Posted November 16, 2020
Coil Technologies, Inc. (“Coil”, “we”, “our”, or “us”) was started because we wanted a way for you to access content effortlessly, fairly reward its creators, and do so without compromising on your right to privacy. We always aim to collect as little data as possible, store it as briefly as possible, keep it as secure as possible, and restrict access to it as much as possible.
By using our Service or interacting with us offline, you agree to our Terms of Service (“Terms”) and consent to our collection, use, disclosure practices, and other activities as described in this Policy. If you do not agree and consent, you must stop using our Service.
If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
1. Information Collection
A. Information You Provide
We collect information about you that you provide when you use our Service. The information we collect, and have collected in the last 12 months, includes:
- Contact Data: Your first and last name and email address.
- Account Credentials: Your username and password.
- Billing Data: Our payment processor, Stripe, collects your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
- Profile Data: Your payment pointer, upvotes, preferences, and profile picture.
- Communications: Content within any messages you send to us (such as feedback, upvotes, and questions to customer support)
- Content: Any articles, comments, links, etc. that you submit to the Service.
- Job Application Data: Data provided to us in the context of your job application with us, if applicable.
B. Information Collected Automatically
We also automatically collect information about you when you use our Service. The information we automatically collect, and have automatically collected in the last 12 months, includes:
- Coil OAuth: When you authenticate through one of our partners' services we collect the authorization and the time of day associated with the authorization. For more information, see the “Partner Sign in and Linking” bullet point in the next section.
- Generated Data:
- Features you use or parts of the Service you view.
- Pages you visit on the Service, but not the pages you visit anywhere else.
- Whether you click links in emails from Coil.
- The time of day you use the Service.
- Your referring and exiting pages on the Service.
- Device Data:
- The type of device and browser you use.
- Your device’s operating software.
- Your device’s regional and language settings.
- Your IP address and other device identifiers.
- Location Data: We derive imprecise location data from your IP address which is data that indicates a country, city, or postal code.
The tracking technologies used to automatically collect information include the following:
- Log Files: A log file is a file that records events that occur in connection with your use of the Service, such as your generated data and device data.
- Cookies: A cookie is an industry-standard small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, tracking referrals, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
- Scripts: We put embeds in a page that send requests to external sites which may allow the external site to collect data about you and drop and read cookies on your browser. For example, we use scripts for website chat functionality.
For further information on tracking technologies and your rights and choices regarding them, see the next section and the section “Your Rights and Choices” below.
C. Where We Collect Information
We collect information you provide at various points on the Service, including:
- Browsing our Website: When you visit our website, we automatically collect generated data, device data, and location data.
- Accounts: When you create an account with Coil, we collect your contact data and account credentials upon registration. We also collect any profile data you submit in connection with your account.
- Purchasing Subscriptions: We use our payment processor, Stripe, to collect your billing data as necessary to process your orders, respond to chargebacks, resolve payment network disputes, and detect and prevent payment fraud.
- Customer Support: We record phone calls and collect the content of messages you send to us, such as feedback, questions, and information.
- Coil Extension: Coil offers a browser extension that allows us to pay content creators when our members visit their websites. We do this through Web Monetization, which is an open-standard protocol for streaming payments to content creators in real time. Until Web Monetization is natively built into browsers, the extension is required for us to stream money to content creators. Members have to sign into the extension so we know the member account is authorized to use Web Monetization.
The “Coil Extension” works as follows: The content creator sets up a wallet through a third-party service which provides the content creator with a payment pointer. The content creator incorporates a Web Monetization HTML tag into their website, using the payment pointer. When a Coil member who has the extension installed on their browser visits the content creator's website, the extension looks for the Web Monetization HTML tag which provides the payment pointer to the Coil Extension. The Coil Extension resolves the payment pointer to an ILP address which is sent to Coil's servers, allowing Coil to pay the content creator. Coil also shares an ephemeral identifier with the creator which the content creator uses to verify that the member’s browsing session is monetized. The identifier is random on every page load and Coil does not use it to track you across different sites.
