We, CoTripper, explain in this Privacy and Cookie Policy (the “Policy”) how we collect, process and/or use information that we receive via our websites, emails we send, and mobile applications (collectively, the “Platform”) that link to this Policy, as amended from time to time. This Policy describes how CoTripper collects, processes, uses, shares, and secures the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.

This Policy applies only to information we collect, process, and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us.

For the purposes of this Policy, “CoTripper,” “we,” or “us” shall mean Harpcan, a Delaware LLC.

Please read this Policy carefully to understand our policies and practices regarding your information and how it will be used in the services we provide through the Platform.

By using the Platform, you understand and agree that we are providing services for you to post content to the Platform including, but not limited to, audio, video, images, photographs, text, and any other data included in any other user-generated content that may be collected and uploaded by you, us, or third-party partners (including interviews, interview meta-data and comments) (collectively, “Content”). At your election, other users of the Platform, including
your family members (when you join a Group, as defined in our Terms of Use) may search for, see, use, or share your Content that you make available through the Platform, consistent with the terms of this Policy and our Terms of Use. In certain instances, and at your discretion, we may work with you to publish you or your family’s stories, in which case such Content may become publicly available and searchable.

Information We Collect
We collect information about you to provide our services. As used in this Privacy Policy, “Personally Identifiable Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate a specific individual, such as a name, phone number, email address, or address. We do not consider Personally Identifiable Information to include information that has been aggregated and/or de- identified so that it does not allow a third party to easily identify a specific individual. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.

Information You Give Us

Categories and examples of information you may provide include the following:
• Profile or contact information such as name, email address, phone number, and photograph, as well as other information you choose to provide when you sign up for an account or use our Platform
• Content you provide, such as interviews, messages, comments, feedback, testimonials, and other data you choose to upload or share
• Payment information such as name, credit card number, and billing address in connection with any purchases made directly through our Platform
• Other messaging information in connection with customer service requests and other correspondence

If you connect to the Platform using Facebook, Google+, or another social networking site (each a “Social Networking Site”), we will receive information that you authorize the Social Networking Site to share with us, which may include public profile information, birthday, current city work, school, email address, and other information (including Personally Identifiable Information). When we receive this information, it becomes CoTripper account information for purposes of your use of the Platform. This information also constitutes personal information and is therefore subject to this Policy. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site’s privacy and data practices. You have the ability to disconnect your Social Networking Site account from your CoTripper account by adapting the privacy settings in your Social Networking Site account. If you come to the Platform through a Social Networking Site, from other websites, or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.

Information We Collect from Your Use of the Platform

• Activity. When you use our Platform, we may collect information about your activity on the Platform, such as Content you engage with (including audio and video recording selections, viewing and uploading history), services and features you use, actions you take, people or accounts you interact with, and other usage data.
• Location. When you use our Platform, we may collect information about your location. With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors. You typically can choose to turn such services on or off. If such device-based location services are on, we may receive and record such information, such as the location where you are creating or uploading Content.
• Camera, Photos, and Audio. Some services offered through the Platform allow us to collect images and/or audio from your device, microphone, video, camera, and camera roll. For example, you may upload Content by providing us access to your camera roll for photos and other applications containing the interview audio file.
• IP Address Information and Other Information Collected Automatically. We automatically receive and record certain information from your web browser or our applications when you access and use the Platform, which may include your IP address, cookie information, hardware model, operating system version, unique device identifiers, and mobile network information (including the mobile phone number).
• Information Collected Using Cookies and Web Beacons. “Cookies” are small data files that are sent to your web browser when you access a website, and the files stored on your device’s hard drive. We use “session” cookies to keep you logged in while you use our Platform, to track your preferences, and to track trends and monitor usage and web traffic information on our Platform. We may use “persistent” cookies to relate your use of our Platform to other information about you and store information about your preferences to make your user experience consistent and customized. For example, we may create a persistent cookie that includes some basic information about you, like whether customer support responded to your inquiry. These cookies stay on your hard drive until you erase them or they expire, and they associate your information with your account even if you are logged out. Most browsers automatically accept cookies, but you can change your browser settings to refuse cookies or prompt you before accepting cookies. You can also use your browser settings or other tools to delete cookies you already have. However, if you disable or refuse cookies, then certain features of our Platform may be inaccessible or not function properly. Our cookies do not, by themselves, contain Personally Identifiable Information, and we do not combine the general information collected through cookies with other Personally Identifiable Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Platform and may associate that information with your account if you have one. Certain features of our Platform may use local shared objects (or “flash cookies”). Flash cookies are small files similar to browser cookies that collect and store information about your preferences and where you browse and what you look at on our Platform. Flash cookies are not managed by the same browser or device settings that are used for browser cookies. You may adjust your Adobe Flash Player settings to prevent flash cookies from being placed on your hard drive. We may also use “clear GIFs” (aka “web beacons” or “pixel
tags”) or similar technologies on our Platform or in our communications with you to enable us to know whether you have visited a part of our Platform or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a website or in an email or other type of message, which is retrieved from a remote website on the Internet enabling the verification of an individual’s viewing or receipt of a website or message. We may also log information using digital images called web beacons on our Platform or in our emails. We may use web beacons to manage cookies, count visits, and to assess our marketing practices. We may also use web beacons to tell if you open or act on our emails. This Policy only covers our use of cookies and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.
• Information Collected for Push Notifications. When you access the Platform through a mobile device, you will also be asked to allow push notifications to be sent to you outside or inside of the Platform. If you do so, a device token will be generated, which is associated with you until you log out. We will collect and store these device tokens on our servers.

