Privacy Policy

Effective Date: June 29, 2019

Welcome, and thank you for your interest in Co-op Limited. (“Co-op”), and our website(s), products, services and applications (the “Services”). This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. If you have any questions about this Privacy Policy, you can contact us here.

If you use our Services, we are the data controller of your personal data. This means we request and collect your personal data and vouch to work responsibly with it. We put the necessary security measurements in place, give you full control over your personal data, and we respect your rights as the owner of your personal data.

This Privacy Policy only covers Co-op's practices regarding personal information, and not information more generally. We may use aggregated, anonymized data that we derived from your personal information before you deleted it, but not in a manner that incorporates any of your personal information or would identify you personally.

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy. You may, of course, decline to share certain personal information with Co-op, in which case Co-op may not be able to provide to you some of the features and functionality found on the Services.

Information Co-op Collects

Things You Provide to Us

When you use the Services, you provide us with personal information that includes your name and your email address. You may also provide your school address and office/mobile phone number, or other personal information.

Your provision of this personal data is required for you to enter into the Terms of Use, a contract, with us, as well as for you to enter competitions and the programmes hosted on the Services. These entries are also a contract between you and the competition host, and we need your personal information to host the Services offered under that contract. If you do not provide the minimum amount of personal data required to register an account, including your name and email address, you cannot use the Services, as this information is necessary for contractual reasons. Please see “European Requirements” below for further information on the bases for our processing your personal information.

We also collect the content you create, upload, or receive from others when using our Services. This includes things like messages you write and receive, learning progress, certificates received.

Information We Collect as You Use Our Services

Your activity

We collect information about your activity in our Services, which may include:

- Learning Progress

- Certificates Awarded

- Learning Tracks/ Paths completed

Cookies and web beacons

We may implement on the Services third party content, such as advertising or analytic services, that uses “clear gifs,” “web beacons,” or other similar techniques, which allow the third party content provider to read and write cookies to your browser or implement similar tracking mechanisms. This information is collected directly by the third party, and Co-op does not participate in that data transmission. Information collected by third parties in this manner is subject to that third party’s own data collection, use, and disclosure policies. We currently implement services provided by Drift and Google Analytics and Facebook.

Linked accounts

When you link an account you may have on a third party service (such as a third party social networking site or email provider) to your Co-op account, Co-op collects certain information stored in connection with that account that you have configured that service to make available, including your email address, provider ID, first and last name, and profile picture. By linking your accounts in this manner, you authorize Co-op to access and use your account on the third party service in connection with your use of the Services.

Why Co-op Collects Information

Co-op uses the information we collect for the following purposes:

Provide Our Services

We use your information to deliver our Services, like administering programmes and competitions you enter.

Maintain & Improve Our Services

We also use your information to ensure our Services are working as intended, such as tracking outages or troubleshooting issues that you report to us. For example, we continuously monitor our systems to look for problems. And if we find something wrong with a specific feature, reviewing activity information collected before the problem started allows us to fix things more quickly.

And we use your information to make improvements to our Services – for example, to understand and analyze the usage trends and preferences of our Co-op users and to improve the way the Services work and look.

Develop New Services

We use the information we collect in existing Services to help us create new features and functionality.

Provide Personalized Services

We use the information we collect to customize our Services for you. We also use data to provide customized third party content and information and to track your status in any Competitions or other activities. In addition, we may use the information we collect to provide personalized and relevant advertising.

Communicate with You

We use information we collect, like your email address, to interact with you directly. For example, we may send you a notification if we detect suspicious activity on your account, or we may let you know about upcoming changes or improvements to our Services. We will also use your email address to contact you with respect to the latest programmes as well as competitions; for administrative and customer service purposes; to address intellectual property infringement, rights of privacy, or defamation issues; or regarding things you post on the Services. And if you contact Co-op, we’ll keep a record of your request to help solve any issues you might be facing.

Co-op also uses your email address or other personal information to send you messages about the Services and communications from other Members. We may also send you messages related to the Services and the activities of third parties we work with. These messages may be targeted at you based on your activities on our Services, for example your engagement in a particular programme or your entry into a specific competition. You will have the ability to opt-out of receiving any such communications through links provided in the email messages.

Protect Co-op, Our Users, and the Public

We use information to help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Co-op, our users, or the public. For example, we collect and analyze IP addresses and cookie data to protect against automated abuse. This abuse can take many forms, such as sending spam to Co-op users or launching a Distributed Denial of Service (DDoS) attack.

When we detect spam, malware, illegal content, and other forms of abuse on our systems in violation of our policies, we may disable your account or take other appropriate action. In certain circumstances, we may also report the violation to appropriate authorities.

Data Retention

Information Retained Until You Remove It

For each type of data, we set retention timeframes based on the reason for its collection.

Information Retained For Extended Time Periods for Limited Purposes

Sometimes business and legal requirements require us to retain certain information for specific purposes for an extended period of time. Reasons we might retain some data for longer periods of time include:

- Security, fraud & abuse prevention

- Financial record-keeping

- Complying with legal or regulatory requirements

- Ensuring the continuity of our services

Sharing Your Information

When You Share Your Information

Many of our Services let you share information with other people, and you have control over how you share. Any information that you voluntarily choose to include in an area of the Services accessible to other Co-op members, such as a public profile page or in a posting, will be available to other Co-op members who access that content. This also applies to information you choose to make available through features that connect to third party services, if applicable.

