Last Updated: November 5, 2025

This Privacy Policy (the “Policy”) describes the types of personal information COTHINK'R and  its affiliates and related entities (collectively, “COTHINK'R” or “we”) collects about you through our operation of our businesses and various digital properties (our “Services”), how we use that information, who we disclose the information to, and certain rights and options you may have regarding your personal information.

This Policy applies to information we collect from you through the websites and mobile applications made available by us (including, cothinkr.com), as well as when you communicate with us, interact with us, or otherwise provide us with information. You may be presented with other privacy notices during the course of interacting with us or using our services; this Policy supplements those other notices.

By using one of our digital properties, communicating with us, or otherwise interacting with us, you consent and agree to our collection, use, and disclosure of your personal information as described in this Policy.

Notice Regarding Use of Artificial Intelligence

We may deploy, via our Services, technical agents that leverage artificial intelligence technologies, such as generative pre-trained transformers and similar tools (collectively, “AI”) to provide users with information, content, or other materials.

Unless the communication you receive contains some indication that you are interacting with a natural person, then the communication is likely the product of one of our AI-powered agents. In other words, your interaction is with an artificial piece of technology, not a real person.

If you have any questions about how AI-powered agents work, or you have questions and would like a real person to respond, please contact us at the information below. Note, however, AI-powered agents are key to the delivery of our Services; in some cases, there is no human or natural person substitute for the task being performed by the AI-powered agent. If you prefer to not interact with any AI-powered agents, then please discontinue your use of the Services.

Personal Information We Collect or Receive About You

A. Personal Information You Provide or Make Available

For the purposes of this Policy, “personal information” is any information that, either alone or in combination with other information, identifies, relates to, or can be used to contact a particular individual. The types of personal information we may collect include the following categories.

• Contact information: First name, last name, email address, mailing address, and telephone number.
• Account details: If you create or register an account with us, your username, password, account number, and other account details that are requested as part of the account setup and management process (e.g., your preferences or areas of interest).
• Demographic information: When completing your user profile, interacting with a survey or tool, or when you otherwise choose to provide the information, demographic information such as your age, education history, professional history, or military status.  
• Transactional data: Details about your transactions with us, including method of payment, relevant billing or shipping addresses, payments received, transaction history, and other information relating to the products or services purchased by you.
• User content: Information, photos, posts, reviews, feedback, or other content that you submit or otherwise post or upload to any portion of our digital properties (e.g., an online forum, community chat, a comment section to an article or post), as well as photos or videos you make available or accessible through your device settings.  In some cases, this information may include or be associated with your account details and may be viewable by other users of the relevant digital property.
• Marketing information: Details regarding promotional materials you may have requested or received from us, the services in which you are interested, your receipt of newsletters or other promotional communications, and information on your marketing or communication preferences.
• Customer communications: Copies of communications or inquiries you have submitted to us, including through email, calls, chat functionalities on our digital properties, forms, social media, or other means. This includes information you provide in response to customer surveys, quizzes, sweepstakes, questionnaires, or intake forms.
• Device, usage, and preference information: Details regarding how and when you use our digital properties, including the device used to connect to the digital property, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to the digital property, and information about your interaction with the digital property. We also collect information regarding the content viewed and issues queried while on our digital property (e.g., articles read or saved, pages visited, products searched for, etc.).

We collect this information when you access, use, or navigate one of our digital properties, create an account with us or use an existing account to engage with one of our digital properties, fill in forms via one of our digital properties, purchase a subscription or access to our Services, request information from us, communicate with us (including by phone, email, chat, or otherwise), interact with any chatbot or similar features available via one of our digital properties, visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

If you do not provide us with certain information, then the digital property you are using may not function as intended, or you may not be able to benefit or take advantage of certain features of our products or services. For example, if you do not provide us with your name and email address, you cannot create an account with us.

Where we have an ongoing relationship with you, and any of the data you have provided (e.g., your contact information) is no longer accurate, please inform us of this so we can amend our records accordingly.

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” 

B. Automatically Collected Personal Information

Like most digital property operators, we use various technologies to collect certain types of information about the users of our digital properties. Note, the vendors that supply us the pixels, tags, web beacons, cookies, and the other tracking technologies discussed below collect your personal information instantaneously and simultaneously to our collection of such information.

