COPE Privacy Policy

Effective Date: September 23, 2025

1. Introduction

Welcome! You have arrived at a website provided by TRAILB TECHNOLOGIES LLC, doing business as EXTRACTS PRO and COPE (“COPE,” “Company,” “we,” “our” or “us“). EXTRACTS PRO and COPE are trade names under which Company offers the same product, a tool for the construction industry to quickly and efficiently extract documentation and information from Procore.

At COPE, we take your privacy seriously. We provide this Privacy Policy (“Policy“) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information. If you have questions about this Policy after you review it, feel free to contact us at privacy@extractspro.com.

2. Scope

This Policy governs the https://withcope.com/, https://extractspro.com, and https://trailb.tech websites, their subdomains, and all subdomains or portals that link to this Policy, as well as any other site operated by us that links to this Policy (collectively, the “Sites“). This Policy also applies when you provide Personal Information or interact with us online or in-person, including via phone calls or other communications with our representatives or in any other instance when you contact us. For the purpose of this Notice, “Personal Information” means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. (The definition of Personal Information does not include publicly available information from federal, state, or local government records, such as professional licenses and real estate or property records.)

We refer to our provision of the Sites and all portals, products, goods, services, events, and interactive features, or other services controlled by us that post a link to this Policy collectively as our “Services.”

By using our Sites or otherwise using our Services, you acknowledge this Policy and agree to our Terms of Use (“Terms“).

3. What Information We Collect

As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you.

As you interact with our Sites or Services, we collect the following Personal Information webforms or inputs/uploads on our Sites, and through telephone calls, emails and other communications with you.

Information That You Provide to Us

Contact information such as your first and last name, email address, job title, home or business address, telephone numbers, mobile numbers.
Financial information such as your business credit card or debit card number, bank account information and your payment, service and purchase history. (We use third party processors to handle payment information and may receive limited information from the third party regarding your payment.)
Other information that could reasonably be used to identify you personally.

Information That Is Automatically Collected

Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Sites or Services (“Usage Information“), including via cookies and other tracking technologies (see Use of Cookies and Other Tracking Technologies section below). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device“) whenever you visit or interact with our Sites. Usage Information includes:

Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
Referring and exit web pages and URLs;
The areas within the Sites that you visit and your activities there, including remembering you and your preferences;
Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware);
Certain other Device data, including the time of day you visit our Sites or other information used to provide analytics or other usage information;
Information about your engagement with our emails; and
Statistical information about how both unregistered and registered users, collectively, use the Sites and Services.

Information Collected from Third Parties

The Sites include functionality that allows certain kinds of interactions between the Sites and your account on a third-party website or application, including ProCore. The use of this functionality may involve the third-party site providing information to us or us providing information to the third party. These third parties also use cookies and other tracking technologies to capture information about your interactions with COPE.

COPE does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

4. Use of Cookies and other Tracking Technologies

We use various methods and technologies to store or collect Usage Information (“Tracking Technologies“). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. By using our Sites and Services, you consent to the use of these Tracking Technologies. You may be able to modify your settings for some of these Tracking Technologies, but certain others may not be able to be modified by a website visitor. If you do not wish to agree to Tracking Technologies that cannot be modified, your sole remedy is to stop using our Sites. A few of the Tracking Technologies used on the Sites, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Sites may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage.
Pixels: A pixel is a small graphic file that allows us and third parties to monitor the use of the Sites and provide us with information based on your interaction with the Sites.
Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Sites’ pages and messages.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on.
ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We may use the following types of cookies:

Strictly necessary cookies. These cookies are essential for you to browse the Sites and use their features, such as accessing secure areas of the site.
Functionality cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your user name and password are so you can automatically log in.
Performance and Analytics cookies. These cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services if the cookies are for the exclusive use of the owner of the website visited.
Targeting and Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always from third-parties.

You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site. For example, we may not be able to recognize your computer or device, and you may need to log in every time you visit.

You can opt-out of non-essential cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Sites’ cookie preference centers. Click on the “Cookie Settings” button in the footer of our Sites to opt in or out of Cookies.

You also can control the use of cookies on most web browsers. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers — on other web browsers, you may need to find a “help” section on the toolbar for more information:

You can opt out of Google Adwords Remarketing here or block Google Analytics from accessing your online activity with a browser add-on here. We also use LinkedIn’s Reporting and Analytics — LinkedIn’s privacy policy is here and more information about managing your advertising preferences within LinkedIn is here. We use Arcade for our product demos and they may collect information about what you view in our demos. Arcade’s privacy policy is here.