We also support monetization for Youtube videos and Twitch channels. When a member who has the extension installed interacts with such videos or channels, we receive the URLs to those videos or channels.
With respect to the Coil Extension, Coil does not share the name, email, or Coil username of its members with content creators. The content creators only know they are being paid by Coil. When browsing with the Coil Extension, Coil can see when a member is on a web-monetized website and which wallet provider the website uses, but not the URL of the specific website.
Please note that content creators are independent third parties, and Coil is not responsible for their data practices. For information about your choices for the Coil Extension, see the section “Your Rights and Choices” below.
- Partner Sign in and Linking: Coil partners with certain third-parties to allow them to monetize their sites through Web Monetization without requiring you to have the Coil Extension installed. In addition Coil partners with certain third-party browsers so that the websites you visit through the browser can be monetized without having the Coil Extension installed. The process is as follows: A Coil member signs into their Coil account or creates a new Coil account, and links the account to a partner. As part of this linking the partner is granted an access token to the member's Coil account. This token allows the partner to identify the member by an id, and stream payments on the member’s behalf. In addition, upon the member’s authorization, the partner may have access to the member’s:
- Membership status which includes the renewal date and if the membership is active
- Full name
- Email address
- Payment pointer
- Currency preferences
- Profile picture URL
For information about your choices for “Partner Sign in and Linking” please see the section “Your Rights and Choices” below.
D. Information Collected from Other Sources
We also obtain information about you from other sources. We protect data obtained from these other sources according to the practices described in this Policy, plus any additional restrictions imposed by the source of the data. The categories of sources we collect, and have collected from in the last 12 months, include:
- Partners with which we offer co-branded services, who sell or distribute our services, or engage in joint marketing activities.
- Social networks with which you interact, such as when you Tweet at us or grant permission to Coil to access your data on one or more of these services.
2. Use of Information
Coil collects and uses information for business and commercial purposes in accordance with the practices described in this Policy. Our business purposes for collecting and using information, and for which we have collected and used information in the past 12 months, include:
- Managing and operating the Service, including your registration and account.
- Facilitating the use of the Coil Extension and partner sign in and linking as described in the “Information Collection” section above.
- Responding to your requests and providing customer service.
- Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Preventing and addressing fraud, breach of policies or terms, and threats or harm.
- Monitoring and analyzing trends, usage, and activities.
- Conducting research, including focus groups and surveys.
- Improving the Service or other Coil websites, apps, marketing efforts, products, and services. Developing and providing you with direct marketing, communications, and advertising about our and other entities’ products, offers, promotions, rewards, events, and services.
- Fulfilling any other purpose at your direction.
- With notice to you and your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
3. Sharing of Information
We share information we collect in accordance with the practices described in this Policy. The categories of parties with whom we share information, and have shared information with in the past 12 months, include:
- Service Providers: We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
- Related Entities: In the event we have any related entities, such as subsidiaries, joint ventures, etc., we may share information within our group of such entities, including where they act as our service providers or for their own internal purposes.
- Vendors and Other Parties: We share information with vendors and other parties for analytics and advertising. These vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
- Partners: We share information with our partners in connection with offering co-branded services, selling and distributing our services, and engaging in joint marketing activities.
- Public Forums: The Service is for users to share their own content. We share information you make public through the Service, such as information in your profile or blogs. Please think carefully before making information public as you are solely responsible for any information you make public. If you publish information on the Service that violates your own privacy, we accept no liability or responsibility.
- Merger or Acquisition: We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
- Security and Compelled Disclosure: We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security, and safety of us, the Service or anyone else.
- Facilitating Requests: We share information at your request or direction, such as when you install the Coil Extension or use “Partner Sign in and Linking”. For more information please see the “Information Collection” section above.
- Consent: We share information with notice to you and with your consent.
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
4. Other Parties
5. Analytics and Advertising
We use analytics services, such as Segment and Amplitude, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. Some of these services may serve ads targeted to your interests based on data collected by them about you across time and services (“Interest-based Advertising”).
