How Cowe Processes Your Personal Information

Data protection laws and privacy laws in certain jurisdictions, like the European Economic Area (EEA), differentiate between “controllers” and “processors” of personal information. A controller decides why and how to process personal information.

A processor processes personal information on behalf of a controller based on the controller’s instructions. When Cowe processes your Customer Account Data, the Cowe entity with whom you are contracting is acting as a controller.

Broadly speaking, we use Customer Account Data to further our legitimate interests to:

• understand who our customers and potential customers are and their interests in Cowe’s product and services,
• manage our relationship with you and other customers,
• carry out core business operations such as accounting, filing taxes, and fulfilling regulatory obligations and
• help detect, prevent, or investigate security incidents, fraud and other abuse and/or misuse of our products and services.

 

What Personal Information Cowe collects

We collect and process your personal information:

When you visit a Cowe public-facing websito or make a request to receive information about Cowe or our products, like a Cowe whitepaper or a newsletter;
When you contact our Sales Team or Customer Support Team; and
When you sign up for a Cowe product or service;
We call this personal information Customer Account Data. We also collect Customer Usage Data from you when you send or receive communications through your use of our services. This data might take different forms, and we might use it for different purposes — read on for more information.

Depending on your interactions with us, we might collect the following categories of personal information, and for the following reasons:

• We collect Identifiers, like your name and contact information (Customer Account Data), when you sign up or use our products or services and to do things like allow you to use our products, verify your identity, and communicate with you.
• We collect Commercial information when we keep track of the services that you purchase from us and our communications history about those services.
• We collect Financial information, such as your payment information, when you pay for our services.
• We collect Internet and other electronic activity information, such as communications metadata, as you interact with our website or use our services. This metadata may be information about how you interact with our websites and the information on them; what features you use on our service; or it may be your Customer Usage Data as you send communications over the service.
• We collect Geolocation information when you use our products or services. Depending on the product or service, this could be location based on your IP address, or, such as if you are using our IoT products and services, based on the cell tower to which a mobile device is connected, or Wi-Fi triangulation.
• We collect Professional or employment information, such as your company or employer or your role at your company.
• If you attend an event or fill out a form or survey with us, we might collect your age, your gender, or other information that counts as characteristics of protected classifications; however, we will only collect those with your knowledge and opt-in consent.

You can always read more in our API documentation about how we treat personal information we process using our service.

When we’re processing your personal information as our customer, we’re generally processing Customer Account Data or Customer Usage Data. When we do, we’re a controller, as we described above, and this Privacy Statement details the rules that control our use of that data.

In addition, as a processor and a service provider, we process Customer Content that may include personal information from any of those categories, plus others. If you’re an end user of a customer of ours, our customer will be able to help you with more details on what categories they’re collecting and using. If you’re our customer, you can read more about our responsibilities as a service provider in our CCPA ad GDPR Notice.

What Customer Account Data Cowe Processes When You Visit Our Website, Sign Up for a Cowe Event, or Make a Request for Information About Cowe and Why
When you visit our website, sign up for a Cowe event or request more information about Cowe, we collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form, to learn more about who is interested in our products and services, and to improve navigation experience on our pages.

Information You Share Directly:

In some places on Cowe’s public-facing websites, you can fill out web forms to ask to be contacted by our Sales Team, sign up for a newsletter, register for a Cowe event, or take a survey. The specific personal information requested on these forms will vary based on the purpose of the form. We will ask you for information necessary for us to provide you with what you request through the form (for example, we will ask you for your email address if you want to sign up for an email newsletter and for your phone number if you want a member of our Sales Team to call you). We may also ask you for additional information to help us understand you better as a customer like your Cowe use case, your company name, or your role at your company. If you sign up to receive ongoing marketing communications from Cowe, like a newsletter, you can always choose to opt out of further communications through a preferences page which will be linked from any marketing email you receive from Cowe. You can also contact our Customer Support Team to communicate your choice to opt out.

Information We Collect Automatically:

When you visit Cowe websites, including our web forms, we and our service providers acting on our behalf automatically collect certain information using tracking technologies like cookies, web beacons, and similar technologies. We use this information to understand how visitors to our websites are using them and which pages and features of the websites are most popular. This helps us understand how we can improve our websites and track performance of our advertisements. In addition, we use tracking technologies to help improve the navigation experience on Cowe websites. We don’t sell this information to third parties, though. For more details on our use of cookies and tracking technologies, please see our Cookie Notice.

What Customer Account Data Cowe Processes When You Communicate with Our Sales or Customer Support Teams and Why:

You may share personal information, like your contact information, with a member of our Sales or Customer Support Team when you communicate with them. We keep a record of this interaction.

