Last Updated and Effective Date: 18 December 2025 

This Privacy Policy describes how Coherent Technical Services, Inc. (“we,” or “us”) collects, uses, discloses, and processes your Personal Information (“you” and “your”), as well as rights that you may have regarding that information.  We reserve the right to change this Privacy Policy at any time.  If we change our Privacy Policy, we will post an updated version on this website.  Please check back periodically to see if our Privacy Policy has been updated.  Updates to the Privacy Policy will be referenced by the "Last Updated and Effective Date" date shown above.  By visiting this website, you acknowledge and consent to the privacy practices described in this Privacy Policy, including any revisions to this Privacy Policy that we post.

1. Definitions.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, household or device. “Personal Information” does not include: (a) information that is lawfully made available from federal, state, or local government records; (b) information that we have a reasonable basis to believe is lawfully made available to the general public by you from widely distributed media.; or (c) information that is deidentified or aggregated consumer information.  

“Sensitive Personal Information” means Personal Information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial, ethnic, or national origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; (e) the contents of an mail, email, and text messages unless we are the intended recipient of the communication; (f) genetic data; (g) information about a child; (h) biometric information for the purpose of uniquely identifying an individual; (i) mental health, physical health and pregnancy; (j) sex life or sexual orientation, including status as a trans or nonbinary individual; (k) status a crime victim; and (l) neural data. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information. 

Please note that various jurisdictions may use different terms.  For example, some jurisdictions use the terms “personal data” or “sensitive personal data”.  Moreover, some jurisdictions do not consider some of the Personal Information listed in the Sensitive Personal Information definition above as Sensitive Personal Information.

2. Information We Collect and the Categories of Source of Collection.

Set forth below are the categories of Personal Information we collect and that have collected in the preceding 12 months and the categories of sources from which the Personal Information was collected.  Please note that we may not collect all of the information referenced below regarding you.

‍

‍

* See the section entitled Online Technologies below.  

We do not collect or use Sensitive Personal Information. 

We also collect aggregated, de-identified or anonymous data that does not identify individual consumers.  We collect this information for various purposes such as statistical or demographic data for legitimate business purposes not prohibited herein or by law.  We commit to maintain and use such data without attempting to re-identify the data.  

3. Business or Commercial Purpose for the Collection of Personal Information.

Set forth below are the business or commercial purpose for our collection of Personal Information.  Please note that we may not use your Personal Information for all purposes set forth in this Privacy Policy.

• To provide you with and improve our services, including account servicing and customer support
• To personalize our products and services for you
• To respond to inquiries, send notices, messages, and related communications
• To conduct marketing and advertising 
• To operate our website, tailoring content, features, and user experiences
• To operate and manage IT and communications systems and facilities, including functionality and debugging of our website
• To maintain security on our websites and internet-connected assets and to detect fraud
• To audit ad impressions 
• To analyze usage and trends
• To audit interactions, transactions, and compliance
• To measure ad impressions and effectiveness
• To detect and prevent security incidents
• To protect against malicious, deceptive, fraudulent, or illegal activity
• To maintain the integrity of our systems and data
• To identify and fix errors that impair functionality.
• To undertake internal research and development
• To verify, maintain and/or improve the quality, safety, and performance of products, services, and devices
• To prevent and manage fraud and abuse
• To manage risk 
• To meet and comply legal, regulatory, tax, and reporting obligations
• To enforce contracts and terms
• To exercise or defend legal claims
• To operate loyalty, referral, and rewards programs
• To administer surveys, sweepstakes, and events
• To train large language models
• See also the next section regarding Online Technologies

4. Online Technologies.  

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer.  Cookies contain information that is transferred to your computer's hard drive. We, our service providers and partners, including Google, may use cookies or similar technologies, such as web beacons and tracking pixels to analyze trends, administer our website, personalize content and ads, track users’ movements around our website to provide you with the most relevant browsing experience, to gather demographic information about our user base as a whole and to provide marketing services. 

We may use several types of cookies and other tracking technologies on our website, as described below.  

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. 
• Functionality/preference cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Statistical, analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Marketing/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it and on third-party websites more relevant to your interests. 
• Third-party cookies.  These cookies are placed on your device by a website from a domain other than our website.  These parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies include analytical cookies, performance cookies and targeting cookies.
  
  • We may use third party advertising companies to place ads.  We do this by allowing our advertising and social media partners to place their cookies on a browser of an individual who visits our site.  The data received by our third party advertising and social media partners allows them to measure the effectiveness of such advertising and to provide advertisements on other websites about our services which are tailored to your interests.  
  • We may use Google Analytics to ensure website functionality and improve our website and services.  This software may record information such as your IP address, location, age and gender, browser type and language, operating system, access time, duration of visit, pages you view within our website, search terms you enter and other actions you take while visiting us, the pages you view immediately before and after you access the services, how often you use our Services, aggregated usage and performance data, app errors and debugging information.  Data collected by Google is subject to its privacy policy.  To learn how Google uses data related to website analytics, please click here.  You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available here.

In addition, we may use web beacons and pixels, which are images that can be placed in web pages and some forms of email.  These technologies can be used to deliver cookies and to collect information about your use of the site.  Finally, we may also collect information through tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel or Javascript tag) that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the page of the site that contains the tracking pixel.  We may use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our site.  Other entities may have access to some of this information.  

Emails that we and our service providers may send may include similar technologies that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email.  More information on how to unsubscribe from our marketing emails is found below.