Do Not Track Browser Setting

We do not track our users across third party websites and thus do not respond to Do Not Track (“DNT”) signals.

Your Privacy Settings

By default, and before you join a Group, any Content that you voluntarily disclose or post to the Platform will only be searchable and accessible by you, and, to the extent necessary to perform its services, by CoTripper. By default, after you join a Group, any Content that you voluntarily disclose or post to the Platform will be searchable and accessible by you, any other member of such Group, and, to the extent necessary to perform its services, by CoTripper. Any Content that you disclose for posting to the Platform and which you elect to share through a Group or make available to the public, will become available to members of such Group or become publicly available and may be re-shared by others, as applicable. So, the same common sense that applies to the internet at large applies to CoTripper and your use of the Platform: when sharing content through a Group or when electing to share content publicly through the Platform, do not send any messages or share any Content that you do not want someone else to access, save, or share.

You may change your privacy settings for your Content through your account to make your Content more or less private.
• Private. Only you can view or access your Content. Your Content will not be accessible by the general public or other users of the Platform if you choose to make such Content private. As noted below, once you join a Group, your Content will automatically be posted to such Group, so make sure that you are comfortable sharing any Content with your Group members before posting or publishing such Content through the Platform.
• Groups. Only people with access to the Groups through which you have shared your Content can view or access such shared Content. Your Group-specific Content will not be accessible by registered users of CoTripper without access to such Groups or by the general public. However, Content shared with a Group may be consumed, displayed, downloaded, and shared by members of the applicable Group, and as a result may be voluntarily or involuntarily made public by members of your Group without your knowledge. Once you have joined a Group, your Content will automatically be posted to such Group, so make sure that you are comfortable sharing any Content with your Group members before posting or publishing such Content through the Platform.
• Public. If you elect to make your Content public, your shared Content may be accessible by anyone in the world. This may be the default setting for an interview hosted by CoTripper or otherwise involving other CoTripper registered users outside of your Groups.

Please note that any Content you post on the Platform is at your own risk. Although we may enable you to set certain privacy settings for such information in your account profile, no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Platform with whom you may choose to share any Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons. Please also note that regardless of your specific privacy settings on your account, your Content may still be accessed and used by CoTripper as described in this Policy, including for purposes of providing and improving our services, customer support, product development, quality assurance, and any other purposes for which you provide consent or we are permitted by law.

How We Use Information

CoTripper is a Platform that connects you with community, content, and shares your family’s stories, and we will use the information we collect to provide you with products and services to further our mission and to improve such products and services. CoTripper will have access to the information on your account (including Personally Identifiable Information) regardless of your Content privacy settings and may use your information to maintain and provide the Platform to you. For example, we may use your information, in either aggregated or individual form, in the following ways:
• to record, archive, and share stories with your family, your Groups, and other people subject to your privacy settings as part of CoTripper’s mission, including by sharing and displaying your username, photograph, location, and, depending on your interview privacy settings, your audio, video, and other content recording and metadata in connection with any Content you upload to the Platform;
• to manage your account preferences, personalize your experience, communicate with you and respond to you regarding the Platform, content, features, and products you use or that we think may interest you, and provide customer service;
• to customize and optimize the content or advertisements you receive or view when you use the Platform, and otherwise improve your experience on our Platform;
• to provide, maintain, protect, analyze, understand, and improve our Platform, content, features and products, which may include tracking traffic, trends, usage, and navigation patterns;
• to develop new products and services;
• for research, development, and educational purposes;
• in any other way we may describe when you provide the information or otherwise consistent with this Policy and our Terms of Use;
• for legal reasons, including, but not limited to, in response to a valid law enforcement request or legal process or to protect our rights and property or those of third parties; and
• for any other purpose with your consent.

