Privacy Policy CoCo

CoCo College and its subsidiaries (hereinafter, "CoCo College," “us,” or “we”) respects yourprivacy and is committed to helping you understand what data we collect, why we collect it, andwhat we do with it. Please, take time to read the Privacy Policy carefully. By providing personalinformation to us, you agree to this Privacy Policy.

1.SERVICES COVERED BY THIS POLICY

1.1 We currently operate the CoCo College website cococollege.com (the "Website" and,the “Services”). This Privacy Policy covers your use of the Services.

2. COLLECTION OF PERSONAL INFORMATION

2.1. Through the use of our services, we collect information for purposes of operation.This information may include your first name, last name, BU email address, phonenumber,, graduation year, prefered location, and photos. We may also receive yourpersonal information from other sources, such as public databases, Boston Universitydatabases, social media platforms and from other third parties.

You can use and visit our Website without providing personal information. However, wewill need to collect personal information in order to provide certain Services or featuresin the website. If you refuse to provide your personal information when required, we willnot be able to provide most key Services of the website.

You also may be able to purchase certain features, from CoCo College, in connectionwith the Services. If you do so, we may use the personal information we collect toprovide services to you in connection with any such purchase. This personal informationmay also be utilized in the payment process in connection with other third parties. If yousubmit any personal information relating to other people to us or to our service providersin connection with the Services, you represent that you have the authority to do so andpermit us to use the information in accordance with this Privacy Policy.

2.2. We will collect the location of your preferred exchange location, in order to record itin the website and inform buyers of a preferred pickup location. CoCo College willcollect this information in the selling process for each product. You may allow or denysuch collection and publication of your location, but it may affect your use of theServices (for example, by not allowing us to post your product’s sale location in themap).

2.3 We may also use ads ​on CoCo College using your information, including the uploaded photo or image of the product as well as other data (including user name andlocation) associated with the ad, for our own advertising purposes, including socialmedia, Facebook ads, newsletters and ads for any media.

2.4. We may disclose the personal information we collect from you to our affiliates forthe purposes described in this Privacy Policy; to our service providers who provideservices such as website hosting, data analysis, payment processing, order fulfillment,information technology and related infrastructure provision, customer service, emaildelivery, auditing and other services; and to a third party in the event of anyreorganization, merger, sale, joint venture, assignment, transfer or other disposition of allor any portion of our business, assets or stock.

2.5 We may use or disclose the personal information we collect from you as we believenecessary or appropriate, including, but not limited to, using and disclosing personalinformation for the following purposes: to protect people or property, to protect ourservices, rights or property, to comply with legal requirements, to respond to legalprocess or law enforcement requests and to comply with requests from other public andgovernment authorities.

3. MEMBERSHIPS AND REGISTRATION

3.1. To use certain Services you will need to register, in order to register you will need toprovide your name, Boston University’s (BU’s) email address, graduation year, and mobile number. The collection of the mobile number will not be available to the publicand will be used for verification and internal purposes.

3.2. We may require you to provide us information such as a photo for every product youupload, your location for the sale, price and description for purposes of making availablethat information on the Website. You may visit some areas of the Services as a guest, butyou may not be able to access all the content and features of those areas withoutregistering.

4. PUBLIC INFORMATION

4.1. Please note that some information you post on our Services will become public andmay be available to other users and the general public. We urge you to be very carefulwhen deciding what information to disclose through the Services.

4.2. Please note that your name​and​ graduation year ​will be openly available to the public on the website in cases such as publishing products. Personal information postedby you or disclosed by you to other users may be collected by other users of suchServices and may result in unsolicited messages.

4.3 When users are interacting with each other (in our chat feature), WE ARE NOTRESPONSIBLE FOR PROTECTING ANY EXCHANGE OF INFORMATION THATUSERS DISCLOSE WITH ONE ANOTHER. We strongly encourage our user to notshare any credit card information, mobile exchange, or any other private information.

5. EMAIL NEWSLETTERS AND PUSH NOTIFICATIONS

5.1 Where permitted by applicable law, we may contact you and/or send to youcommercial communications via electronic communications, such as email, to informabout our products, services, offers, or any commercial content related to the company. If

you do not want to receive marketing emails from us, you can always opt-out byfollowing the unsubscribe instructions provided in such emails. Please note that theautomated emails will be sent through the means of third party applications, so someprocesses may need to be consulted with them. Please note that even if you opt-out fromreceiving commercial communications, you may still receive administrativecommunications from CoCo College, such as transaction confirmations, notificationsabout your account activities (e.g. account confirmations, password changes, etc.), andany other important announcements. We may also send you push notifications if youhave opted-in to receive them. You can disable push notifications in your mobile device’ssettings.

