platform. Cookies are small data text files stored locally on your computer that uniquely identify your browser. As a result, when you access or use the Platform, you will provide or make available certain information to us. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to same. We track your activities if you click on advertisements for CoCounsel services on third party Platform such as search engines and social networks, and may use analytics to track what you do in response to those advertisements. If you disable cookies, you may lose some of the features and functionality of using our Platform, as cookies are necessary to track and enhance your use and access.
We may, either directly or indirectly, also continue to track your behavior on our Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through third parties we engage to provide services to us, track your behavior on our Platform to market and advertise our services to you on the Platform and third party websites.
We do not respond to “do not track” browser signals.
We treat information collected by cookies and other technologies as non-Personal Data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by local law, we also treat these identifiers as Personal Data
CoCounsel may collect information from various third parties about you, such as any third-party service providers who we use to provide our Services to you. From time to time, we may also use or augment the Personal Information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use such third party information to confirm contact or financial information or to better understand your interests by associating demographic information with the information you have provided.
Additionally, we may allow you to access or use certain features of the Platform, or share your access to or use of the Platform with others using accounts you created with third party services, like Facebook (“Third Party Service Accounts”). If you choose to login to the Platform using this method, the Third Party Service Account may ask your permission to share certain information from your Third Party Service Account with CoCounsel – such as your name, email address, and your Third Party Service Account profile data. Such information is collected by the Third Party Service Account provider and shared with CoCounsel according to the Third Party Service Account provider’s privacy policies.
Other services, such as those of third party payment providers, may require you to provide your financial information (such as your payment card information, including expiration date and verification code) as well as your name, address, email address, and other Personal Information to complete purchases. CoCounsel does not collect any financial information or payment card information itself in relation to orders on the Platform; all payment processing is conducted by third party payment providers.
We will primarily use, share, and/or disclose your information to provide you access to, and facilitate your use of, our Platform and other Services. We will use, share, and/or disclosure Personal Information from or about you in the following instances:
A. When you consent for us to do so (“Consent”). We may also ask for your consent to process your Personal Information for a specific purpose that we communicate to you, for instance, to receive our newsletter and other such mailings you may be interested in. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.
B. To fulfill a contractual obligation that we have with you, where applicable (“Contract”). This includes the processing of your information related to your online orders via our Platform.
C. To comply with a legal or statutory requirement or obligation (“Legal Obligation”). This may include responding to a lawful and enforceable request by law enforcement, judicial body, or other public authorities, or in connection with a legal obligation we have to a third party, or reporting unlawful activity to law enforcement.
D. To fulfill another legitimate interest, when not overridden by your interests or, where applicable, your fundamental rights and freedoms which require the protection of Personal Information (“Legitimate Interest”).
We use, store and process information about you for the following general purposes:
We may review, scan, or analyze your communications with other users exchanged via the Platform in relation to maintenance of the Platform, for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages to mask contact information and references to other websites. We may also scan, review or analyze messages for research and product development purposes to help make searching, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings.
We may use Demographic Information to tailor the Platform to your interests, as well as any communications related to your use of our Services, and those communications you have consented to receive from CoCounsel.
Your Personal Information may be disclosed in several instances, including:
We reserve the right to report to law enforcement any information – including Personal Information – related to the use of our Services to further any unlawful activity or activity we in good faith believe to be unlawful.
We may also share Demographic Information with advertisers on an aggregated basis (i.e., without telling the advertisers your identity). One of the reasons we may do this is to increase the likelihood that our advertisers’ goods and services will appeal to you as a customer of the CoCounsel Platform. Our sharing of Demographic Information with our advertisers is anonymous (i.e., we do not tell advertisers which particular CoCounsel Customers are members of which demographic groups), subject to the rest of this Privacy Notice. When you respond to an advertisement, however, we ask you to remember that if the advertisement is targeted to a demographic group and you decide to give the advertiser any of your Personal Information, then the advertiser may be able to identify you as being a member of that demographic group.
CoCounsel does not sell, trade, or rent your Personal Information to others. As noted above, we may release or disclose your information to third-party service providers or agents who perform functions on our behalf or who facilitate the provision of our Services to you.
We may also share your information in relation to a merger, sale, financing, acquisition or other transaction involving all or a part of CoCounsel with another company. We may also share any additional information that you have consented for us to share.
If you are visiting this site or utilizing services from a country other than the United States, the various communications you send and receive may result in the transfer of information across international boundaries. If you are located in the European Union you should be aware that information you provide or which is otherwise collected on this Platform or through any services rendered may be transferred to countries (including the United States) which may not have data protection laws deemed as adequate as those in the EU.