How We Share Your Information

We may share your information in the following circumstances:
• Third-Party Service Providers. We may share your information with individuals and third-party companies that perform services on our behalf, including for payment processing, data storage, email and hosting services, data analysis, marketing services, advertising services, and customer services and support.
• Analytics and Data Enrichment Services. We use third- party analytics to help understand your usage of our Platform and to improve our services (e.g., Google Analytics). We may provide your contact information, registration information, technical information, usage data, or de-identified data to data enrichment services, which may match such information with publicly available database information, including contact and social information from other sources, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses.
• Marketing. We do not rent, sell, or share personal information about you with other people or non-affiliated companies for their direct marketing purposes unless we have your permission. Our Platform may allow you to opt-in to receive communications from third parties. If you give us your permission to share your personal information with such third parties, then you may receive communications from such third parties and you are solely responsible for your engagement with such third parties.
• As Required by Law and Similar Disclosure. We may access, preserve, and disclose your personal information or other account information if we believe doing so is required or appropriate to comply with law enforcement requests and legal processes, such as a court order or subpoena, or to protect your, our, or others’ rights, property, or safety.

If you have any questions regarding how we use your Content, please contact us at info@cotripper.co.

Your Privacy Rights

CoTripper operates globally and is therefore subject to a variety of data privacy laws that confer a range of privacy rights upon our users. We have chosen to provide these privacy rights to our users regardless of their location.
• If you wish to submit a data rights request to access, correct, delete, export, rectify, update, or ask questions about your personal data, you may do so by contacting us at info@cotripper.co.
• In addition, you can object to the processing of your personal information or ask us to restrict processing of your personal information by contacting us at info@cotripper.co.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. Registered users can manage their account settings and email marketing preferences as described in the “Choices Regarding Your Personal Information” section below. If you are an unregistered user, or to opt-out of other forms of marketing (such as postal marketing or telemarketing), you may contact us at info@cotripper.co.
• Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

CoTripper does not discriminate against users who exercise any of these privacy rights. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable timeframe. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Close Your Account

If you’d like to close your CoTripper account, you can do so within your account settings on the Platform or by contacting CoTripper. When you close your account, you will no longer have full access to your Content, but we reserve the right to keep any information in a closed account in our archives that we deem necessary to comply

with our legal or regulatory obligations, resolve disputes and enforce our agreements. If, after you close your account, you wish to know which personal information we keep you can proceed in accordance with your rights set out above.

How Long We Keep Your Personal Information

We keep your personal information for only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes, or enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.

Third Party Sites

This Policy does not apply to the practices of third parties including any third-party websites, services and applications that you access through the Platform. We cannot take responsibility for the content or privacy policies of those third parties and encourage you to carefully review the privacy policies of any third-party websites, services, and applications you access.

Security Safeguards

Security. We employ physical, electronic, and managerial measures to safeguard the information we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. You are responsible for keeping your username and password secret. Once you have registered with us, we will never ask you for your password. Please create a unique password for your CoTripper account and do not use it for any other web services or applications. Do not share your password with anyone else.

Protecting Your Information. We implement and maintain reasonable measures to help safeguard your information. However, we make no guarantee that these reasonable efforts will make your information completely secure. Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information. Again, we encourage users to think carefully before electing to share content on the internet.

Privacy of Children. We do not knowingly collect, use, or distribute personal information from children under the age of 13. To access or use the Platform you must be at least 13 years of age or, if older, the age of majority in your jurisdiction, otherwise you may not use the Platform. If you become aware that a child has provided us with personal information without parental consent, please contact us at info@cotripper.co. If we become aware that a child has provided us with personal information without parental consent, we may remove such information and terminate the child’s account.

California Resident Rights

If you are a California resident, you have the rights set forth in this section.