6. Your Rights and Choices
A. Review and Update of Account Information
You may access, update, or delete certain account information that you have voluntarily submitted to us through your account on the Service by logging into your account and visiting your account settings. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
B. Tracking Technology Choices
- Cookies: Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track: Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor nor take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove tracking technologies, some parts of the Coil Service may not function correctly.
C. Interest-Based Advertising
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you. It does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
Please note that if you opt out of using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
- Emails: You can opt-out of receiving promotional emails from us at any time by clicking the unsubscribe link in an email, or by emailing us at [email protected] with the word UNSUBSCRIBE in the subject field. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or Coil’s ongoing business relations.
Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions.
E. Unlinking Your Accounts
- Coil Extension: If you wish to revoke access to the Coil Extension at any time, you can do so by uninstalling the extension from your browser.
- Partner Sign in and Linking: If you wish to unlink your Coil account from a partner account which you granted access, you can do so through your Coil account settings.
The Service is intended for a general audience and not directed to children under 13 years of age. Coil does not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe Coil has collected personal information in violation of COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such personal information. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
8. Data Security
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.
9. International Transfer
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Policy.
10. Changes to this Policy
From time to time, it may be necessary to revise or reissue this Policy as we develop technologies to do more with less data, launch new products, adapt to new laws or regulations, respond to user feedback, etc. We reserve the right to update this Policy as we deem appropriate and will post the updated Policy to the website. We may provide additional notice to you via email or through our website if the changes are material. Any changes are effective immediately upon posting of the revised Policy. Your continued use of the Service indicates your consent to the Policy when posted.
11. Contact Us
If you have any questions or comments about this Policy, our data practices, or our compliance with applicable law, please contact us:
By email: [email protected]
Coil Technologies, Inc.
268 Bush St #3632
San Francisco, CA 94104
This Policy is designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at [email protected].
12. Your California Privacy Rights
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise your rights.
A. Notice of Collection
The below notice sets out the categories of personal information we have collected in the past 12 months as enumerated by the CCPA. For specifics on where and how this information is collected please visit the "Information Collection" section above.
- Identifiers: name, email address, IP address, and other online identifiers.
- Customer Records: Our payment processor, Stripe, collects your payment information.
- Commercial or Transactions Information: Records of services purchased, obtained, or considered, and your payment pointer.
- Internet Activity: Your preferred display currency, browsing history on coil.com, search history on coil.com, and interactions with a website, email's from Coil, or advertisement.
- Visual Data: Your profile picture and pictures uploaded to our blog.
- Geolocation Data: Data inferred from an IP address.
- Inferences drawn from the above information about your predicted characteristics and preferences as set out in this Policy.
We collect, use, and share these categories of personal information for the business purposes described in the “Use of Information” and "Sharing of Information" sections above.
We do not sell information as defined by the CCPA.
B. Right to Know and Delete
You have the right to know certain details about our data practices in the past 12 months. In particular, you may request from us the categories of:
- Personal information we have collected about you
- Sources from which the personal information was collected
- Personal information about you we disclosed for a business purpose or sold
- Third-parties to whom the personal information was disclosed for a business purpose or sold
In addition, you have the right to request:
- The business or commercial purpose for collecting or selling the personal information
- The specific pieces of personal information we have collected about you
- The deletion of the personal information we have collected from you
To exercise any of these rights, please submit a request to [email protected]. In the request, specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
C. Authorized Agent
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
D. Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for exercising any of your rights.
E. Shine the Light
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third-parties and, in some cases, affiliates for those third-parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us”. Requests 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 Coil is not required to respond to requests made by means other than through the provided email address or mail address.
13. Additional Disclosures for Nevada Residents
We do not sell personal information. However, Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third-party for the third-party to license or sell the personal information to other third-parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at [email protected].
14. Your European Privacy Rights
Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Coil acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.
B. Lawful Basis for Processing
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; and (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third-party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject appropriate or suitable safeguards, such as standard contractual clauses.
C. Your Data Subject Rights
You have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Coil Service. In addition, you have the right to ask us not to process your personal data (or provide it to third-parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with a supervisory authority.