We keep your Personal Information to enable your continued use of CoCounsel’s Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be required by applicable law, as necessary to protect our rights and interests, or as otherwise communicated to you. For example, we may retain your transaction history so that you can review past purchases (and repeat orders if desired) and what addresses you have shipped orders to, and to improve the relevancy of products and content we recommend.
CoCounsel will ensure that you can exercise your rights pertaining to your Personal Information, including rights as provided by various data protection laws. CoCounsel therefore informs you that, where applicable under relevant law, you are entitled:
Under certain laws, you may also have the right to “opt-out” of having your Personal Information sold to a third party. However, CoCounsel does not sell your Personal Information to any other party. Only in the case of a merger, sale, financing, acquisition, or other transaction involving all or part of CoCounsel may your information be involved in a transaction.
For deletion/”right to be forgotten” requests, we will undertake a good faith effort to accommodate requests for access to or deletion of personal information. However, these requests may be subject to the evaluation of additional factors, including disproportionate burden or expense, or the risk to the rights, including the privacy rights, of others.
We will strive and work to resolve any inquiry you may have regarding our privacy practices. EU residents may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact the competent data protection authority directly.
If you have any questions, would like to exercise any of these rights, or if you need any assistance with privacy related matters, please contact us as described in the “Contact Us” section below. We will take the necessary steps to respond to you as soon as possible.
You may change certain preferences in your account regarding the sharing and use of your information on our Platform by visiting your account settings. Please note that some Platform functionality may be impacted depending on the preferences you choose.
CoCounsel also offers individuals the opportunity to choose or “opt-in” to receive emails or other communications from us and/or our partners regarding offers, products, and services we feel may interest you. We will ask you if you want to receive such emails before we begin sending them to you. If you have opted in to receive such communications from us but later decide you do not want to receive solicitations from us or our partners related to your account with us, you can “opt-out” by accessing and editing your account information to no longer receive such offers and mailings, or by following the “unsubscribe” directions attached to such emails.
You also have the ability to change your browser’s and your device’s cookie settings, as described above.
You can always update your basic account information by logging into your CoCounsel account. If you need to access, update, or delete other Personal Information we may have in another way or manner, please contact us at the address below. Note that we may limit additional requests to modify your Personal Information, such as if your request impacts other users’ privacy, concerns information that CoCounsel does not possess or control, is repetitive, is unlawful, or requires technical means disproportionate to the request.
We have reasonable and appropriate administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. Accordingly, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store. As a result, you acknowledge that there are data security and privacy limitations inherent to the Internet, and that the security, integrity, and privacy of any and all information exchanged between you and CoCounsel cannot be guaranteed.
We may change this Privacy Notice at any time and without notice, at our sole discretion. We may change how we collect and then use Personal Information. The most current version of our Privacy Notice is accessible on our Platform at all times. If we make material changes to the Privacy Notice, we will notify you either by posting an alert on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Notice.
We collect your email address in order to:
As noted above, if you have opted in to receive such communications from us but later decide you do not want to receive solicitations from us or our partners related to your account with us, you always can “opt-out” by accessing and editing your account information to no longer receive such offers and mailings, or by following the “unsubscribe” directions attached to such emails.
California Civil Code Section 1798.83 permits California residents who have supplied Personal Information, as defined in the statute, to us to request and obtain certain information regarding our disclosure, if any, of Personal Information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of Personal Information shared and the names and addresses of all third parties that received Personal Information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to us at the below address. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this address. Information will be provided within thirty (30) days of your request, or we will inform you that we need additional time to fulfill your request.
You may also request that we not share your personally identifying information with third parties for purposes of direct marketing; if you make such a request we agree to cease sharing your personally identifying information with third parties for purposes of direct marketing within a reasonable time.
Information shared by us with third parties for purposes other than direct marketing will not necessarily be included in our response to such request. We reserve the right to request and confirm proof of identity as we determine necessary in our sole discretion.
California residents may reach the Complaint Assistance Unit of the Division of Consumer Services by mail at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
If you have any questions regarding this Policy or our privacy practices, you can contact us at:
9130 S. Dadeland Blvd, Suite 1704
Miami, FL 33156
Attn: Timothy V. Curtis
Toll-free: (305) 374-1521
Or by email at: firstname.lastname@example.org
Please note that CoCounsel is not responsible for the content or practices of third party websites or services to which CoCounsel may link through our Platform. Your interaction with all third party service providers’ websites is governed by the applicable third party privacy policies. We encourage you to review the privacy policies of such third party providers before using their sites or services.