If you contact our Sales or Customer Support Teams, those teams keep a record of that communication, including your contact details and other information you share during the course of the communication. We store this information to help us keep track of the inquiries we receive from you and from customers generally so we can improve our products and services and provide training to team members. This information also helps our teams manage our ongoing relationships with our customers. Because we store a record of these communications, please be thoughtful about what information you share with our Sales and Customer Support Teams. While we will take appropriate measures to protect any sensitive information you share with us, it is best to avoid sharing any personal or other sensitive information in these communications not necessary for these teams to assist you.

What Customer Account Data Cowe Processes When You Sign Up for and Log Into a Cowe Account and Why:

When you sign up for an account with us, we ask for certain information like your contact details and billing information so we can communicate with you and so you can pay for our products and services. We also collect some information automatically, like your IP address, when you log in to your account or when your software application built on Cowe makes requests to our APIs. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.

Information You Share Directly:

When you sign up for a Cowe account with us, you’ll be asked to give us your name, email address, and optionally, your company name, and to create a password. You can also name your account (or accounts, if you have more than one). We collect this information so we know who you are, we can communicate with you about your account(s), and we can recognize you when you communicate with us through the account portal or otherwise.

When you sign up for a Cowe account, we ask you for a username, email address, and ask you to create a password. Similarly, we collect this information so we can identify you on our service, provide the service to you, communicate with you about your account, and recognize you when you communicate with us.

We also use your email address to send you information about other Cowe products, services or events in which we think you may be interested. You can opt out of further marketing communications through your marketing preferences page linked from any marketing email you receive from Cowe. Or, you can contact our Customer Support Team to communicate your choice to opt-out.

When you first sign up for an account, we also ask you for a telephone number so we can communicate a verification code to that telephone number and have you enter the code into our website. This helps us ensure you’re actually a human being. A Cowe team member may also contact you at this number to help you with onboarding unless you tell us you don’t want us to contact you.

When you set up two-factor authentication for your account, we’ll ask you to enter a telephone number to set up the process. You have the option to use that telephone number as the method for us to communicate verification codes to you to verify that it is you logging into your account. 

When you upgrade your trial account, we’ll ask you to provide our payment processor with your payment method information like a credit card or your Paypal account, and/or your billing address. Our payment processor, acting on our behalf, gathers this so we can bill you for your use of our products and services. Our payment processor will share your billing address with Cowe. Your billing address may also be used by Cowe for tax calculation and audit purposes.

For some products, we may also obtain a physical address from you that includes a proof of address, name, or other identification information. For example, to conduct certain marketing activities in certain countries, local law may require us to have a physical service address on file for the individual who will be using that Cowe product or service, whether that’s you or your end user, and/or proof of identity and physical service address. We call these “subscriber records.”

We may have to share subscriber records with the local telecommunications carrier that provides local connectivity services or with local government authorities. We may also use this physical service address for tax purposes.

Similarly, for some of our products, you or your end user, whoever is going to be making use of the product, may have to complete an application form providing details about your company and your intended use of the product, like when you are interested in getting a short code. We’ll use this information for the purpose for which it was gathered from you. We may also use it in connection with improving our own internal processes and services or training our team members.

Information We Generate or Collect Automatically:

When you sign up for an account with Cowe, we’ll automatically assign you and your account(s) unique IDs called SIDs and we’ll automatically generate an API token for each of your accounts. These are used like a username and password to make API requests. Instead of using these API tokens, you can provision API Keys, and use your API key for authentication when making requests to our APIs. We keep a record of these credentials so we know it is you making the requests when your application makes requests to our API using these credentials.

In addition, when you use our account portal, we collect your IP address and other data through tracking technologies like cookies, web beacons, and similar technologies. We use this information to understand how customers are using our platform, who those customers are (if they are a company and the IP address is associated with that company), what country they are logging in from (for analytics and export control purposes), and to help improve the navigation experience. 

Note that we also collect the IP address of your devices or servers when you make requests to our APIs. When you use our APIs, we also collect and process the information contained in those interactions. For more information about how personal information is processed in that context, see the section below on “How Cowe Processes End Users’ Personal Information” and our API Docs.

All information we collect when you sign up for a Cowe account and interact with the Cowe account portal or our products or services may be used to detect, prevent, or investigate security incidents, fraud, or abuse and misuse of our platform and services. We will also use it, and share it with our service providers, as needed for our operational purposes — such as to do things to function as a business and provide our services to you.

Other Customer Account Data We Collect and Why

We may collect information about you, as our customer, from publicly-available sources so we can understand our customer base better.

