For the purpose of data protection legislation, the data controller is TGI Services Limited, a British Virgin Islands (BVI) business company incorporated and existing in the British Virgin Islands with BVI company number 1811882 and having its registered office c/o the offices of Aleman, Cordero, Galindo & Lee Trust (BVI) Limited, P.O. Box 3175, Road Town, Tortola, British Virgin Islands. When we refer to “Coconut” in this policy, we refer to this entity.
Information we collect
We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.
When you create a Coconut account, we’ll collect some details about you such as your name, email, password, birth date, gender, nationality, living in, languages known, your resume, etc.
Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change.
We also collect and store certain information associated with actions you take. For example, when you login, we store the last login, last access. We also store information about the job postings that you apply to, members you are connecting with and other information about your behavior on our Platform.
If you enter credit/debit card information on the Platform in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.
Sometimes we need to request more information to verify your identity or to meet legal and regulatory obligations. When that is necessary, you will be prompted to provide such information.
Information we collect automatically
When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computers, such as your IP address or other device identifiers, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.
Automated means of data collection include the following:
Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access a Coconut website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.
Device Information. We collect information about the device you use to access the Platform, including the type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
How we use information
We use the information we collect to provide our services. In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. So it is largely necessary for fulfilling the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:
To provide you with personalized content, services offered by Coconut as well as promotional content and services (for example, Coconut uses your preferred positions to send relevant jobs you may be interested in);
To customize and improve the features, performance, and support of the site;
To provide relevant advertising, including interest-based advertising from us and third parties, which may mean that we share non-personally identifiable information, such as your job title, to third-party advertisers;
To transmit your application and save your application materials;
To share your saved Profile or resume with employers;
For internal operations, including troubleshooting, data analysis, testing, research, and service improvement
To communicate with you or initiate communication with you on behalf of third parties through your Coconut account or through other means such as email, telephone (including mobile phone), including through the use of contact information that you provide to us or (where it is lawful for us to do so) that we otherwise obtain from third-party resources;
To analyze use of the Platform and improve the Platform;
Protecting Your Information
Coconut seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Coconut control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.
Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
What types of Cookies do we use?
We use two types of Cookies on the Platform: "session cookies" and "persistent cookies." Session Cookies are temporary Cookies that remain on your device until you leave the Platform. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or "lifetime" of the specific Cookie and your browser settings).
What are Cookies used for?
Cookies transmit information about you and your use of the Platform, such as your browser type, search preferences, job titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. With the exception of an identifier Cookie that we associate with registered accounts to prevent fraud by members of the Platform, Cookies link to certain unique information such as the job titles that you entered at time of registration or on your profile, but this is not linked to your name.
Preferences and Features
Analytics and Performance
Ad Choices and Managing Cookies
Coconut works with several third parties to provide you with personalized, interest-based advertising. We may target ads to you, and measure their performance, on and off the
Member-provided profile information (e.g., job title, occupation, location, authorized information shared from your Social Networking Site)
Your use of the Platform (e.g., search history, job clicks, companies you follow);
Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket).
IP address or mobile device location information (to the extent you have enabled location tracking on your device);
Cookies (both on and off the Platform) which may include information from the Ad Partners we use to help deliver relevant ads to you.
How We Work with Third-Party Ad Partners
When we work with our Ad Partners to serve you personalized, interest-based advertising, we do not share information with them that they can use to identify you or associate with you as a specific individual unless you have instructed us to do so (such as when you fill out a lead form in an ad, or approve your Profile for display to employers). Similarly, if one of these Ad Partners have information about you saved in one of their own Cookies on your browser, they use that information to help us send you a relevant ad, but they do not share with us information that we can associate with you as an individual.
We work with third parties, such as Google Analytics, to provide analytics services that use the Cookies set on your device to measure the performance of advertising and track traffic to Coconut generally. We have also implemented Google Analytics Demographics and Interest Reporting, which categorizes Cookie information so that we and third-party service providers can better deliver advertisements that are relevant and useful to you on the Platform and various websites across the internet. In addition, a Cookie on some of our employer clients sites provides us with aggregate data about the number of applications submitted to those sites by users of Platform.
Opting Out of Cookies
If you enable location data for the mobile version of the Platform (including any version installed as a native application), we may use your location data to serve you geo-targeted ads for employers and other advertisers that are local to you. In such instances, we do not share your location with the advertiser or advertising network; rather, we provide the advertiser or advertising network with a means to push ads through to users located in certain areas. You may disable location services at any time in your device privacy settings or the Coconut native app settings.
Ad Partner Cookies
Here are some options for managing the third-party Cookies used by our Ad Partners:
You can adjust Cookie preferences on Coconut through our Cookie Consent Tool.
You are also able to opt out of other third-party advertiser and ad network placement of Cookies or targeted advertising generally by visiting the following links: Network Advertising Initiative; Digital Advertising Alliance; European Interactive Digital Advertising Alliance (for users in the EU); The Digital Advertising Alliance of Canada (for users in Canada); or you can follow opt-out instructions of the Ad Partners we work with listed here. You will continue to receive generic ads by companies not listed with these opt-out tools.
You can opt out of tracking by Google Analytics and Google Analytics Demographics and Interest Reporting services by visiting Google Ads Settings or by downloading the Google Analytics Opt-Out Browser Add-on.
Please note: If ads or other features on the Platform are provided by third parties, those parties set and use their own Cookies that are subject to those third parties' privacy notices and policies. Coconut does not have access to, or control over, these Cookies. Also, if you respond to ads posted by third parties or submit information to third parties via the Platform, such third parties receive information about you subject to their privacy policies.
This document was last updated on May 28, 2020