You have the right to request certain information about our collection and use of your personal information over the past 12 months. In response, we will provide you with the following information:
• The categories of personal information that we have collected about you
• The categories of sources from which that personal information was collected
• The business or commercial purpose for collecting personal information
• The categories of third parties with whom we have shared your personal information
• The specific pieces of personal information that we have collected about you
• If we have disclosed your personal information to any third parties for a business purpose over the past 12 months, we will identify the categories of personal information shared with each category of third-party recipient. If we have sold your personal information over the past 12 months, we will identify the categories of personal information sold to each category of third-party recipient.


You have the right to request that we delete the personal information that we have collected about you. Under the California Consumer Privacy Act (the “CCPA”), this right is subject to certain exceptions. For example, we may need to retain your personal information to provide you with the Platform or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “valid request.” We may not respond to requests that do not meet these criteria. We will only use personal information provided in a valid request to verify your identity and complete your request. You do not need to have an account with us to submit a valid request.
We will work to respond to your valid request within 45 days of receipt. We will not charge you a fee for making a valid request unless your valid request(s) is or are excessive, repetitive, or manifestly unfounded. If we determine that your valid request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a valid request at the contact information described below. You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

We do not sell your personal information and have not sold your personal information over the last 12 months.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Platform as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of personal information that we receive from you.

GDPR Disclosure

Legitimate Purpose

In respect of each of the purposes for which we use your personal information, the General Data Protection Regulation (“GDPR”) requires us to ensure that we have a legal basis for that use if you are within the European Union (“EU”). The legal bases depend on how you use our Platform. This means we collect and use your personal information only where:
• we need it to provide you the services we offer, including to operate the Platform, provide customer support and personalized features, and to protect the safety and security of the Platform;
• it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Platform, and to protect our legal rights and interests; or
• we need to process your personal information to comply with a legal or regulatory obligation.

We may also rely on your consent as a legal basis for using your personal information where we have expressly sought it for a specific purpose. If we do rely on your consent to use your personal information, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
CoTripper is the “Controller” (for the purposes of the GDPR) of your personal information. Our address is 3510 Gentry Ridge Ct Silver Spring, MD.
Data Storage
We store information about users on servers primarily located in the United States and we may also store such information on servers and equipment in other countries. If you are accessing our Platform from outside of the United States, please know the data and personal information you submit may be transferred to and stored on servers in the United States or other countries.
Service Providers

We use a variety of third-party service providers to help us provide services related to our services. Service providers may be located inside or outside of the European Economic Area (“EEA”). We hold Data Processing Agreements (DPA) in place with all the third-party services, that guarantee that adequate safeguards are put in place with respect to the protection of such personal information as required by EU’s GDPR Data Protection policies. We do not sell personal information to third parties.

Your Rights

The people who provide us with any personal information have the following rights:
• Right of access. The data subjects shall have the right to obtain from the controller confirmation that their data are processed properly and they shall have the right to access their personal data.
• Right to rectification of information. The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning his or her.
• Right to erasure (to be forgotten). The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her.
• Right to restriction of processing. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
o the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
o the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
o the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
• Right to data portability. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. Please have in mind that this right will not be enforceable to:
o the third parties’ data that you have provided to the controller; and
o the data that concern you, but have been provided to the controller by third parties.
• Right to object. The data subject shall have the right to object to processing of personal data concerning him or her. You shall be able to object to the commercial communications submitting. You can exercise this right by contacting us at info@cotripper.co and clearly express the right you want to exercise.

Updates to Our Privacy Policy

We may revise this Policy from time to time by posting an updated version on the Platform. The revised Policy will be effective immediately for unregistered users and users registering accounts or otherwise acknowledging the Policy on or after the revision date. For other users who registered accounts before the revision date, it will also become effective immediately. However, they can object to the new Policy within thirty (30) days after the revision date. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review our website for the latest information on our privacy practices. Your continued use of the Platform is subject to the most current effective version of this Policy. If you object to the Policy after it becomes effective for you, you may no longer use the Platform.

Business Transfers

As we continue to develop our business, we may sell, transfer, or otherwise share your Personally Identifiable Information in connection with a merger, reorganization, bankruptcy, or sale of either our company or Platform. In such transactions, customer information is often one of the transferred business assets but remains subject to the promises made in any pre-existing privacy policy (unless the customer consents otherwise). You acknowledge and consent that such transfers are permitted by this Policy, and that any acquirer of ours or our current assets may continue to receive, store, and process your information as set forth in this Policy. You also consent to us providing access to your information as part of diligence or review processes conducted by potential acquirers, entities providing financing to them, their advisors, us, and our advisors.

Contact Us
If you have any questions or suggestions regarding this Policy, please contact us at info@cotripper.co.