We may use publicly-available information about you through services like LinkedIn, or we may obtain information about your company from third party providers to help us understand our customer base better, such as your industry, the size of your company, and your company’s website URL.

How Long We Store Your Customer Account Data

Cowe will store your Customer Account Data as long as needed to provide you with our services and to operate our business. If you ask Cowe to delete specific personal information from your Customer Account Data (see ‘How To Make Choices About Your Customer Account Data’ below), we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.

Here is an overview of how long we hold on to Customer Account Data in a form that can be used to identify you, unless there is a specific need or obligation to retain your information longer (like in the case of an open investigation, audit or other legal matter):

Customer Account Data stored in our customer relationship management system(s) is generally stored up to 7 years following closure of your account. Invoice records, including their digital equivalent, may be retained in identifying form by Cowe for longer periods for accounting, tax, and audit purposes depending on and in accordance with applicable law.

Similarly, where we collect subscriber records, such as a physical address or identity information, in connection with providing our communications products and services, we will retain this data as needed for legal, security and anti-fraud purposes and depending on and in accordance with applicable local law.

We may retain your communications with Cowe’s Customer Support Teams for up to 3 years after your account is closed.
Apart from the above, within 60 days following closure of your account, we will either delete other Customer Account Data or transform it such that it can no longer be used to identify you.

How To Make Choices About Your Customer Account Data

You can make various choices about your Customer Account Data through the account portal, such as accessing it, correcting it, deleting it, or updating your choices about how it is used, when you log into your Cowe account or through the marketing preferences center. Any other requests about your data you cannot make through these self-service tools, you can request by contacting Customer Support.

Closing Your Account and Deletion

To request closure or deletion of your Cowe account, you can contact Customer Support or cancel your Cowe subscription, although canceling will not automatically delete your Cowe account. You should know that closure and/or deletion of your Cowe account will result in you permanently losing access to your account and data in the account. Please note that certain information associated with your account may nonetheless remain on Cowe’s servers in an aggregated form that does not identify you or your end users. Similarly, data, including personal information, associated with your account we are required to maintain for legal purposes or for necessary business operations (see “How Long We Store Your Customer Account Data” section above) will be retained after account closure until no longer needed.

Promotional Communications

You can choose not to receive promotional emails from Cowe by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting Customer Support. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to things like updates to our terms of service or privacy notices, security alerts, and other notices relating to your access to or use of our products and services.

Cookies and Tracking Technologies. How you make choices about cookies and other tracking technologies depends on the type of cookie or tracking technology being used. For details on how to manage your preferences for cookies and tracking technologies, please check out our Cookie Notice.

Other Choices About Your Customer Account Data. In addition, you can express other choices about your Customer Account Data (i.e., accessing it, deleting it, restricting its use, porting it, or withdrawing consent for its use) by contacting our customer support team.

If you are an end user of an application built on Cowe’s platform and not a direct customer of Cowe, you should direct requests relating to your personal information to the relevant application provider in accordance with the application provider’s own privacy policy.

California Consumer Access and Deletion Rights

For those customers that would like more information about our use of Customer Account Data or Customer Usage Data, you have the ability to request:

• that we provide details about the categories of personal information that we collect about you, including how we collect and share it;
• that we provide you access to the personal information we collect about you; and
• that we delete the personal information we have about you.
• Please be aware that when you ask us for these things, we will take steps to verify that you are authorized to make the request.

As part of the services we provide to our customers, we provide you with a number of self-service features at no additional cost, including the ability to access your data, download a copy of your data, delete your data, or restrict the use of your data. If you need more help than that, let our Support team know; we will provide reasonable and timely assistance to assist you.

Please keep in mind that when you ask us for your personal information, or you ask us to delete your personal information, we may need to withhold or retain some of that personal information for security, legal, or anti-fraud reasons. Also, we do need some of the Customer Account Data and Customer Usage Data we have to maintain customer accounts. If you ask us to delete that information, we may not be able to continue providing you our services. This also means that we won’t be able to provide access to or delete information about customers who are the point of contact for businesses that use our services. If you would like to request access or deletion, you may contact our Support team.

How Cowe Processes Your End Users’ Personal Information

Your end users’ personal information typically shows up on Cowe’s platform in a few different ways:

• Communications-related personal information about your end users, like your end users’ phone numbers for number-based communications, your end users’ email addresses for email communications, IP addresses for IP-based communications, device status (indicating whether a device is available for messaging), or device tokens for push notifications, show up in our systems when you use or intend to use this information to contact your end user through use of our products and services.
• Your end users’ personal information may show up in “friendly names,” which are strings you provide, if you choose to include your end users’ personal information as part of a string.
• Your end users’ personal information may also be contained in the content of communications you (or your end users) send or receive using Cowe’s products and services.

