In COR we are committed to protecting Consumers personal data and respecting your privacy. This privacy policy (“Privacy Policy”) sets out the basis on which we, COR Global Ltd. and our affiliates (hereinafter indistinctively “COR” or “We” “Us”) collect, use, process, share, disclose and store the Personal Data -as this term is defined below-, collected and/or processed in connection with you accessing and/or logging in COR’s website: www.projectcor.com and mobile devices as an app (hereinafter, indistinctively “Consumer/s” or “You” and the “Platform/s” respectively). Through this Privacy Policy We show the main measures we take to fulfill our commitment with your privacy.
As used in this Privacy Policy, “Personal Data” or “Personal Information” means any data provided by Consumers, when accessing and/or logging in to our Platform/s, or by any other means as further detailed on Section 3 of this Privacy Policy.
This Privacy Policy complements COR’s Terms and Conditions for the Usage of “COR’s” Platform’s available at: https://projectcor.com/es/terms-of-service/(hereinafter, “COR’s Terms and Conditions”).
The Personal Information collected by COR will be processed pursuant to: (i) the manner described herein; (ii) COR’s Terms and Conditions; and (iii) all requirements set forth by laws governing Personal Data applicable to the geographical area where the Consumers are located at (“Applicable Data Protection Laws”.)
For further clarifications on this Privacy Policy, questions or concerns, please do not hesitate to contact us (see Section 17 How to contact Us).
COR Global Ltd. is a Delaware limited liability company headquartered at 910 Foulk Road Suite 201, Wilmington, DE 19803; e-mail address legals@projectcor.com.
For the purpose of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), COR is the data controller of Consumer’s Personal Data as described in this Privacy Policy, unless expressly specified otherwise.
COR’s Data Protection Officer is Mr. José Gettas with e-mail address:
jose@projectcor.com.
We have collected within the last twelve (12) months, and may collect in the future the following categories of Personal Information listed below from Consumer’s, through the Platform/s, for business purposes pursuant the California Consumer Privacy Act of 2018 (“CCPA”):
Identifiers and registration contact information: Consumer’s full name, gender, birth date, country of residence, location, e-mail address, postal address, telephone number, Internet Protocol (IP) address.
Internet or other electronic network activity information: Consumer’s device information and device identifiers, browsing type and language, browsing history, search history, and information regarding the Consumer’s interaction with the Platform/s.
Geolocation data: Consumer’s’ city, state, zip code, etc. related with the IP address.
Other Information: Personal Data that you provide to Us as part of your use of COR, as detailed in 3(e).
We may collect data, including Personal Data, through our interactions with Consumers when they:
Access and register on our Platform/s and/or our affiliates Platforms;
Download content on our Platform and/or our affiliates Platforms;
Provide us and/or our affiliates with information via phone, email, social media, etc.;
Subscribe to COR’s and/or COR’s platforms newsletters, or other content-related material;
Leave comments on our Platform/s and/or on our affiliate’s platforms.
During in-person meetings at COR’s and/or COR affiliate’s events, conferences, workshops or gatherings;
Online information about Consumer’s may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our Platform/s our affiliate’s Platforms or sites of third parties. For more information on cookies and similar technologies, please see Section 6 below.
We work closely with various third parties and may receive Personal Data from them. We protect the Personal Data obtained from them in accordance with the practices and policies described herein, plus any additional obligations imposed by the third-party source of the Personal Data. The third-party sources may vary due to context, but may include the following:
authentication partners: if Consumer’s register or log in into our services using third party credentials (e.g. Facebook, Google, OKTA) we will import their information from such third party source to help Candidate’s and Companies’ create an account on our Platform;
technical services partners that helps us without technology, and may provide us with certain data (e.g. such as mapping IP address to location data) to help us to provide our services,
(iii) advertising partners, that provide us with services on our Platform (analytics, marketing, etc.) providing with inferences about Candidate’s and Companies’ preferences and interests to offer Candidate’s and Companies’ a better service and customized offering.
Our Platform/s automatically collects certain data, through automatic data collection tools such as cookies, beacons, among others. These tools automatically collect the following information:
Technical information including, but not limited to, Consumer’s browser type, operating system, device information, online identifiers including cookie data and Internet Protocol address (IP), domain name, referral URL, time zone setting, and/or time-stamp for their visit, information about their devices.
