Privacy Policy

Co-Op Managers ("Co-Op Managers," "we," "us," or "our") administers co-op advertising programs for manufacturer brands and operates Co-Op Command, the software platform manufacturers, brand administrators, and dealer or retailer locations use to run those programs. This Privacy Policy describes the information we collect through co-opmanagers.com and app.co-opmanagers.com, how we use and share it, and the rights and choices available to you. If you have questions after reading it, contact us at privacy@co-opmanagers.com.

1. Scope of This Policy

This policy applies to everyone who interacts with us in the following ways:

• Website visitors. Anyone who browses co-opmanagers.com, whether or not they submit a form.
• Business contacts. Employees or representatives of manufacturer brands, dealers, retailers, distributors, or wholesalers whose business contact information appears in our systems because we administer, or have approached them about, a co-op program.
• Platform users. Individuals who hold a login account on Co-Op Command at app.co-opmanagers.com, whether as a brand administrator, a dealer or location user, or in any other authorized role.
• Our employees and staff. Individuals who operate the platform and administer programs on our clients' behalf. This policy describes the categories of employee data we hold to the extent relevant to how the platform functions, but it is not a comprehensive employment privacy notice.

This is a business-to-business service. We do not knowingly collect information from, or direct any part of our website or platform to, individual consumers acting in a personal capacity, except to the extent a dealer or retail location's own personnel interact with the platform in their professional role.

2. Information We Collect

2.1 Information collected automatically from website visitors

When you visit co-opmanagers.com, our analytics provider, Project Crumb, automatically collects information about your visit, including the pages you view, links you click, the order in which you move through the site, how long you spend on a page, the general type of device and browser you are using, and the referring source that brought you to the site (including any campaign or advertising identifiers appended to the link you followed). Project Crumb assigns your browser a first-party cookie, described in Section 5, so that repeat visits from the same browser can be recognized as belonging to the same visitor. This is described in full detail in Section 4.

Our web servers and hosting infrastructure also automatically log standard technical information for every request, including your IP address, browser and operating system identifiers (user agent string), the date and time of the request, and the page or resource requested. We keep these logs for security monitoring, abuse prevention, and diagnosing technical problems.

2.2 Information you submit directly

If you fill out a contact form, request a program review, or subscribe to our newsletter through co-opmanagers.com, we collect the information you provide, which typically includes your name, business email address, company or brand name, phone number if provided, and the content of any message you send us. This information is stored in our internal customer relationship management system (our "CRM") as a lead record and is used to respond to your inquiry and, where you have not opted out, to follow up about our services.

2.3 Business contact information in our CRM

Because we administer co-op advertising programs and conduct business development for manufacturer brands, our CRM contains business contact records for individuals at manufacturer brands, dealers, retailers, distributors, and wholesalers. This information typically includes name, business email address, business phone number, job title, and company or brand affiliation. This data is compiled from co-op program documentation that is provided to us or that is otherwise available to us in the ordinary course of administering or proposing to administer a co-op program, from information dealers and brands provide directly, and from information you submit to us as described in Section 2.2. This is business contact information used for business-to-business purposes; it is not information about you in a personal or consumer capacity.

2.4 Outbound email and engagement data

When we send email to a business contact, whether an introductory outreach message, a program update, or other business correspondence, we use Project Crumb's email tracking capability to generate a unique tracking link for that specific recipient and to log the send itself against that recipient's contact record. This allows us to see, for that specific individual, whether the email was delivered, opened, and whether a link inside it was clicked, and it allows us to observe that same individual's subsequent activity on co-opmanagers.com if they click through from the email to the website. Section 4 explains this capability, its purpose, and your options regarding it in full.

2.5 Platform account information

Individuals who are issued a login account on Co-Op Command, whether internal staff, a brand administrator, or a dealer or location user, have an account record that includes a username, a securely hashed password (we never store passwords in plain text), display name, and, where applicable, job title, business email address, and phone number. This information is used solely to operate the platform, authenticate account holders, and support the business relationship the account exists to serve. We do not share platform account information with any party outside the business relationship it relates to, except as described in Section 6.

2.6 Data submitted through the platform by our clients

Manufacturer brand clients and their authorized users may enter or upload information into Co-Op Command in the ordinary course of running a co-op program, including dealer and location records, program rules, budgets, order and claim data, creative assets, and related business records. We act as a processor and administrator of this information on our clients' behalf. Section 7 of our Terms of Service governs ownership of this data; this Privacy Policy governs how we handle any personal information contained within it.

3. How We Use Information

We use the information described above for the following purposes:

• Administering co-op programs. Processing accruals, claims, orders, approvals, and reporting on behalf of manufacturer brand clients and the dealer or location networks those programs serve.
• Operating the platform. Authenticating account holders, maintaining account security, providing customer support, and delivering the features of Co-Op Command.
• Business development and outreach. Identifying and contacting manufacturer brands, dealers, retailers, distributors, and wholesalers who may benefit from our services, and measuring the effectiveness of that outreach as described in Section 4, so that we can prioritize follow-up appropriately and avoid contacting people who have asked not to be contacted.
• Responding to inquiries. Answering questions submitted through our contact form or by email or phone, and following up on requests for a program review or demonstration.
• Improving our website and services. Understanding which pages and content are useful to visitors so that we can improve the site and the information we publish.
• Security and fraud prevention. Detecting, investigating, and preventing unauthorized access, misuse, or fraudulent activity affecting our website or platform.
• Legal compliance. Meeting our legal, regulatory, tax, and accounting obligations, and responding to legal process as described in Section 6.