Learn more about cookies and similar technologies or to opt out of targeted advertising cookies here. More resources are also available from the Digital Advertising Alliance (“DAA“) or the Network Advertising Initiative (“NAI“). We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs.

We may also use pixel tags which are small graphic files that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address from the device which you loaded the page, the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements. You may not be able to disable pixels.

Other Tracking Technologies may be used that collect comparable information for security and fraud detection purposes. You cannot disable the Tracking Technologies we use for security and fraud detection.

If you have any questions about cookies or to generally find out more about cookies, visit this site. Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. We always do our best to honor your choices, but because some choices are set at the browser or device level, you may have to make these choices multiple times if you use different browsers or different Devices.

5. Why We Collect Information

We use the information we collect about you in a variety of ways, including the following:

To Provide Our Services

We process certain Personal Information when you access or use our services, including to:

process your purchases of, or requests for, products and services;
create and verify user accounts;
facilitate the functionality of our Sites, including payment-related functionality; and
customize experiences and personalization when you are on our Sites.

To Communicate with You

We process certain information to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

communicate with you about orders, purchases, services, and accounts;
respond to your customer service inquiries and requests for information;
post your comments or statements on our Sites;
send you personalized content and special offers;
communicate with you about our products or for other promotional purposes; and
implement your communications preferences, or other communications that you have asked us to communicate on your behalf.

For Improvement of Our Sites or Services

We want to ensure that our Sites and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

maintain, improve, and analyze our Sites or Services; and
detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

maintain appropriate records for internal administrative purposes; and
comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Sites and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your express consent.

6. When We Disclose Information

To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:

Service providers. To provide information to nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. Examples of such disclosures include using a payment processor, customer service provider, email marketing provider, or cloud services provider. Our current list of subprocessors can be found here. This list is subject to change. If required by applicable law, we will provide advance notice of new or different subprocessors.
Marketing and advertising. We also may share your information, including your Personal Information, with third parties that perform analytics or tracking functions for us, such as Google Analytics. In addition, we may share the information we have collected about you, including Personal Information, for marketing purposes as disclosed at the time you provide your information and as described in this Policy.

Legal process. To comply with a validly issued and enforceable subpoena or summons; as a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
Business transactions. In conjunction with a prospective purchase, sale, or merger of all or part of our practice, if we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.

Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Sites or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (Non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

7. Retention of Personal Information

COPE will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

How long we have had a relationship with you or provided our Services to you;
The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;
Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments: defend against potential legal claims: detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;
The privacy impact on individuals of ongoing retention; and
The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

8. Additional Disclosures About Information

No Information From Children Under 16 — Our Sites are not intended for use by children under the age of 16. We do not request, or knowingly collect, any personally identifiable information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.
No Automated Decision-Making – We do not use automated decision-making technology to make profiling or behavioral advertising decisions about our users.
No Financial Incentives — We do not provide financial incentives in exchange for any Personal Information provided to us.
No Action Taken For Do Not Track — Do Not Track (“DNT“) is a web browser setting that requests that a web application disable its tracking of an individual user. We do not monitor or take any action with respect to DNT signals or other mechanisms. You can learn more about Do Not Track here.
Opt-Out Preference Signals — Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC“) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. You can learn more about GPC here. Where required by applicable law in certain regions, when we detect such a signal, we will make reasonable efforts to respect your GPC choices.

9. Visitors to the Sites Outside of the United States

If you are visiting the Sites from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Sites will be created and processed on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Sites or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Policy.

10. Links

For your convenience, the Sites and this Policy may contain links to other websites. COPE is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Sites should be deemed to imply that COPE endorses or has any affiliation with the links.

11. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Sites, and you provide us with your information at your own risk.

12. Your Choices About the Information We Collect

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information and you have a login with us, please make any changes within your account. If you do not have an account with us, please provide any changes or requests regarding your Personal Information using the information in the “Contact Us” section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

In addition, you can opt out of receiving promotional emails from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the “Contact Us” section below. Your choice will not affect our ability to share information in the other ways described in this Policy.

For information on how to control and adjust your cookie settings, please see the “Cookies and Other Tracking Technologies” section above.

Residents of the jurisdictions below may have additional choices regarding their Personal Information.