Usage information including, but not limited to, Consumer’s geographic location information (such as country and/or state), date and time they visited our Platform, numbers and frequency Consumers to our Platform, page views and search queries, clickstream behaviors, amongst others. Also, it may include details of Consumer’s use of third-party applications in connection with COR’s Platform.
Information you provide in goals, portfolios, projects, and tasks
Information and documentation uploaded to COR, such as attachments
Information contained in emails you address to x@projectcor.com
Profile photo and other information you choose to include to describe yourself, only collected if you do choose to provide it
Video and audio recordings, and transcripts of those recordings, if you use video messaging
Professional or employment information, such as your title or role at your company
Any other information you choose to provide while using COR that identifies or can be reasonably associated with you
Other information you may provide to us when you interact with COR in other ways
You may voluntarily provide us with information when you interact with us in other ways, such as when you directly interact with COR staff, such as our sales, user research, support, or user operations groups. COR may process:
Your requests, questions, and responses to us via forms or email
Information you provide in connection with COR sweepstakes, contests, or research studies, if you choose to participate
Information to verify your identity
Your date of birth
Your audio and video, if you participate in a sales call, support call or user research study and do not opt out of call recording, which also involves the collection of biometric information associated with the call recordings
During the past 12 (twelve) months we have disclosed the categories of Personal Information about Consumer’s listed on previous Section 3, to our affiliates, group companies and service providers for the business purposes as described below. We have not, however, sold Consumers Personal Information to third parties.
(i) To fulfill the purpose for which the Personal Information is provided.
(ii) To communicate with Consumers and provide them information and answer their requests and inquiries.
(iii) To operate our business; execute the existing contractual relationship with Consumers, suppliers, employees and applicants, including the payment of contractual obligations. (iv) To Provide our services to Consumers and/or products required by Consumers;
(v) To follow up with our services (e-mail or phone inquiries) Inform about new products or services and / or about changes in products and/or services.
(vi) Evaluate the quality of our services.
(vii) To conduct surveys.
(viii) Develop the process of Consumer registration and project management;
(ix) To provide Consumers with e-mail alerts, event registrations, and other notices concerning COR’s activities, or events and/or news that might be of interest to Consumers;
(x) To administer and improve the functionality of our Platform and its technical and functional management;
(xi) To analyze, develop and improve the use and performance of our Platform/s;
(xii) As necessary and appropriate to protect COR’s, Consumer’s rights and/or property;
(xiii) To manage the security of our Platform/s;
(xiv) To comply with applicable law and regulations to operate our business;
(xv) To answer to law enforcement requests as required by applicable law, court order, or governmental regulations;
(xvi) Support internal or external audit processes.
Please bear in mind that the Personal Information we collect also allows us to keep Consumers posted on COR’s latest announcements, updates, and upcoming events. Also, to customize the content and advertising that Consumers see in our Platform, personalizing Consumer’s experience and allowing us to deliver the type of content and service and/or product offerings they are most interested in and to send periodic e-mails regarding our products and/or services. In the event Consumer’s subscribe to any services or communications offered by COR, such as advertisements or newsletters, they are entitled to unsubscribe at any time by following the instructions included in such communications. If Consumer doesn’t want to be on our e-mailing list, it can opt-out anytime by sending us an e-mail to: marketing@projectcor.com.
We do not process special categories of Personal Data; this is Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, genetic data, biometric data processed for the purpose of uniquely identifying a natural person, data related to health or data related to sexual life or sexual orientation of a natural person.
We rely on the following legal bases to collect and process Consumer’s Personal Data under Applicable Data Protection Laws, as it corresponds:
Consent: where Consumers have provided their consent for the processing of their Personal Data for a specific purpose.
Performance of a Contract: where processing is necessary for the performance of a contract with Consumers or taking steps prior entering a contract with any of them for the provisions of our services.
Legal obligation: where we have a legal obligation to process Consumer’s Personal Data, for example when answering to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law.
Legitimate interest: to satisfy a legitimate interest, for example when it is not required by law, but it clearly benefits the Consumers.
Cookies are small files that a Platform or its service provider transfers to Consumers computer’s hard drive through their web browser (if they allow) that enables the Platform’s or service provider’s systems to recognize their browser and capture and remember certain information. For instance, we use cookies to understand Consumer’s preferences based on previous or current Platform/s activity, which enables us to provide them with improved services. We also use cookies to help us compile aggregate data about Platform/s traffic, and Platform/s interaction so that we can offer better Platform experiences and tools in the future.
