Privacy Policy

Func Digital LTD (“Func Digital,” “we,” “us,” or “our”) operates the cooperly.ai website and any related software or mobile applications (collectively, the “Service”). We respect your privacy and are committed to protecting it by complying with this Privacy Policy.

This Privacy Policy describes the information we collect from you as part of the regular operation of our Service, and how we use and disclose that information.

By using our website or the Cooperly service, you acknowledge that we will process personal data as described in this Privacy Policy. Where we rely on consent (for example, for non-essential cookies or certain marketing communications), we will ask for your consent separately and you can withdraw it at any time.

This Privacy Policy explains how we process personal data. Our Terms & Conditions govern your use of the Service.

1. Introduction

Our role (Controller vs Processor)

Depending on how you use Cooperly.ai, we act as either a data controller or a data processor:

  • Website visitors and marketing contacts: Func Digital LTD is the data controller of personal data collected via our website, cookies, contact forms and marketing communications.
  • Cooperly product (team data): When a company uses Cooperly for its team, that company is the data controller for personal data relating to its employees/contractors (including responses in Coop Profiles, Pulse and Team Fundamentals). In this context, Func Digital LTD acts as a data processor and processes such data on the controller’s documented instructions

If you are an invited team member and you want to exercise your data protection rights, please note that in many cases your employer or the organisation that invited you to Cooperly is the appropriate point of contact as the controller. You can also contact us at privacy@cooperly.ai and we will support the controller as required.

Purpose of This Policy‍

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit or use cooperly.ai. By accessing or using the Service, you agree to the collection and use of information in accordance with this Policy and our Terms & Conditions.

Legal Basis

We process personal data in compliance with UK data protection laws, including the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Age Restriction

Our Service is not intended for anyone under the age of 18. If we learn that personal data has been collected from someone under 18 without appropriate authorisation, we will take steps to delete such information.

Contact Information

If you have questions about this Privacy Policy, please contact:
Func Digital LTD
email: privacy@cooperly.ai

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2. Information We Collect

If you choose to invite others to join cooperly.ai, we may request contact information (e.g., their names, email addresses) in order to send them an invitation. We may also receive Personal Information from other users: for example, if they refer you or attempt to grant you access to their cooperly.ai account. By providing someone else’s Personal Information, you confirm you have the right to do so and acknowledge that we may collect, use, and disclose this information as described in this Privacy Policy.

Personal Data You Provide

  • General Data
    • IP address, browser type, device and software details
    • Web page visited before coming to the Site
    • Search queries and actions on our Site
    • Locale preferences and time/date stamps
    • Metadata concerning your files and usage patterns
  • Registration Details: Corporate email address, password, and potentially your name and role, if you register as a Team Leader.
  • Team Member Data: Invitation-based registration details (name, corporate email, role) provided by Team Leaders or by Team Members themselves.
  • Profile/Survey/Check-in Data: If you participate in the “Coop Profile” test or other check-ins, we may collect your responses and insights derived from them.

Team data processed in the Cooperly product

When you use Cooperly as part of a team, the service may process information you provide or generate in the product, such as:

  • Coop Profile responses (work preferences, communication preferences, feedback preferences, signals),
  • Pulse check-ins (for example “ok/not ok” and short context),
  • Team Fundamentals responses (trust, clarity, accountability, workload, progress),
  • Team and account metadata (organisation name, role, invitation status, timestamps),
  • Derived summaries or insights created to help the team leader understand team status and improve communication.

In the Cooperly product context, this data is typically processed on behalf of the organisation that invited you (the controller).

Automatically Collected Data

  • Log Files: IP address, browser type, device information, pages visited, and timestamps.
  • ‍Cookies & Similar Technologies: We use cookies, local storage, or similar tools to enhance user experience and analyse usage. For more details, see Section 6 (Cookies & Tracking).

Sensitive Personal Data

We do not intentionally collect sensitive personal data (e.g., health, political, religious, or biometric data). If you upload such data in violation of our Terms & Conditions, we may delete it and/or suspend your account.
Do not include sensitive personal data in free-text fields

3. How We Use Your Information

Service Provision

To create and manage user accounts, process invitations, maintain teams, and enable features such as check-ins, Pulse, and Coop Profile results.

Communications

To send administrative updates (e.g., changes to our Service or this Policy), respond to inquiries, or provide customer support.

Analytics & Improvements

To analyse usage trends, improve the Service’s functionality and user experience, and develop new features (e.g., refining AI-driven insights).

Automated decision-making

Cooperly may generate summaries or insights to assist team leaders (for example, trend indicators or prompts). We do not make decisions about individuals based solely on automated processing that produce legal effects or similarly significant effects.

Legal & Compliance

To comply with legal obligations, enforce our Terms & Conditions, and protect against fraud or misuse.

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4. Lawful Bases for Processing

We rely on one or more of the following legal grounds for processing your personal data:

Performance of a Contract

When processing is necessary to provide the Service you’ve requested, such as managing your account or fulfilling subscription features.

