This Privacy Policy was last updated on February 13th, 2017.

Our Policy:

Project Cohort, Inc. (“Project Cohort”, “we”, “us” and/or “our”) is committed to respecting the privacy rights and concerns of individuals in connection with Project Cohorts website at  (the “Site”) and the Company’s services and related mobile application (collectively, the “Services”). This Privacy Policy sets forth Project Cohort’s policy with respect to information it collects and uses in connection with the Site and Services, including any information which is capable of uniquely identifying an individual (“Personal Data”).

The Services are designed to enable individual users of the Service (“Users”) to distribute custom User-generated messages and content across various digital domains and platforms to a particular audience (“Viewers”) based upon the apparent attributes and interests of the Viewers (“Viewer Attributes”). Project Cohort may receive and use information relevant to determining Viewer Attributes from its third party business partners who have directly collected such information in accordance with their respective privacy policies. Project Cohort is not responsible for the collection, storage, or use of any Personal Data or other information by its third party business partners. We encourage you to review the privacy policies of the third-party websites, mobile applications, and other online services that you visit. We may offer individuals the right to “opt out” of receiving receiving targeted messages from our Users, and to the extent we do so, the mechanism for opting out is described in the section entitled “Your Choices” below.

Information We Collect: When you interact with us through the Site, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Site: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, or register for access to the Services as a User. Wherever Project Cohort collects Personal Data we make an effort to provide a link to this Privacy Policy.

Data from Mobile Device Address Book and Other Applications: The Services may also collect information (including Personal Data) about others that is stored in a User’s mobile device address book, mobile device contacts, calendar or other non-Project Cohort applications in order to send messages to a particular individual. Depending on a User’s mobile device operating system, the Services may request permission to access such information. For example, as a User you may use our address book or “contacts” importer (or other similar features) to upload your address book into the Services.

Data from Invitations: If you are a User, please note that when you invite another

User to connect with you on the Services or invite another person to join the Services and become a, that person may have access to your email address or, for SMS invitations, mobile number because it may be displayed in the invitation. After sending these invitations, we may also remind your invitees of your invitation on your behalf.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Project Cohort and the authorized third parties referred to herein located in the United States.

Other Information:

Non-Identifiable Data: When you interact with Project Cohort through the Site or Services, we receive and store certain personally non-identifiable information. Such information is collected passively using technologies such as cookies, pixel tags and web beacons, and at present, such information cannot be used to specifically identify an indiv. Project Cohort may store such information itself or such information may be included in databases owned and maintained by Project Cohort affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating the Site and Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Site and Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

Aggregated Personal Data: In an ongoing effort to better understand and serve its Users, Project Cohort often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Project Cohort may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Project Cohort may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Location Information: Our Service may collect and use your location information (for example, by using the GPS on your mobile device when you access the

Site or Services from your mobile device) to provide certain functionality of our Service. If you choose to enable our location features, your location information may be publicly displayed within the Service. Please keep in mind that your generalized location (for example, the city or locality in which you are located) may be made available to other Users or individual visitors to the Site, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your location information may be subject to abuse, misuse, and monitoring by others, so please be careful if you choose to enable location functionality. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data” section.

Do Not Track Signals: We may (and we may allow third party service providers to) use cookies or other technologies to collect information about your browsing activities over time and across different websites following your use of the Services. Our Service currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Third Party Analytics: We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. As an example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go to

We have also implemented Google Analytics features based on Display Advertising (Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and Integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers). Visitors can opt out by using Google’s Ads Settings or going to

Our Use of Your Personal Data and Other Information:

Project Cohort uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Project Cohort and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. Project Cohort and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. in addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists,p lease contact us as indicated below.

If Project Cohort intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information:

Project Cohort is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: Project Cohort, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Project Cohort may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Project Cohort, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Your Choices:

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

Exclusions:

This Privacy Policy does not apply to any Personal Data collected by Project Cohort other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Project Cohort through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Project Cohort shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children:

Project Cohort does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Project Cohort through the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites:

This Privacy Policy applies only to the Site and Services. The Services may contain links to other web sites not operated or controlled by Project Cohort (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Project Cohort endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Integrating Social Networking Services:

One of the special features of the Service is that it allows you to enable or log in to the Services via various social networking services like Facebook or Twitter (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and Project Cohort shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

Security:

Project Cohort takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Project Cohort via the Internet.

Changes to Project Cohort’s Privacy Policy:

The Services and our business may change from time to time. As a result, at times it may be necessary for Project Cohort to make changes to this Privacy Policy. Project Cohort reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Project Cohort:

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.

Please also feel free to contact us if you have any questions about Project Cohort’s Privacy Policy or the information practices of the Services.

You may contact us as follows: info@yourcohort.com.