We classify cookies in the following categories:
We may use web beacons are very small graphic image or object embedded in our web page or e-mail) to collect information about Consumers online actions, visits to our Platform/s, and activity.
(i) Understand and save Consumer’s preferences for future visits.
(ii) Compile aggregate data about Platform traffic and Platform interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
In Consumer’s browser
Consumer’s may modify or withdraw their consent for the use of Cookies at any time. If Consumer do not want to receive cookies anymore, Consumer may use their web browser either to accept them, reject or personalize them. For such purpose, Consumer must follow the instructions on their web browser. If Consumer sets its browser to reject Cookies, Consumer may not be able to use all COR’s functions in the Platform.
In Consumer’s devices
In Consumer’s mobile device, the operative system (IOS) offers options for avoiding personalized advertising -both in IOS and Android- to limit the use of information with the use of apps to generate advertisement based on your interests and tastes.
Please be aware that advertisers and our partners may also use their own cookies and beacons, and unluckily we do not held control for the information they collect. In such cases, Consumer will need to refer to their Privacy Policies. These third parties may use the information collected to serve more relevant advertisements. To configure Consumer’s cookie controls and reject advertising cookies, including third-party cookies, Consumer shall follow the instructions on their mobile device.
Under current privacy laws and regulations, Consumers are given certain rights in relation to their Personal Data. Accordingly, we are glad to offer them with security, transparency, and access control to their Personal Data as available, and with the exceptions set forth on applicable laws and regulations.
Under the GDPR:
If Consumer is resident from the European Economic Area (EEA) or the UK, it has the following rights regarding their Personal Data:
Right of access: Consumer has the right to be informed and request access to the Personal Data we have collected and process about itself.
Right to rectification: Consumer has the right to request the rectification of inaccurate Personal Data concerning Consumer, which must be duly amended or updated without undue delay.
Right to erasure: Consumer has the right to request we delete its Personal Data.
Right to restriction of processing: Consumer has the right to request us to prevent from processing its Personal Data, either all or some of its Personal Data, temporarily or permanently.
Right to data portability: Consumer has the right to request a copy of its Personal Data in electronic format and the right to transmit such data to another controller.
Right to object: Consumer has the right, at any time, to object us from processing its Personal Data on grounds relating to its situation, and the right to object for its Personal Data to be processed for direct marketing purposes.
Right not to be subject of automated decision making: Consumer has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning Consumer or similarly significantly affects Consumer.
For exercising any of the aforementioned rights, please contact us or emailing us at legals@projectcor.com or at the following number +1(650)741-1254.
Under CCPA
If you are a California resident, CCPA may provide you with additional rights regarding our use of your Personal Information.
Section 3 of this Privacy Policy describes the categories of Personal Information we collect, use and disclose, and/or have collected, used and disclosed from Consumers for the preceding 12 (twelve months); the sources from which we obtain each category of Personal Information, and the purposes for which we obtain such Personal Information.
This section describes Consumers rights under the CCPA and how for Consumer to exercise those rights.
If Consumer is a resident of the state of California, USA, it may exercise the following additional rights under the CCPA:
RIGHT TO KNOW the specific pieces of Personal Information about Consumer we collect, use, disclose or sell, or have collected, used, disclosed, or sold:
Consumer has the right to KNOW the specific pieces of Personal Information we collect, use, disclose or sell, and have collected, used, disclosed or sold, covering the 12-month period preceding our receipt of a verifiable consumer request.
In particular, Consumer might request for us to disclose:
The categories of personal information collected;
Specific pieces of personal information collected;
The categories of sources from which the business collected personal information;
The purposes for which the business uses the Personal Information;
The categories of third parties with whom the business shares the Personal Information;
To make a verifiable consumer request for information about the Personal Information we have collected about you, for exercising your rights by using our Contact Form https://cor.zendesk.com/hc/es/requests/newor emailing us at legals@projectcor.com or at the following number +1(650)741-1254.
RIGHT TO DELETE your Personal Information.