Also, if you communicate directly with another Co-op member, any information that you voluntarily choose to include in such a communication with other Co-op members will be available to such other members. Once you make your information available in any of these ways, it could be collected and used by the recipients without restriction. We urge Co-op members to exercise common sense, prudence and good judgment about what information to make available to others through the Services.

When Co-op Shares Your Information

We are not in the business of selling your information. We do, however, disclose your personal information in connection with developing and maintaining the Services and operating Competitions. We share your personal information in the following cases:

With your consent

We’ll share personal information outside of Co-op when we have your consent.

To operate programmes and competitions

Co-op may disclose your personal information to the respective learning platforms to enable your participation in the programmes and competitions and our operation of the programmes and competitions.

For external processing

We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer support. These third parties may have access to or process your personal information as a result of performing the services they were engaged to perform.

For legal reasons

We will share personal information outside of Co-op if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

- Meet any applicable law, regulation, legal process, or enforceable governmental request.

- Enforce our Terms of Use, including investigation of potential violations, and take precautions against liability.

- Detect, prevent, or otherwise address fraud, abuse, security, or technical issues.

- Protect against harm to the rights, property or safety of Co-op or our affiliates, our users, or the public as required or permitted by law.

- Protect the security or integrity of the Services and to protect or enforce third party rights.

We may share non-personally identifiable information publicly and with our partners — like publishers, advertisers, developers, or rights holders. For example, we share information publicly to show trends about the general use of our Services.

If Co-op is involved in a merger, acquisition, or sale of assets, we’ll continue to ensure the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Our Commitment to Data Security

Co-op uses a variety of physical, managerial, and technical safeguards designed to improve the security of our systems and your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Co-op, nor can we guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. You transfer your information to Co-op at your own risk.

If Co-op learns of a security breach, we will notify you in accordance with applicable law.

Third Party Websites

The Services contain links to websites and services provided by third parties. Any personal information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links are displayed on the Services. We encourage you to learn about third parties’ privacy and security policies before providing them with personal information.

Our Commitment to Children’s Privacy

Protecting the privacy of children is especially important. For that reason, Co-op does not knowingly collect or maintain personal information from persons under 13 years old, and no part of the Services is directed to persons under 13. IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.

If Co-op learns that personal information of children under 13 years old has been collected on the Services without verifiable parental consent, then Co-op will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has obtained a user account on the Services, then you may alert Co-op at Co-op Support and request that Co-op delete that child’s personal information from its systems.

If you are between the ages of 13 and 16 years old, you may not use the Services until Co-op has received verifiable parental consent or endorsement from your school for your use of the Services. If you are between the ages of 13 and 17 years old or under the age of contractual majority in your country, you also may not enter any competitions until Co-op has received verifiable parental consent or endorsement from your school for your entry into a specific competition. Please check the eligibility rules for each competition to verify that minors are allowed to participate and ensure that the parental consent form is on file for each competition. More information on the parental consent process can be found at Co-op Support.

Compliance & Cooperation with Regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data Transfers

Your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We transfer your personal data from the European Union to the United States in accordance with standard contractual clauses we entered into. The standard contractual clauses can be read here.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

European Requirements

If European Union (EU) data protection law applies to the processing of your information, you can exercise your right to request access to, update, remove, and restrict the processing of your information. You also have the right to object to the processing of your information or export your information to another service. Please visit Co-op Support to exercise these rights.

If you have any questions, you may contact our data protection office at [email protected]. If you have concerns regarding your rights under local law, you can contact your local data protection authority. We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.

When we’re pursuing legitimate interests

We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

- Providing, maintaining, and improving our Services to meet the needs of our users

- Developing new products and features that are useful for our users

- Understanding how people use our Services to ensure and improve the performance of our Services

- Customizing our Services to provide you with a better user experience

- Marketing to inform users about our Services

- Providing advertising to make many of our Services freely available for users

- Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services

- Protecting against harm to the rights, property or safety of Co-op, our users, or the public as required or permitted by law

- Performing research that improves our Services for our users and benefits the public

- Fulfilling obligations to our partners like developers and rights holders

- Enforcing legal claims, including investigation of potential violations of our Terms of Use

When we’re providing a service

We process your data to provide a service you’ve asked for under a contract. For example, we process your information in connection with programmes and competitions you enter.

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.

Changes and Updates to this Privacy Policy

We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. Note that our amended Privacy Policy will become effective on a going-forward basis as stated in the Terms, except that (i) unless you agree otherwise, we will use your personal information in the manner described in the Privacy Policy in effect when we received that information and (ii) if you do not agree with any changes to the Privacy Policy, you must terminate your Co-op membership and cease use of the Services. Your continued use of the Services after a revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of the Privacy Policy.

Co-op Contact Information

Please contact Co-op with any questions or comments about this Privacy Policy, your personal information, our use and disclosure practices, or your consent choices through Co-op Support.

Specific Contact Emails:

- General Privacy: privacy [at] co-op [dot] group

- Data Protection Office: data-protection-office [at] co-op [dot] group

Contact Us


1/F, 30 Tai Yuen Village,

Yung Shue Wan, Lamma Island,

NT, Hong Kong


Phone: +852 60897550

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