The technologies we use on our digital properties include:

• Pixels, tags, web beacons, gifs, and similar code-based technologies.  These technologies are small pieces of code that run when a digital property page or an email is loaded. They are used to monitor the behavior of the visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics and details about the interaction.  For example, when you open our homepage, a pixel may run and generate information based on the visit (e.g., your IP address and what day and time you were on the homepage), and then this information is processed by us or our vendors. Pixels work in conjunction with cookies to let us know what portions of our digital properties are of interest to you and to help us provide you with tailored information. Even if you have disabled or turned off cookies (discussed below), the pixels, tags, and web beacons we use may still detect and collect certain information about your interaction with our digital property; in other words, these kinds of technologies may disregard any cookie-prohibitive markers or signals.
• Cookies: Cookies are small text files that can be used by websites to make a user’s experience more efficient. Our website uses different types of cookies to, among other things, automatically recognize you when you return to our site, store information regarding your preferences, and analyze traffic to our site. Please note that where cookies are essential to the operation of our site, if disabled, you may not be able to enjoy certain features of the site. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.  We do not honor “Do Not Track” signals.
• Log Files and Device Identifiers.  We use log files to track actions occurring on digital properties and to collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
• Analytics.  Our digital properties may also deploy third-party analytics tools, such as Google Analytics.  You can find more information about how data is collected and processed in connection with the Google Analytics service at https://policies.google.com/technologies/partner-sites. You can also read Google’s privacy policy at https://policies.google.com/privacy?hl=en.

The information collected through these technologies may be combined with personal information or aggregated with other information on website visits. We may share information about your use of our website with our advertising and analytics partners, who may combine it with other information that you previously provided to them. In some cases, the vendors who supply us with these technologies

Please see the Section titled “Your Choices About Your Personal Information” for more information about options you may have to configure pixels, tags, cookies, and similar technologies on our digital property.

C. Personal Information from Other Sources

We may obtain both personal and non-personal information about you from other users of our website and services, business partners, suppliers, and other third parties and add it to other information we have collected.   

We may provide you the ability to log in to our digital properties through certain third-party accounts. When you use these single sign-on protocols to access our services, we receive tokens from the sign-on protocol to help identify you in our system and confirm you successfully authenticated through the applicable sign-on protocol.

We, and the third parties we engage, may combine information we collect from you over time and across your online activity with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness and also helps us better tailor our interactions with you.

D. Personal Information from Social Media

If you interact with us on any social media platform: (i) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (ii) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts.  Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform.  We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.

How We Use Your Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

• Making our Services, including our digital properties, and their features and tools, available to you.
• Authenticating your credentials or facilitating any login to our Services, including through the use of single-sign-on options provided by third parties.
• Registering you for an account with our Services.
• Managing our relationship with you, including entering into and fulfilling any transactions with you. 
• Allowing our affiliates, related entities, and operational partners to communicate with you and deliver relevant information to you, including information about their products and services.
• Operating our business, including engaging in accounting, auditing, invoicing, or reconciliation and collection activities, determining the effectiveness of our marketing or sales strategies or processes, managing our communications.
• Analyzing market and consumer trends and developing financial, product, or profile insights.
• Enhancing your experience on our digital properties, including by identifying and displaying content that might be of interest to you and otherwise ensuring that our content is presented to you in a useful and effective manner.
• Communicating with you and responding to your inquiries and communicating regarding our Services, the functionality of our digital properties, and other issues.
• Sending you informational communications and promotional solicitations, tracking your marketing preferences, and for our internal marketing purposes.
• Managing customer service issues, including issues relating to the performance of our Services and customer feedback.
• Developing, updating, and improving our Services (including our websites and mobile applications), our administrative processes that support our business, and customer experience, and otherwise improving our knowledge and insights regarding users.
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the use of our digital properties or use of our products or services.
• Enforcing our agreements with you or our organizational partners and customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.
• Notifying you about changes to our services or material changes to this Policy.
• Providing you with surveys or otherwise soliciting feedback from you.
• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent. 

For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.

Disclosure of Your Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties, to the extent permitted by applicable law.

In addition, we may disclose your personal information to the following types of individuals or entities:

• Service providers we use to facilitate our business operations and administer our Services. These parties have access to your personal information to perform specific tasks on our behalf. For example, our service providers include (i) IT and system administration providers, (ii) data storage and server providers, (iii) web hosting providers, and (iv) vendors to facilitate payments and payment processing.
• Other users of our Services, if you choose to post or share content in forums, bulletin boards, or in connection with other community-oriented or social features of our digital properties.
• Vendors whose technologies we leverage to provide certain features of our digital properties, such as video players and chat software providers.
• Marketing and advertising vendors that may assist with lead generation, hosting information relating to customers and business partners and potential customers or business partners, marketing automation, advertisement placement and targeting, and marketing campaigns and communications. Examples of these vendors include Meta and LinkedIn. 
• Analytics vendors in order to understand our digital property traffic and usage patterns, optimize our digital properties, track marketing conversions, and identify potential new customers or users.
• Our affiliates and related entities, investors, and operational partners.
• Our professional advisors, such as lawyers, accountants, and other similar advisors.
• Other parties for any purpose we disclose at the time you provide the information.

We may also disclose your personal information to:

• Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
• Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
• Protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and risk reduction.
• Enforce or apply the terms and conditions of our digital properties, any terms and conditions of purchase (to the extent applicable), and other agreements between you and us.

Note, the technology vendors we use to make our digital properties available to you may collect your personal information instantaneously and simultaneously with us collecting the same information.

Our Marketing Efforts

We may send you direct marketing communications from time to time via physical or electronic mail, including news, updates, and other announcements relating to our services and business activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe from our marketing communications using the functionality in the communication you have received or by contacting us at the information below.