Consumer also has the right to request that we delete their Personal Information, subject to certain exceptions, according to Applicable Data Protection Laws. You may exercise your right by accessing our Contact Form at the following link https://cor.zendesk.com/hc/es/requests/newand typing in the message box “I want to permanently delete my data” or emailing us at legals@projectcor.com or contacting us at the following number +1(650)741-1254.
We may deny your deletion request if retaining the personal Information is necessary for us or our service provider(s) to:
Complete the transaction for which We collected the Personal Information, provide a service that You requested our You may request given the nature of our business relationship, or otherwise perform our contract with You.
Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech or another right provided by law, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and to otherwise use internally, the Personal Information in a lawful manner that is compatible with the context in which the consumer provided the information.
Comply with a legal obligation.
RIGHT TO RECEIVE A COPY of your Personal Information:
Consumer has the right to request a copy of the Personal Information collected by COR. Consumer may exercise its right by using our Contact Form at the following link https://cor.zendesk.com/hc/es/requests/newand typing in the message box “I want to receive a copy of my Personal Information” or emailing us at legals@projectcor.com or contacting us at the following number +1(650)741-1254.
RIGHT TO NON-DISCRIMINATION:
You have the right not to be discriminated by us; this is: us denying you our services or charging you a different price or rate for our services, amongst others, as a consequence of you having exercised any of your consumer rights under the CCPA.
You may exercise any of your rights under the CCPA by submitting your request for information required to be disclosed and/or deleted by accessing our Contact Form at the following link https://cor.zendesk.com/hc/es/requests/newor emailing us at legals@projectcor.com or contacting us at the following number +1(650)741-1254.
As described above, to exercises your rights, Consumer shall submit a verifiable consumer request.
When receiving a verifiable consumer request, we will verify the person making a request is the Consumer about whom we have collected the Personal Information. We will generally avoid requesting additional information for the Consumer’s purpose of verification. However, if we if we cannot verify the identity of the Consumer from the information we maintain, we may request certain additional Personal Information, that will be only used for the purposes of verifying the Consumer’s identity. We will address the Consumer verifiable request in an appropriate manner, pursuant to provisions set forth on the CCPA.
Provided Consumer have a password-protected account with us, we may verify your identity, by authenticating you through that account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Requests made through authorized agents: Please note that under the CCPA, Consumer also may designate in witting or through a power of attorney an authorized agent to make the request on their behalf and exercise their privacy rights. Before accepting their agent’s request, we will take all steps necessary to verify Consumer has duly authorized him/her to act on their behalf, for which they must provide us in writing a signed authorization or copy of a power of attorney.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Under CCPA, we endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform Consumer of the reason and extension period in writing.
If Consumer has an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by e-mail or electronically, at your option.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We’re proud to have you as a Consumer and will continue working hard to maintain the highest level of transparency, security, and trust. And if you have any questions or concerns, don’t hesitate to reach out and let us know.
We may share Consumer’s Personal Data globally with our affiliates, subsidiaries and group companies to carry out our activities, specified in this Privacy Policy. Also, we may share Personal Data with, or subcontract processing, with third parties located in different countries than their country.
In this regard, we may share Consumer’s Personal Information with:
our affiliates: to provide our services and/or products;
our service providers: that help us conduct our business and support infrastructure;
advertising partners;
For business transfers: we share Consumer’s Personal Data in those cases where we sell or negotiate to sell our business to a buyer or potential buyer. In this case, we will continue to ensure the security and confidentiality of the Personal Data, and give Candidate’s and/or Companies’ notice before their Personal Data is transferred to a buyer or becomes subject to a different privacy policy;
Others Third Parties admitted under the Applicable Data Protection Laws, for the purposes and legal basis indicated in Sections 4 and 5 of this Privacy Policy.
In some cases, our affiliates, subsidiaries, and/or third-party service providers are located in other countries, meaning that Consumer’s Personal Information may be processed or stored in other countries. In certain circumstances, our affiliates, subsidiaries, and/or service providers may be required to disclose information to government authorities, regulators, courts, or law enforcement in those countries.
When Consumer’s Personal Data is transferred internationally to third parties located in territories which may not offer an equivalent level of protection to privacy as that applicable within their country of residence (Personal Data collected within the European Economic Area (EEA), for example may be transferred to be processed by third countries located outside the EEA), we ensure that the transfer of the Personal Data is carried out in accordance with the terms of Applicable Data Protection Laws.