We call the information in the first two bullets above Customer Usage Data. The information in the third bullet is what we refer to as Customer Content.

As noted above, data protection law (including privacy law) in certain jurisdictions, like the EEA, differentiate between “controllers” and “processors” of personal information. When Cowe processes Customer Content, we generally act as a processor. When we process Customer Usage Data, we act as a processor in many respects, but we may act as a controller in others. For example, we may need to use certain Customer Usage Data for the legitimate interests of billing, reconciling invoices with telecommunications carriers, and in the context of troubleshooting and detecting problems with the network.

What Customer Usage Data and Customer Content Cowe Processes and Why

We use Customer Usage Data and Customer Content to provide services to you and to carry out necessary functions of our business as a communications service provider. We do not sell your end users’ personal information and we do not share your end users’ information with third parties for those third parties’ own business interests.

The particular end user personal information Cowe processes when you, our customer, use our products and services and the reason Cowe processes depends on how you use our products and services and which Cowe products and services you use. For that reason, our API docs for each of our products and services are the best place to find information about our processing of personal information when you use that Cowe product and service.

In many cases, you can opt to store records of your communications, or other activities, on Cowe, which may include your end users’ personal information. You may also have the option to use additional features or tools within Cowe’s products or services that allow you to do things such as analyze the records, including end user personal information, in your Cowe account. In those cases, Cowe will process this information to provide you with the service you request.

In addition, records containing end user personal information may, from time to time, also be used in debugging or troubleshooting or in connection with investigations of security incidents, as well as for the purposes of detecting and preventing spam or fraudulent activity, and detecting and preventing network exploits and abuse. It may also be anonymized, as allowed by law, and we may use data that can no longer identify you or relate to you for our legitimate business needs.

How Long Do We Store Customer Usage Data and Customer Content and Exercising Choices About End User Personal Information

Details regarding how long your end user personal information may be stored on Cowe systems and how to delete, access, or exercise other choices about end user data will depend on which Cowe products and services you are using and how you are using them. For that reason, our API docs for each of our products and services, are the best place to find more detailed information about managing end user data collected and stored in connection with your use of our products and services, as well as the particular data retention periods for your use case.

As a Cowe customer, if the Cowe product or service you use enables you to store records of your usage on Cowe, including personal information contained within those records, and you choose to do so, then Cowe will retain these records for as long you instruct. In some cases, use of extended storage may cost more. If you later instruct us to delete those records, we will do so. Please note that it may take up to 30 days for the data to be completely removed from all systems. In some cases, a copy of those records, including the personal information contained in them, may nonetheless be retained to carry out necessary functions like billing, invoice reconciliation, troubleshooting, and detecting, preventing, and investigating spam, fraudulent activity, and network exploits and abuse. Sometimes legal matters arise that also require us to preserve records, including those containing personal information. These matters include litigation, law enforcement requests, or government investigations. If we have to do this, we will delete the impacted records when no longer legally obligated to retain them. We may, however, retain or use records after they have been anonymized, if the law allows.

When and Why We Share Your Personal Information Or Your End Users’ Personal Information

We do not sell or allow your Customer Account Data to be used by third parties for their own marketing purposes, unless you ask us to do this or give us your consent to do this. Further, we do not sell your end users’ personal information. We also do not share it with third parties for their own marketing or other purposes, unless you instruct us to do so. You can read more in our CCPA Notice.

Below are the different scenarios under which we may share your data with third parties:

Telephony operators as necessary for proper routing and connectivity. Cowe provides an easier way for developers to build applications that make use of the publicly switched telephone network (PSTN) to send communications. Therefore, communications-related data is shared with and received from telephony operators as necessary to route and connect those communications from the sender to the intended recipient. How those telephony operators handle this data is generally determined by those operators’ own policies and local regulations.

Other communications service providers for proper routing and connectivity:

Cowe also enables sending or receiving communications through communications service providers that do not use the PSTN, such as WhatsApp and Facebook Messenger (referred to as Over-the-Top (OTT) communications service providers). If you choose to use Cowe to send or receive communications by way of these providers, Cowe will share communications data with these providers as necessary to route and connect those communications from the sender to the intended recipient. How those OTT communications service providers handle this data is determined by their own policies.

Third-party service providers or consultants:

Cowe engages certain third-party service providers to carry out certain data processing functions on our behalf. These providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances they will appropriately safeguard the data. In addition, Cowe uses advanced algorithms to detect and prevent fraudulent activity on our network. We may work with undisclosed partners to enhance this service, but we will never disclose personal information except for information that will help us detect and mitigate risk in the future. Once we have identified and mitigated the risk and fingerprint ID will be used to track future risk in an anonymised technique to prevent personal data from being comprimised.  