We do not use any of the information described in this policy to serve you third-party advertising, and we do not use it to build advertising profiles for sale or transfer to advertising networks or data brokers.

4. Project Crumb: Analytics and Email Engagement Tracking

This section explains, in full, what Project Crumb is, exactly what it tracks, why we use it, and what we do and do not do with the information it collects, because we believe this capability deserves a plain and complete explanation rather than a vague reference elsewhere in this policy.

4.1 What Project Crumb is

Project Crumb is a first-party analytics and attribution platform that we use internally to understand how visitors use co-opmanagers.com and how recipients engage with email we send. It is not Google Analytics, it is not a Meta or Facebook Pixel, and it is not an advertising network. Project Crumb runs on our own infrastructure and under our own control, and the data it collects is not accessible to, sold to, or shared with any advertising company, data broker, or unrelated third party.

4.2 What it tracks on the website

On co-opmanagers.com, Project Crumb records the pages a visitor views, the order in which they are viewed, links clicked, approximate time spent on each page, general device and browser information, and the source or campaign that referred the visitor to the site. It recognizes repeat visits from the same browser using the first-party cookie described in Section 5.

4.3 What it tracks in outbound email

When we send an email to a business contact, each link in that email is replaced with a unique tracking link that is specific to that one recipient and that one send. When the recipient opens the email or clicks a link, Project Crumb records that the specific recipient took that action, at what time, and it can then recognize that same recipient's browser if they land on co-opmanagers.com, allowing us to see what that individual does on the site after clicking through from our email. We refer to this collectively as email engagement tracking.

4.4 Why we use it

We use email engagement tracking exclusively for our own internal sales and customer success purposes: understanding whether outreach is being read and acted on, prioritizing follow-up with people who have shown genuine interest, avoiding repeated outreach to people who have not engaged, and honoring opt-out and unsubscribe requests promptly and reliably. We do not use it to build a profile of you for any purpose unrelated to our own business development and client service, and we do not use it for advertising, whether on our own site or anywhere else.

4.5 What we do not do with this data

We do not sell, rent, license, or otherwise share email engagement or website analytics data collected through Project Crumb with any third party for their own independent use. We do not share it with advertising networks, data brokers, or data cooperatives. We do not use it to retarget you with advertising on other websites or platforms. The only parties with access to this data are our own authorized personnel who need it to do their jobs, and Project Crumb itself, which processes it on our behalf as our service provider and under confidentiality and data protection obligations to us, as described in Section 6.

4.6 How long this data is kept

Website analytics and email engagement data is generally retained for as long as reasonably necessary to support the business purposes described above, and in any case no longer than 36 months from the date of the underlying visit, email send, or event, after which it is deleted or aggregated into a form that no longer identifies an individual. We may retain records for a longer period where necessary to comply with a legal obligation, resolve a dispute, or enforce our agreements.

4.7 Your choices

You can ask us at any time not to track your engagement with our email or website, or to delete tracking data we hold about you, by emailing privacy@co-opmanagers.com with the email address or name associated with the outreach you received. Every marketing email we send includes an unsubscribe mechanism, and unsubscribing stops both future email and the engagement tracking associated with future sends to that address. You can also control cookies at the browser level as described in Section 5, which will prevent our website analytics from recognizing repeat visits from that browser.

5. Cookies and Similar Technologies

We use only first-party cookies that are necessary or functional to the operation of our website and platform. We do not use third-party advertising cookies, and we do not use Google Analytics, Meta Pixel, Facebook Pixel, or any comparable third-party advertising or social media tracking technology on co-opmanagers.com or app.co-opmanagers.com.

The cookies we use are:

• _crumb_vid. Set by Project Crumb on co-opmanagers.com to recognize repeat visits from the same browser for analytics and email engagement attribution purposes, as described in Section 4. This is a first-party cookie, meaning it is set by and readable only by our own domain, not by a third-party advertiser.
• Platform session cookie. Set by app.co-opmanagers.com when you log in to Co-Op Command, used solely to keep you signed in securely during your session. This cookie is strictly necessary for the platform to function and is not used for tracking or analytics.

Most browsers allow you to block or delete cookies through their settings. Blocking the Project Crumb cookie will not prevent you from using the website, but it will prevent us from recognizing repeat visits from your browser as belonging to the same visitor. Blocking the platform session cookie will prevent you from remaining logged in to Co-Op Command.

6. How We Share Information

We do not sell personal information. We have not sold personal information in the preceding twelve months and we do not intend to. We share information only in the limited circumstances described below.