13. Your California Privacy Rights

This section of the Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA“) as amended by the California Privacy Rights Act (“CPRA“). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;
To know the length of time we intend to retain each category of Personal Information;
To know whether your Personal Information is sold or disclosed and to whom;
To access your Personal Information;
To delete the Personal Information you have provided to us, with certain exceptions;
To correct your Personal Information;
To opt out of the sale of Personal Information;
To know if Sensitive Personal Information (“SPI“) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction, or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

The categories of Personal Information collected about you;
The categories of sources from which the Personal Information is collected;
The business or commercial purpose for collecting, selling or sharing Personal Information;
The categories of third parties to whom the business discloses Personal Information; and
The specific pieces of Personal Information collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Personal Information Collected

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category of Personal Information	Examples of this Category	Sources of Personal Information	Business Purpose for Collection
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.	You Automatically Third Parties	To provide, improve and market our products and Services. To provide information you requested. To identify potential customers. To verify identity. To prevent fraud. To comply with law.
Personal information described in California Civ. Code § 1798.80(e)	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	You Automatically Third Parties	To provide, improve and market our products and Services. To provide information you requested. To identify potential customers. To verify identity. To prevent fraud. To comply with law.
Characteristics of protected classifications under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking.	N/A	N/A
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	You Automatically	To provide, improve and market our products and Services. To provide information you requested. To identify potential customers. To verify identity. To prevent fraud. To comply with law.
Biometric information	An individual’s genetic, physiological, biological or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA) or activity patterns that can be used to establish individual identity, including images of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information.	N/A	N/A
Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	Automatically	To provide, improve and market our products and Services To provide information you requested To complete a transaction with you For analytics purposes To identify potential customers To verify identity To prevent fraud To comply with law
Geolocation data	Physical location and/or movements.	N/A	N/A
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	N/A	N/A
Professional or employment related information	Current or past job history or performance evaluations	N/A	N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	N/A	N/A
Inferences drawn from other Personal Information	Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	N/A	N/A
Sensitive Personal Information	Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data	You	Only collected with your express consent to process a transaction with you.

Information related to how long we retain each category of Personal Information is included in the “Retention of Personal Information” section above.

Personal Information Sold or Shared

We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:

Category of Personal Information	Recipient Categories	Purpose for Sale/Sharing
Identifiers	Advertising, marketing, and analytics providers	Marketing and analytics
Personal information described in California Civ. Code § 1798.80(e)	N/A	N/A
Characteristics of protected classifications under California or federal law	N/A	N/A
Commercial information	Advertising, marketing, and analytics providers	Marketing and analytics
Biometric information	N/A	N/A
Internet or other electronic network activity information	Advertising, marketing, and analytics providers	Marketing and analytics
Geolocation data	N/A	N/A
Sensory Data	N/A	N/A
Professional or employment-related information	N/A	N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99)	N/A	N/A
Inferences drawn from other Personal Information	N/A	N/A
Sensitive Personal Information	N/A	N/A

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Personal Information Disclosed for Business Purposes

We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:

Category of Personal Information	Recipient Categories	Business Purpose for Disclosure
Identifiers	Service Providers	Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (not for cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services
Personal information described in California Civ. Code § 1798.80(e)	Service Providers	Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (not for cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services
Commercial information	Service Providers	Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services
Internet or other electronic network activity information	Service Providers	Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information — this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information for monetary value, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit, such as via Google Analytics, may be considered a “sale.” You can opt out of Google Adwords Remarketing here. You can change your Meta/Facebook Ad Preferences here. You can block Google Analytics from accessing your online activity with a browser add-on here. Other options for controlling cookies can be found in the “Cookies and Other Tracking Technologies” section above.

You may also exercise this right by writing to us the information in the “Contact Us” section below, or clicking on our Cookie Settings link in the footer of our Sites.

Right to Limit Use of Sensitive Personal Information

If applicable, California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. However, we do not collect or provide your Sensitive Personal Information to any third parties.

Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not disclose Personal Information protected under this section to third parties for their own direct marketing purposes.

Exercising Your California Privacy Rights

You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by using the information in the “Contact Us” section below.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

14. Your Privacy Rights under Other U.S. State Laws

We provide the information in this section for compliance with the applicable privacy laws in U.S. States other than California. Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

To confirm whether or not a controller is processing your personal data and to access such personal data;
To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold, shared, or disclosed and to whom;
To correct inaccuracies in your personal data;
To delete your personal data;
To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Not to discriminate against you because you have exercised any of these rights, including by:
- denying you Services;
- charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
- providing you a different level or quality of Services; and/or
- suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

To exercise any of these rights, you may make a privacy request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using the information in the “Contact Us” section below.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the “Contact Us” section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

15. Your Rights Under the General Data Protection Regulation

This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area (“EEA“). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR“). Any terms defined in the GDPR have the same meaning when used in this section.