Sub-processors:

We may share Customer Content with sub-processors who assist in providing the Cowe services, like our infrastructure provider, or as necessary to provide optional functionality like transcriptions. An up-to-date list of Cowe's sub-processors is located here.

Compliance with Legal Obligations:

We may disclose your or your end users’ personal information to a third party if (i) we reasonably believe that disclosure is compelled by applicable law, regulation, legal process, or a government request (including to meet national security, emergency services, or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. If Cowe is required by law to disclose any personal information of you or your end user, we will notify you of the disclosure requirement, unless prohibited by law. Further, we object to requests we do not believe were issued properly. You can read more in our Law Enforcement Guidelines.

Other Cowe Group Entities:

We may share your personal information or your end users’ personal information within the Cowe group of companies, such as with a subsidiary of Cowe Inc. We and our subsidiaries will only use the information as described in this notice.

Business transfers:

If we go through a corporate sale, merger, reorganization, dissolution or similar event, data we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. In that situation, and that situation only, we might transfer your data in a way that constitutes a sale under applicable law. If we do, we’ll let you know ahead of time, and any acquirer or successor of Cowe may continue to process data consistent with this notice.

Aggregated or de-identified data:

We might also share data with third parties if the data has been de-identified or aggregated in a way so it cannot be used to identify you or your end users.

If you’re a Californian interested in what personal information we have shared lately for our business purposes, here’s a list:

• Identifiers
• Commercial information
• Financial information
• Internet or other electronic activity information
• Geolocation information
• Professional or employment information

By “our business purposes,” we mean that we only share personal information as we describe in this section (in other words, with telephony operators, communications providers, and so on).

Transfers of Personal Information Out of the EEA and Switzerland

When you use our account portal, or our other products and services, personal information of you and your end users processed by Cowe may be transferred to the United States, where our primary processing facilities are located, and possibly to other countries where we or our service providers operate. These transfers will often be made in connection with routing your communications in the most efficient way.

Cowe employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law, including Binding Corporate Rules and Standard Contractual Clauses.

While Cowe relies on strong transfer mechanisms to protect the data we transfer across borders, we understand that data transfer mechanisms do not operate in a vacuum. You can read more about the appropriate technical and operational safeguards Cowe has taken to safeguard our customers' personal data. But first, an overview of our transfer mechanisms.

Standard Contractual Clauses:

We rely instead on other safeguards to transfer personal information outside the EEA and Switzerland, such as European Union Model Clauses, also known as Standard Contractual Clauses.

Data Collection and Email

Cowe Marketing Platform services collect the same data the Cowe services collect, and for the same reasons. The CMP services also collect some additional data in the form of web beacons placed in the body of emails delivered using the CMP platform. This allows us to keep track of whether or not an email has been delivered, opened, clicked on, whether it bounced or was treated as spam. You may learn more about these web beacons on our Website Navigational Information page.

Customer Content and Email Recipients’ Personal Information:

Like other Cowe services, CMP is a data processor for Customer Content, like email communications contents and the contents of marketing campaigns. CMP is also a data processor for email recipients’ email addresses and other recipients’ personal information.

Data Subject Rights and Opt Outs

CMP takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. You can manage, access, or delete many of your account and profile settings within the dashboard provided through the CMP platform, including, in some instances, your end users’ personal information.

Additionally, you can opt out of receiving marketing emails from us at any time by clicking the 'unsubscribe' link at the bottom of our marketing messages. Please note that it may take up to three days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request. You will not be able to opt out of service emails from us, such as billing emails, unless you deactivate your account.

Automated Decision Making:

Cowe may use automated decision making using a variety of signals derived from account activity to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity. Holders of accounts suspended under these circumstances are notified of the suspension and given an opportunity to request human review of the suspension decision.

Handling disputes relating to our data protection practices:

We hope we can resolve any disputes relating to our data protection practices between us. You can raise your concern or dispute by writing to us.

How We Secure Personal Information

We use appropriate technical and organizational measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place.

Please note that no service is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

To protect the confidentiality of your account and protect from unauthorized use of your account, we two factor authentication is enabled by default. Additionally, you must keep your account password and Auth Token confidential and not disclose them publicly or to unauthorized individuals — this includes accidentally distributing them in a binary or checking them into source control. Please let us know right away if you think your password or Auth Token was compromised or misused. For instructions on changing your password and other security details please visit https://support.cowe.io