Privacy Policy

Cocoon Financial Services, Inc. (“Cocoon,” “Company,” “we,” “us” or “our”) is concerned about protecting the privacy of users of our Services and website located at cocoon.com (the “Site”) and our mobile application. In all circumstances, Cocoon will comply with applicable privacy legislation in the jurisdiction in which you are located (hereinafter “applicable laws”). This Privacy Policy explains how we collect, use, share and otherwise process your personal information in connection with the Site and our services, and the rights and choices that may be available to you with respect to your information.

By using our Services and Site, you agree to the terms of this Privacy Policy. 

Description of Services & Information Collected

Cocoon offers a cloud-hosted Software-as-a-Service (SaaS) platform that provides employees with an easy, understandable and fast way to privately design their leave and helps employers administer and manage parental, medical and caregiver leave correctly. Providing our Services requires Cocoon to collect and process certain personal information provided by employers (“Employers”) about their employees, as well as information provided directly by individual employees.  Using information provided by Employers and their employees, Cocoon assists with recovering funds from state and insurance sources; coordinating payroll; and tracking leave and compliance.  

Information About You Collected from Employers

When we collect personal information about you directly from your Employer, your Employer determines the processing of your personal information. If you have questions about how the personal information we receive from your Employer is collected, how it is processed or why we process it, please refer to your Employer’s privacy policy or contact your Employer. If you have requests regarding the personal information we process on behalf of your Employer, please direct your inquiries to your Employer.

Personal information means any information about an identifiable individual.  The personal information we collect about you from your Employer may include:

• Contact and Profile Data: your name and work email.
• Government-issued Identification Numbers: your Social Security, Taxpayer Identification Number or Social Insurance Number.
• Employment Information: your employer’s name, your job title, office location, start date, salary, and job duties.
• Insurance Information: your provider and policy number.

Information Collected Directly from You

We collect personal information that you provide directly to us through the use of our Services. The information we collect in this manner may include:

• Contact and Identification Data: your name, email, mailing addresses and phone number.
• Government-issued Identification Numbers: your Social Security number, Taxpayer Identification Number, or Social Insurance Number.
• Employment Information: your employer’s name, your job title, office location, start date, salary, and job duties.
• Account Data: your personal email and password that you may set up to establish an online account with us.
• Information About Your Pregnancy: your expected due date, adoption or foster child placement date, expected delivery method, name and contact information of delivery hospital and doctor, midwife, or other medical professional, and parental leave preferences.
• Information About Your Medical Leave Request: condition or diagnosis, name and contact information of medical providers and expected dates of disability.
• Insurance Information: your provider and policy number.
• Documentation: any attachment you upload that contains personal information, such as a birth certificate, insurance card, medical record, or other document.
• Information about Third Parties: We collect information that you choose to provide regarding your partner, dependents, or other third parties, such as their names, email addresses and phone numbers.
• Feedback: information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Usage Data: your preferences for receiving communications about our activities and publications, and details about how you engage with our Site and communications.

Automatically Collected Data

We and our service providers may use cookies, beacons, pixel tags and other tracking technologies to automatically log information about you, your computer or mobile device and your activity over time on the Site and other online services, including:

• Device Data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, device identifier (such as the Google Advertising ID or Apple ID for Advertising), the website you visited before browsing our Site and general location information such as city, state or geographic area.
• Online Activity Data: Cocoon.com, our business website, tracks additional information using cookies that includes your browsing history, search history, whether you clicked on or opened one of our emails, which of our pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access.

Please visit the “Options” section of this Privacy Policy for information on how to disable or opt-out of certain cookies and similar technologies.

You may refuse to provide certain personal information, but some parts of the Site or our services may not be fully available or functional without submitting such information.

Cocoon will only collect as much information as is required to fulfill the purposes of our business and comply with our contractual obligations with Employers.

Use of Information

We use your personal information for the following purposes or as otherwise described in this Privacy Policy or at the time of collection:

Operations. We may use personal information to operate the Site and provide related services, including to:

• Manage the leave management process on behalf of Employers;
• Provide, operate and improve the Site and our services;
• Establish and maintain your account on the Site;
• Enable security features of the Site, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• Understand your needs and interests, and personalize your experience with the Site and our communications;
• Respond to your requests, questions and feedback;
• Protect the security of the Site and our systems; 
• Provide you with customer support when needed; and
• Comply with applicable laws.

Research and development. We may analyze use of the Site and mobile application to evaluate and improve the Site, mobile application and our services, and to develop new products and services, including by studying user demographics and use of the Site and mobile application. We use third party analytics, monitoring, and product improvement tools to support these activities. These third parties help us operate, analyze, and improve our services and are listed in our Trust Center as subprocessors.

Compliance, fraud prevention and safety. We may use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); to audit our internal processes for compliance with legal and contractual requirements and internal policies; to enforce the terms and conditions that govern the Site; and to prevent, protect against, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity. 

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect, by removing the information that makes the data personally identifiable to you. We may use and share such anonymous, aggregated or de-identified data for any purpose we deem appropriate, such as to maintain and improve the Site, mobile application and our current as well as future products and services.

To develop and use artificial intelligence and other models to provide the services. We may use anonymous, aggregated, or de-identified data that does not identify any Customer or you to train AI models deployed on the Cocoon Site and services to improve the efficiency of the Site and services. Cocoon does not provide identifiable personal information to third-party AI systems for model training.

To send you promotional communications. We may send you promotional communications about the products or services that we offer.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information where your consent is required by applicable laws.