Under applicable law, COPE is considered the “data controller” of the Personal Information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in your own login account as applicable in case any changes have occurred. We have listed below the rights that you may be able to exercise under GDPR in respect of the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that are required in connection with the purposes set out in this Policy.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

The right to access, update or delete the information we have collected from you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Information.
The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information — please review the “Why We Collect Information” section above for more information:

Contract: To conclude or perform a contract with you; for example:
- To manage and fulfill orders, and to provide other Services;
- To manage our accounts and records; and
- To handle your inquiries and requests.
Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests — we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent, or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:
- To respond to your customer service inquiries and requests for information;
- To maintain, improve, and analyze our Sites and Services we offer;
- To conduct marketing activities;
- To detect, prevent, or investigate security breaches or fraud; and
- To facilitate the functionality of our Sites.
Legal Compliance: To comply with our legal obligations; for example:
- To maintain appropriate records for internal administrative purposes and as required by applicable law.
Consent: We will send you information by email on our Services or other promotions with your consent or if you otherwise opt-in to receive those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

How to Exercise Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the information in the “Contact Us” section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us using the information in the “Contact Us” section below.

16. Your Rights Under the UK GDPR

If you are a resident of the United Kingdom, the following provisions also apply:

If we share your personal data within COPE or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office. You may make a privacy request under the UK GDPR by using the information in the “Contact Us” section below.

17. Your Canadian Privacy Rights

Canadian laws provide specific privacy rights to our Canadian customers. If you are a resident of Canada, this section applies in addition to all other applicable rights and information contained in this Policy.

Where applicable, We follow applicable Canadian federal and provincial privacy laws (“Canadian Privacy Law“), including:

The Personal Information Protection and Electronic Documents Act (PIPEDA)
Alberta’s Personal Information Protection Act (Alberta PIPA)
British Columbia’s Personal Information Protection Act (BC PIPA)
Québec’s Act respecting the protection of Personal Information in the private sector (Québec Act).

Consent

In most cases, we rely on implied consent to collect, use, or disclose your Personal Information. In some circumstances, including those involving sensitive Personal Information, we obtain express consent. Where you have provided your consent to the collection, use, and transfer of your Personal Information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by submitting a request using the information in the “Contact Us” section below. Please note that if you withdraw your consent, We may not be able to provide you with a particular product or service. We will explain the impact to you at the time of your request to help you with your decision.

Use of Your Personal Information

We will not collect, use, or disclose Personal Information except for the identified purposes identified above (See When We Disclose Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the Personal Information we provide to them, those relationships are governed by a written agreement regarding the confidentiality of your information.

Canadian Access and Challenge Rights

Canadian Privacy Law provides the right to receive information about the existence, use, and disclosure of your Personal Information and be provided access to that information. You may also challenge the accuracy and completeness of your Personal Information and have it amended as appropriate. Depending on the nature of the challenged information, amendment may involve correction, deletion, or addition of information.

Exercising Your Canadian Privacy Rights

If you have an account with us, you may view and update your account information (as noted above) directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your Personal Information, you may also submit a written request using the information in the “Contact Us” section below. When submitting a request, we also may require you to confirm your identity and your residency to obtain the information. For emails, please include “Canadian Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Canadian resident, and provide your province of residence. We will begin processing your request once you have completed the verification process and will respond within the timeframe required by law.

If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation.

Additional information about how to exercise your rights under Canadian Privacy Law can be found here:

Office of the Privacy Commissioner of Canada
Website
Phone: 1-800-282-1376

Office of the Information and Privacy Commissioner of Alberta
Website
Phone: 1-888-878-4044
Edmonton office: (780) 422-6860
Calgary office: (403) 297-2728

Office of the Information and Privacy Commissioner of British Columbia
Website
Vancouver: (604) 660-2421
Elsewhere in BC: (800) 663-7867

Commission d’acces a’ l’ information du Quebec
Website
Phone: 1-888-528-7741

18. Your Rights Under the Australian Privacy Act and the New Zealand Privacy Act

If you are located in Australia, you have certain additional data protection rights in accordance with the Australian Privacy Principles under the Australian Privacy Act 1988 (Cth). If you are a resident of New Zealand, you have rights under the Privacy Act 2020. This section applies in addition to all other applicable rights and information contained in this Policy.

To exercise any of your privacy rights under the Australian or New Zealand Privacy Acts, please submit a verifiable data subject request to us by using the information in the “Contact Us” section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of one of these countries by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us using the information in the “Contact Us” section below.

19. Changes to This Privacy Policy

We may change this Privacy Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes.

By continuing to use the Sites or Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be bound by the Privacy Policy as changed.

20. Contact Us

If you have any questions or suggestions regarding this Policy, please contact us as follows:

TRAILB TECHNOLOGIES LLC, doing business as EXTRACTS PRO and COPE

Email: privacy@extractspro.com

Webform: https://withcope.com/contact

Last Reviewed: 20-April-2026