6.1 Service providers acting on our behalf

We share information with third-party service providers who perform services for us and who are contractually obligated to use that information only to provide those services to us and to protect it with appropriate confidentiality and security measures. These service providers include our email delivery infrastructure, which transmits the email we send, our website and application hosting provider, which stores and serves our website and platform, and Project Crumb, which processes analytics and email engagement data on our behalf as described in Section 4. None of these providers is authorized to use the information for their own independent purposes or to share it further.

6.2 Legal and regulatory disclosure

We may disclose information if required to do so by law, subpoena, court order, or other legal process, or if we believe in good faith that disclosure is necessary to comply with a legal obligation, protect the rights, property, or safety of Co-Op Managers, our clients, or the public, investigate or prevent fraud or security issues, or respond to a government or regulatory request.

6.3 Business transfers

If Co-Op Managers is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, information may be transferred as part of that transaction. We will provide notice, through this website or another reasonable means, before information becomes subject to a different privacy policy as a result of such a transaction.

6.4 With your direction or consent

We may share information in any other circumstance where you have directed us to do so or otherwise given your consent.

6.5 Our voluntary privacy commitment

We are a business-to-business company and may not meet the revenue or data-volume thresholds that trigger full applicability of laws such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, "CCPA"). Regardless, we have written this policy, and we operate our data practices, consistent with the spirit and intent of the CCPA and comparable privacy laws, including the "we do not sell personal information" commitment above and the rights described in Section 9.

7. Data Retention

We retain information for as long as reasonably necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law. As general guidance:

• Website analytics and email engagement data is retained as described in Section 4.6.
• Contact form, newsletter, and lead records are retained for as long as the business relationship or prospective relationship is active, and are periodically reviewed and purged where a contact has gone inactive for an extended period and has not engaged with our outreach or asked to remain on file.
• Business contact records used to administer a co-op program are retained for the duration of the program and for a reasonable period afterward to support historical reporting, audit, and legal recordkeeping needs.
• Platform account information is retained for as long as the account is active and for a reasonable period after deactivation to support account recovery, audit, and legal recordkeeping needs.
• Server and security logs are retained for a limited period sufficient for security monitoring and incident investigation purposes, typically not exceeding twelve months.

8. Data Security

We use encryption in transit (HTTPS/TLS) for all traffic to and from co-opmanagers.com and app.co-opmanagers.com. Platform account passwords are stored using a one-way cryptographic hash and are never stored or transmitted in plain text. Access to systems containing personal information is limited to employees and authorized personnel who need it to perform their job functions, and access is reviewed periodically. No method of transmission or storage is completely secure, and we cannot guarantee absolute security, but we work to protect information using measures appropriate to its sensitivity.

9. Your Rights and Choices

9.1 Access, correction, and deletion

You may ask us to tell you what personal information we hold about you, to correct inaccurate information, or to delete your information, by emailing privacy@co-opmanagers.com. We will respond within a reasonable time and will honor your request except where we have a legitimate business or legal reason to retain certain information, such as an active program relationship, an unresolved dispute, or a legal recordkeeping obligation, in which case we will explain the reason.

9.2 Marketing opt-out

You may opt out of marketing and outreach email at any time by using the unsubscribe link included in the message or by emailing privacy@co-opmanagers.com. Opting out of marketing email does not affect transactional or program-related communications necessary to operate an active co-op program or platform account.

9.3 Tracking opt-out

You may ask us to stop tracking your engagement with our website or email, or to delete existing tracking data associated with you, as described in Section 4.7.

9.4 California residents

Consistent with our voluntary privacy commitment in Section 6.5, California residents may exercise the rights described above, including the right to know what personal information we have collected about them, the right to request deletion, the right to correct inaccurate information, and the right to opt out of the sale or sharing of personal information (which, as stated in Section 6, we do not engage in). We will not discriminate against you for exercising any of these rights.

9.5 Rights for individuals outside the United States

Although Co-Op Managers is a United States company and this is not a service directed at individuals in the European Union, the United Kingdom, or other jurisdictions with comprehensive data protection laws, we will make good-faith efforts to honor requests consistent with rights commonly recognized under such laws, including access, correction, deletion, and objection to processing, from anyone who contacts us at privacy@co-opmanagers.com, regardless of where they are located.

10. Children's Privacy

Our website and platform are intended for business use by adults acting in a professional capacity and are not directed at children. We do not knowingly collect personal information from anyone under the age of 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete it promptly.

11. International Users

Co-Op Managers is based in the United States, and the information we collect is processed and stored in the United States. If you access our website or platform from outside the United States, you understand and agree that your information will be transferred to, stored, and processed in the United States, which may have data protection laws that differ from those of your home jurisdiction.

12. Third-Party Links

Our website may contain links to third-party websites that are not operated by us. This Privacy Policy does not apply to those third-party websites, and we encourage you to review the privacy policy of any third-party site you visit.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the updated policy on this page with a revised effective date at the top. If we make a material change to how we handle personal information, we will provide additional notice, such as a notice on our website or an email to affected contacts where appropriate. Your continued use of our website or platform after a change becomes effective constitutes acceptance of the updated policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Co-Op Managers
Email: privacy@co-opmanagers.com
Website: co-opmanagers.com