6. WHAT NON-PERSONAL INFORMATION WE COLLECT FROM YOU

6.1. In many cases, we will automatically collect certain non-personal information aboutyour use of the Services. We collect this information to ensure that the Services functionproperly. We might collect, among other things, information about your browser ordevice, app usage data, information through cookies, pixel tags and other technologies,and aggregated information. This information may include:

IP address, which we may use for purposes such as calculating usage levels, diagnosingserver problems and administering our Services. We may also derive your approximatelocation from your IP address. To do this, CoCo College may use cookies and othertechnologies, as described in this and the following section(s).

6.2. We may also use and disclose non-personal information for any purpose, exceptwhere we are required to do otherwise under applicable law. In some instances, we maycombine this information with personal information. For example, if you have created anaccount with our Services, your account information may be linked to the items youpurchased (i.e., purchase order history). If we do, we will treat the combined informationas personal information as long as it is combined.

7. INFORMATION ON COOKIES AND RELATED TECHNOLOGY

7.1. CoCo College Services may contain "cookies." We may use cookies to manage ourusers’ sessions and to store preferences, tracking information, and language selection.

Cookies may be used whether you register with us or not. “Cookies” are small text filestransferred by a web server to your hard drive and thereafter stored on your computer.The types of information a cookie collects include the date and time you visited, yourbrowsing history and your preferences.

We may use the information collected through cookies to promote, highlight, orotherwise feature certain items in connection with your use of the Services. We may usethe responses to these promoted or featured items, or your search queries and results, tocustomize the Services to you.

7.2. We use Google Analytics and/or other Analytics, which use cookies and similartechnologies to collect and analyze information about use of the Services and report onactivities and trends. This service may also collect information regarding the use of otherwebsites, apps and online resources. You can learn about Google’s practices by going to

https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at

https://tools.google.com/dlpage/gaoptout

8. HOW YOU MAY ACCESS, DELETE, OR CHANGE INFORMATION YOU HAVEPROVIDED WITH OUR SERVICES

8.1. You can exercise your rights to access, rectify, erase and object the processing ofyour personal information at any time by sending a written request to CoCo College’smail at

team@cococollege.comor by deleting your account directly under your settings tab in the page account option.

8.2. In order to properly attend your request, please make clear what personal informationyou are writing about to the email. For your protection, we may only respond to requestsfor the personal information associated with the university (Boston University’s) emailaddress you use (when creating your account) to send us your request, and we may needto verify your identity before implementing your request. We will try to comply withyour request as soon as we can, but we may need to retain certain information for ourrecord keeping purposes and there may also be residual information that will remainwithin our databases and other records, which will not be able to be removed.

9. OUR COMMITMENT TO SECURE THE PERSONAL INFORMATION WE HAVECOLLECTED

​9.1 We seek to use reasonable organizational, technical and administrative measures to

protect personal information within our organization. No website or Internet transmissionis, however, completely secure. Consequently, CoCo College cannot guarantee thatunauthorized access, hacking, data loss, or other breaches will never occur. Your use ofthe Services is at your own risk. CoCo College urges you to take steps to keep yourpersonal information safe by memorizing your password or keeping it in a safe place. Ifyou have reason to believe that your interaction with us is no longer secure, pleaseimmediately notify us in accordance with the “Contacting Us” section below or bycontacting

team@cococollege.com

10. THIRD PARTIES

10.1 This Privacy Policy does not address, and CoCo College is not responsible for, theprivacy, information or other practices of any third parties, including any third partyoperating any site or service to which the Services link.

10.2 We also may use a third-party payment service to process payments made throughthe Services. If you wish to make a payment through the Services, your personalinformation may be collected by such third party and not by us, and will be subject to thethird party’s privacy policy, rather than this Privacy Policy. We have no control over, andare not responsible for, this third party’s collection, use and disclosure of your PersonalInformation.

11. RETENTION PERIOD

11.1 ​We will retain your Personal Information for the period necessary to fulfill the

purposes outlined in this Privacy Policy unless a longer retention period is required orpermitted by law.

12. USE OF COCO COLLEGE BY MINORS

12.1 ​The Services are not directed to individuals under the age of sixteen (16), and we

request that they not provide personal information through the Services. Any content or

information that is disclosed on the website that may result in offense or not applicable topeople under the age of sixteen (16) is not the responsibility of the CoCo College groupor the Services that are being provided.

13. NOTICE OF CHANGES TO THE POLICY

13.1 CoCo College reserves the right to modify this Policy at any time by notifyingregistered users via e-mail of the existence of a new Policy and/or posting the new Policyon the Services. All changes to the Policy will be effective when posted, and yourcontinued use of any CoCo College Services after the posting will constitute youracceptance of, and agreement to be bound by, those changes.

14. CONTACTING US

14.1 If you have any questions or comments regarding this Policy, please contact us byemail at

team@cococollege.com

Please do not send sensitive information to us by email,

since email communications are not always secure.