We will take all the necessary steps to verify that Consumer’s Personal Data receives an “adequate level of protection” or substantially equal (where required by local law) level of protection. This, by requesting their express consent to the transfer pursuant to applicable law, and/or entering into Data Transfer Agreements (“DTA’s”) pursuant to applicable law, such as the Model Clauses of EU Directive 87/2010, valid as set forth by Section 47 of the GDPR, or Corporate Binding Rules as an option to the referred DTA’s, when the international transfer of Personal Data is made amongst companies of the same economic group, to countries that do not count with an adequate level of protection in accordance to the terms of applicable law.
In any event, we will apply appropriate technical and organizational safety measures to the transfer of Personal Data, so as to ensure that data importers comply with the Applicable Personal Data Laws and use the Personal Data for the sole purposes for which the Personal Data is transferred.
We may display advertisements from third parties and other content in our Platform that may link you to third parties’ Platforms. We cannot control nor held responsible for such content and third party’s privacy policies. If you click and access a third-party advertisement or link, please understand that you are leaving COR, and any Personal Data you provided will not be covered by this Privacy Policy.
Please refer to the third-party Privacy Policies to find out how they collect and process your Personal Data.
We will keep Consumer’s Personal Data as long as necessary to fulfill the purposes described herein.
Upon Consumers’ request, we will delete their Personal Data, unless we are allowed or required to keep certain Personal Data, for example to fulfill a legal obligation or to resolve a dispute, etc.
We are firmly committed with the security of Consumer’s Personal Data. We will make our best efforts to protect your Personal Data, by implementing adequate technical, physical, administrative, and organizational measures, in order to guarantee the security of Consumer’s Personal Information.
However, please be advised that no system is ever a complete secured system, Consumers can always decide not to use our products and/or services.
We also encourage Consumers to take all possible measures to secure their Personal Data by using a safe strong password, never sharing their password with others, logging out of the account immediately after having use the account, amongst others.
Despite our best efforts to guarantee the maximum possible level security of Consumers information by adopting technical and organizational measures to contribute to the security of their data, provided we suffer a data breach, we will take all necessary measures to reduce its effects.
In accordance with the terms of Applicable Data Protection Laws accordingly, without undue delay and, where feasible, after having become aware of it, we will notify the Personal Data breach to the supervisory authority and/or to the Consumer’s, as appropriate under the terms of Applicable Data Protection Laws.
The CCPA gives California residents the right to opt-out from the sale of Personal Information. We do not sell nor have sold information that directly identifies Consumer’s. We do not exchange information about Consumer’s to third parties in exchange for money or other consideration. We share information with third parties who work with us, as explained on previous sections, for the purposes described herein.
However, due to the broad definition of “sale” of Personal Information under CCPA, including the provision of Personal Information to another business or third party for monetary and other valuable consideration, shall Applicant and/or Companies prefer for us not to sell their Personal Information, please access the following Contact Form link https://cor.zendesk.com/hc/es/requests/newand type in the message box “DO NOT SELL MY PERSONAL INFORMATION” in order to opt-out of the future sale of your Personal Information or email us at legals@projectcor.com or contact us at the following number +1(650)741-1254.
Services rendered by COR shall only be available for persons with legal capacity to enter into contracts under applicable laws. Thus, should you not meet this requirement, you shall not provide us with your Personal Data.
Our services are not directed to children under the age of 13 years, or from ages from 13 to 16, or equivalent minimum age in the relevant jurisdiction. If you are under the age limit of 13 years, or from 13 to 16 years old, please do not use our services and do not provide us with any Personal Data or information.
We will not collect, process nor sell the Personal Information of Consumer’s under 13 years of age, or from 13 to 16 years, if we have actual knowledge that the Consumer is less than those years of age.
All Personal Data provided to COR shall be safely stored. COR shall store Consumer’s Personal Data in secured servers.
We may make changes to this Privacy Policy periodically. We shall give notice of any changes to Consumer’s Companies through the usual means of communication, such as the email. Notwithstanding the aforementioned, Consumer’s undertake the obligation to regularly access this Privacy Policy and search for any amendments hereto.
Should Consumers have any privacy-related queries or comments, or regarding this Privacy Policy they shall contact us at: legals@projectcor.com, and including the following information: consumer’s name and surname, ID, e-mail address, telephone number and domicile.
Last updated: November 2021