Your Choices About Your Personal Information

A. Tracking Technologies and Advertising

Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies.  Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same.  Please note that if you disable or delete cookies, you may not be able to access or use certain features of our digital properties.

The National Advertising Initiative also makes resources available to assist consumers in opt-out of certain tailored online ads, which you can access at https://optout.networkadvertising.org/?c=1.

B. Marketing Communications and Emails

You may choose to opt out of marketing emails by using the “Unsubscribe” link found at the bottom of such emails. You can configure your device settings to disable push notifications. You can opt out of receiving certain communications by contacting us at the “Contact Us” information below.

C. Google Analytics

As discussed above, we use Google Analytics in connection with the website.  If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can access at https://tools.google.com/dlpage/gaoptout?hl=en-US.  You can find more information on how Google uses information it collects at https://policies.google.com/technologies/partner-sites.

D. Updating Your Information

We take reasonable steps to keep your personal information accurate and complete. You can access or update your personal information, including contact or account information, by contacting us at the “Contact Us” information below.

E. Declining to Provide Information

You can choose not to provide us with information we may request, but that may result in you being unable to use certain features of our digital properties, request information about our Services, or initiate other transactions with us.

F. Do Not Track Mechanisms

Please note that our websites do not honor “Do Not Track” signals, and such signals will not impact the operation of our websites. Do Not Track signals are different than the Global Privacy Control (more information about GPC can be found at https://globalprivacycontrol.org/).

Additional Information for California Residents

California Civil Code § 1798.83 (California’s Shine the Light Act) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

Additional Information for Nevada Residents

Under Nevada law, Nevada “consumers” may request that certain “operators” of internet sites and online services refrain from the “sale” of their “covered information” to third parties (as such terms are defined under Nevada law).  Our disclosures of your information to third parties (as described above) do not qualify as a sale under Nevada law. Nonetheless, you may contact us at the information below to make a request under the laws of the state of Nevada.

Additional Information for Residents of Other U.S. States

The laws of the jurisdiction where you reside (e.g., Texas, Minnesota) may afford you certain rights with respect to your personal information.

The sections above entitled, “Personal Information We Collect or Receive About You,” “How We Use Your Personal Information,” and “Disclosure of Your Personal Information,” describe the categories of personal information processed by us, how such information is collected, the purposes for processing, the categories of personal information disclosed to third parties, and the categories of third parties to whom we disclose personal information.  The laws of some U.S. states regulate the handling of “sensitive personal information” or “sensitive data.” We do not collect or process any “sensitive personal information” or “sensitive data.”

Subject to exceptions, the laws of your state of residence may provide you the right to:

• Confirm whether we are processing your personal information and/or to access such data;
• Update or correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information;
• Delete personal information provided by or obtained about you;
• Obtain a copy of the personal information provided to or processed by us, in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means;
• Obtain a list of the third parties to whom we have disclosed personal information;
• Be free from discrimination for exercising any of the rights described in this section; and/or
• Opt out of the sale of your personal information, the processing of your personal information for the purposes of targeted advertising, or the use of your personal information for automated decision-making or automated profiling in furtherance of decisions that produce legal or similarly significant effects.

We do not engage in the sale of personal information for monetary consideration or in automated profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers. As a result, the right to opt out of such activities may not be available.

We similarly do not engage in “targeted advertising,” as that term is defined by certain privacy laws, or “sales” of personal information (again, as that term is defined by certain privacy laws), so the right to opt out of such activities may not be available.

You can submit a request regarding your personal information by sending an email to [email] with the subject, “Privacy Request.” In the event we decline your request, depending on the applicable law, you may have the right to appeal the decision. You can do so by contacting us at the same email address. You may also be entitled to report the matter to the appropriate regulator in your state.

Data Retention

We retain personal information for as long as necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements.  We also consider any specific limitation periods under applicable law.

Information Security

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Data Location

You understand and agree that information about you may be stored or processed by information technology systems located in the United States of America or jurisdictions that may have laws that differ from the laws of your country of residence or the jurisdiction in which you reside.

Links to Third-Party Websites

Our digital properties may contain links to third-party digital properties (e.g., social media sites). Such third-party digital properties have separate privacy policies that you should review. We cannot and do not take responsibility for the content of linked websites or those companies’ data-handling practices.

Privacy of Children Online

Our digital properties are intended for use by a general audience. We do not knowingly collect the personal information of any individual under the age of 13. If you believe we have collected the personal information of a child under 13, please contact us at the information below.

Changes to the Privacy Policy

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements. 

Please note that we may change this Policy from time to time.  If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the website after any changes is deemed to be acceptance of those changes.  Accordingly, we encourage you to check the Policy periodically for updates.

Contact Us

If you have any questions regarding our information handling practices, please contact us by e-mail at [email protected] or by using the contact information provided below:

COTHINK'R LLC
40 S 4^th Street, Suite 401M
Minneapolis, MN 55415