Legitimate Interests

To maintain the security of our platform, prevent fraud, improve user experience, or market our services (subject to your opt-out rights).

Legal Obligations

Where UK or other applicable law requires data processing for compliance.

Consent

Where required by law (including under UK PECR / EU ePrivacy rules), we will obtain your consent before placing or accessing non-essential cookies or similar technologies. You can change your cookie preferences at any time using our cookie banner (or settings, where available).

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5. Information Sharing and Disclosure

Any user content or information you provide via the Service may be shared with other users in your account or with people to whom you explicitly grant access.

Service Providers, Business Partners, and Others

We employ trusted third-party companies and individuals to perform certain tasks on our behalf (e.g., maintenance, analytics, payment processing). These third parties have access to information only for performing specific tasks and are obligated to protect it under terms comparable to those in this Privacy Policy.

Third-Party Applications

We may share your information with a third-party application when you choose to link or otherwise integrate it with our Service. We are not responsible for how these third parties handle your information; please review their respective privacy policies for more details.

Compliance with Laws and Protection of Rights

We may disclose information when we believe, in good faith, that such disclosure is necessary to:

  • Comply with any applicable law, regulation, or legal process
  • Protect the safety of any person
  • Prevent or address fraud, abuse, or unlawful activity
  • Enforce or protect our property rights

Business Transfers

If Func Digital LTD or cooperly.ai is involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction. We will notify you of any change in ownership or use of your information and any choices you may have, where required.

Non-Private or Non-Personal Information

We may share aggregated, anonymised, or otherwise non-personal information publicly and with third parties for research, marketing, analytics, or similar purposes.

Team Leader & Team Members

If you’re a Team Member, certain data (e.g., your Coop Profile status) may be visible to your Team Leader and other Team Members, as necessary for the Service’s functionality.

6. Cookies & Tracking Technologies

Use of Cookies

We use cookies and similar technologies on our website. Some cookies are strictly necessary for the site to function. Others are used for analytics and to understand how visitors use our website (for example, Google Analytics and Hotjar).

Where required by law, we will place or access non-essential cookies only after you provide consent through our cookie banner (or settings, where available). You can withdraw or change your consent at any time using the same tool.

You can withdraw or change your consent at any time using our cookie banner (or browser settings, where available).

Analytics Tools

We collect information (ourselves or through third parties) for:

  • Technical administration of the Service
  • Analysing usage patterns to improve functionality and user-friendliness
  • Verifying user authorisation and processing requests

We may use third-party analytics providers such as Google Analytics, Hotjar and similar to help us understand our Site traffic and user interactions:

  • Google Analytics: Helps us analyze web traffic and usage. You can learn more by visiting Google’s Privacy Policy.
  • Hotjar: Helps us understand user interactions on our Site (e.g., clicks, scroll depth). You can learn more by visiting Hotjar’s Privacy Policy.

Disabling Cookies

You can disable cookies in your browser. However, some features of the Service might not function properly without them.

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7. Data Retention

Duration

We retain personal data as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required by law.

Account Closure

If you delete your account, we will erase or anonymise your data unless retention is required to meet legal obligations or protect our rights.

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8. Data Subject Rights (UK GDPR)

You may have the right, subject to certain exemptions, to:

  1. Access your personal data.
  2. Rectify inaccuracies in your data.
  3. Erase your data (right to be forgotten).
  4. Restrict or object to certain processing.
  5. Port your data to another provider.
  6. Withdraw Consent (where consent is the legal basis for processing).

Requests can be sent to: privacy@cooperly.ai. We may need to verify your identity before responding to a request. We aim to respond within one month, although this period may be extended in certain cases where permitted by law.

9. International Data Transfers

If we transfer personal data outside the UK or the EEA, we will ensure appropriate safeguards are in place. These may include:

  • the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as applicable, and/or
  • reliance on an applicable adequacy decision where available.

We also take additional measures where appropriate to protect personal data in line with applicable law.

10. Security Measures

We take commercially reasonable security measures to protect against unauthorised access, alteration, disclosure, or destruction of your data. However, no method of transmission or storage is 100% secure. You are responsible for safeguarding your password and other authentication credentials.

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11. Changes to This Privacy Policy

We may update this Policy from time to time. If changes are material, we will notify you (e.g., by posting a prominent notice on the Site or emailing you). By continuing to use the Service after those changes take effect, you agree to be bound by the revised Policy.

12. Data Processing Addendum

If you are a customer organisation, our processing of team data in the Cooperly product is governed by our Data Processing Addendum (DPA), which forms part of the customer contract and sets out the required terms for processor services (including sub-processors, security measures, assistance with data subject requests, breach notifications and deletion/return of data). The DPA is available on request at privacy@cooperly.ai.

13. Contact Us

If you have questions about this Privacy Policy, please contact:
Func Digital LTD
email: privacy@cooperly.ai