Sharing of Information

We may share personal information with:

State or Federal Agencies that Administer Family or Medical Leave Benefits.  We may share your personal information with the state or federal agencies that administer family or medical leave benefits in order to facilitate your application for disability or parental leave and benefits. We do not control how these state agencies may process your personal information.

Insurance Companies.  We may share your personal information with insurance companies to facilitate your claim for short term disability benefits.  We do not control how insurance companies process your personal information but we take appropriate steps to protect the privacy of your personal information where required. 

Enterprise Employers. If you use our Services through one of our Employers (including your employer), we share your personal information with that Customer in order to facilitate your medical, caregiver or parental leave and state and insurance benefits and to ensure proper payment and communication regarding the length and type of leave. We do not control how the relevant Customer may collect, use or disclose your personal information.

Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the service (such as payment, customer support, hosting, analytics, email delivery, marketing and database management services).

Professional advisors. We may share your personal information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. We may share your personal information with law enforcement, government authorities, agencies or departments, and private parties, as we believe in good faith to be necessary or appropriate for the compliance, fraud prevention and safety purposes described above or as otherwise required or permitted by applicable laws.

Business acquirers. We may share your personal information with relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, (including, in connection with a bankruptcy or similar proceedings).

Retention of Personal Information

Cocoon retains personal information only for as long as necessary to provide our services and to comply with our legal, regulatory, contractual, and security obligations. Retention periods vary depending on the type of information, the nature of the services provided, and applicable legal requirements. For example, information associated with employee accounts, leave administration, benefit applications, and related communications may be retained for longer periods where required to comply with employment, tax, benefits, audit, or dispute resolution obligations. Cocoon maintains internal retention schedules that define retention periods by category of information and applicable legal requirements. When personal information is no longer required for these purposes, it is deleted or de-identified in accordance with Cocoon’s data governance and security practices.

Options

Cookies & browser web storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Opt out of marketing communications. If at any time you wish to opt-out of future newsletters or other promotional emails and communications, you may click the “unsubscribe” link in the email or otherwise contact us at support@cocoon.com. It may take up to 10 business days before you stop receiving promotional emails. This opt-out does not apply to operational communications, for example, confirmation emails.

Your Rights

Some states grant you certain rights and control over your information. Those rights may include:

• Information about You: You may ask for us to state what categories of personal information about you we have, and the categories of sources from which we collect your personal information.
• Correct Your Information: You may log into your account, if you have one with any of our Sites, to correct the information stored in your profile. You may also contact us to help you correct your information.
• Receive a Copy of Your Data: You may request the categories and specific pieces of information (if any) we have about you, the categories of personal information that we have disclosed about you for a business purpose, and the categories of third parties with which we have shared personal information.
• Delete Your Data: You may request that we delete the personal information we have collected from you.
• Profiling: You may opt out of our ability to create a profile of you for marketing or advertising purposes. Where you have created an account with us or where we have created a customer profile based on your transactional history with us, we may be limited in how we can manage your data and you may be asked if you wish to delete your data instead.
• Do Not Sell: You may opt out of our sale(s) of your personal information, as "sale" is defined by data privacy laws. Please see above for more information.
• Non-Discrimination: California law prohibits discrimination against you for exercising your privacy rights.
• Do Not Share for Targeted Advertising: You may opt out of targeted advertising. For more information on how to do so, please see above.
  
  

How to Exercise Your Rights

If you are using the Cocoon Services through your Employer, contact your Employer to initiate a rights request. 

If we have collected your information directly for our marketing efforts or you are an agent of an Employer, please contact us at support@cocoon.com. 

Verification Process and Required Information

All requests must be verified. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity. If we cannot verify your identity based on the information provided, a request for a copy of your data will be treated as a request for information and if we cannot verify your identity, a request to delete personal information may be treated as a request to opt-out of the sale of personal information.

If you wish to appeal a decision regarding your rights, please contact us at support@cocoon.com.

Authorized Agent

You may designate an authorized agent to make a request on your behalf. An Authorized Agent must have written documentation of their authority to act on your behalf, such as a Power of Attorney.

Information about Children

The Site, mobile application and our services are not directed to children under 16. We do not knowingly collect or solicit personal information from children under 16 on the Site or mobile application. If you are under 16, please do not attempt to register an account or send any information about yourself to us. If we discover that we have collected personal information from children under 16, we will take commercially reasonable measures to promptly delete such information from our systems. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, please contact us at support@cocoon.com.

If you provide Cocoon with personal information related to your dependents, including children under 16, when using our Services, including uploading Documentation, you are deemed to have consented to our use of this information to provide the Services to you and your Employer.  

Security

We maintain various physical, electronic and procedural safeguards designed to protect the personal information we collect. We protect personal information in a manner appropriate to the sensitivity of the information. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of personal information.

Third-Party Websites

The Site contains links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third-party and we cannot control, and take no responsibility for, the content or privacy practices of such third-party websites, mobile applications or online services operated by third parties. Please carefully review the Privacy Policy and any other applicable terms for such third-party websites, mobile applications or online services operated by third parties.

International Data Transfers

Cocoon currently stores and processes personal information in the United States. We do not transfer personal information outside of the United States in connection with providing our Services. If this practice changes in the future, Cocoon will implement appropriate safeguards as required by applicable law.

Policy Updates

We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Site. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

Contact

If you have any further questions concerning this Privacy Policy, would like to request to correct, update, or delete such information, or have a complaint about the processing of your personal information, please contact privacy@cocoon.com or legal@cocoon.com. We have assigned a privacy officer who will deal with and address your issues as appropriate, subject to certain exceptions as stated in applicable laws. You may also file an inquiry or complaint with any applicable privacy commissioner which may exist in your jurisdiction of employment.