If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this.  Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

By using our website and services you affirmatively agree to the use of online technologies disclosed in this Privacy Policy.

5. Personal Information We Disclose, Share for Targeted Advertising or Sell and the Purpose for It.

Disclosure of Personal Information to Service Providers

We disclose your Personal Information to service providers, vendors, and contractors that perform services on our behalf. The following sets forth the categories of Personal Information we have disclosed to our service providers for a business purpose over the past 12 months.

• Personal Information
  
  • Personal Identifiers 
  • Internet Information
  • General Geolocation Data
  • Inferences

We disclose and have disclosed in the preceding 12 months the foregoing categories of Personal Information to our service providers and contractors for the following business purposes:   

• Auditing of Ad Impression: We disclose Personal Information for auditing purposes related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Security and Fraud Detection: We disclose Personal Information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
• Functionality & Debugging: We disclose Personal Information to engage in debugging to identify and repair errors that impair existing intended functionality.
• Short-Term / Transient Use: We disclose Personal Information for short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s Personal Information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
• Services on Our Behalf: We disclose Personal Information in order to receive services performed on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
• Advertising and Marketing Services: We disclose Personal Information to provide advertising or marketing services on our own behalf.
• Research & Development: We disclose Personal Information for internal research related to technological development and demonstration.
• Quality Control & Improvement of Products and Services: We disclose Personal Information to verify, maintain, and improve our products and services.

Disclosure for Other Purposes

We have disclosed Personal Information to our service providers for the following additional purposes.  Please note that we may not have disclosed all of the information referenced herein regarding you to our service providers and/or may not have disclosed all information regarding you to our service providers for all purposes set forth in this Privacy Policy.

As Necessary Disclosures

We may also use and/or disclose Personal Information, as necessary: (a) to comply with any law, regulation and/or legal process and/or exercise or defend legal claims; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.  We may also use and disclose your Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).  You acknowledge that such transfers may occur and that any acquirer of or successor to us may continue to use your Personal Information as set forth in this Privacy Policy.

Selling and Sharing (for Targeted Advertisement) of Personal Information

We do not sell your Personal Information as that term is commonly understood to be disclosure of your Personal Information in exchange for money.  Rather, as used herein, definition of sale includes situations where another company can use your Personal Information for its own purposes.  Please see the Online Technologies section above.

As noted in the Online Technologies section, we use third party cookies and, under California law, the disclosure of data received by our third-party advertising and social media partners may be considered a sale of Personal Information.

However, please note that we do not share for cross-context behavioral advertising Personal Information that we collect.

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

Our Retention Policy – How Long We Keep Your Personal Information.

We will retain each category of your Personal Information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Information pursuant to any applicable contract, law or regulation.  To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Data Security.

We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the Personal Information we collect, use, process and disclose. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information.  We evaluate these measures on a regular basis to help ensure the security of the processing.  Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

7. Email Communications.

You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in our commercial emails we send, or by sending us a request to information@goctsi.com.  If you opt-out of receiving marketing email communications, we may still send you email messages related to specific transactions with us.  Unsubscribing yourself from our marketing communications will not affect our service to you.

8. Children. 

We do not direct our websites or applications to children under thirteen (13) years of age.  We do not knowingly collect information from persons under 13 years of age or provide any Personal Information from such persons to any third party for any reason whatsoever.  We do not allow persons known to be under 13 years of age to receive direct marketing communications from us.  No information should be submitted to our website or applications by persons under 13 years of age.  When appropriate, we may ask you to indicate your date of birth to verify compliance with the age requirements set forth herein. 

9. Consumer Rights. 

Your Rights if You Are a Resident of California  

California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act, as amended, and related regulations (CCPA).  Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

• Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting, selling, or sharing Personal Information; (4) the categories of parties to whom we disclose Personal Information; and (5) the specific pieces of Personal Information we have collected about you.  You also have the right to know the list of all third parties to whom we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. 
• Right to Know Personal Information Disclosed, Sold or Shared and to Whom.  You have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; (2) the categories of Personal Information that we sold or shared about you and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold or shared; and (3) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.  
• Right to Request Deletion of Your Personal Information.  You have the right to request that we delete your Personal Information.  However, there a are number of situations where you do not have the right that we delete your Personal Information.  For example, you cannot request that we delete your Personal Information if it is reasonably necessary for us to comply with a legal obligation, complete the transaction for which the Personal Information is collected or provide the services that you have requested or reasonably anticipated by you within the context of our ongoing business relationship, or to otherwise perform a contract between us.  We also will not delete your Personal Information from our backup systems to the extent permitted by the CCPA.  Following receipt of a request, we will let you know what, if any, Personal Information we can delete.  If we cannot delete all of your Personal Information, we will let you know the reason.  
• Right to Correct Inaccurate Information.  If you believe that any of the Personal Information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information.  Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct.  
• Right to Opt-Out of the Sale and Sharing of Your Personal Information.  You may opt-out of the sale of your Personal Information, to the extent applicable, by clicking here: Do Not Sell My Personal Information. Please note that given our data practices, the right to opt out of sharing for cross-context behavioral advertising does not apply to you.
• Right to Limit the Use of Your Sensitive Personal Information.  You have the right to limit the use of Sensitive Personal Information under circumstances. Given that we do not collect or disclose Sensitive Personal Information, this right does not apply to you.  
• Right to Not to be Retaliated Against. If you choose to exercise any of your rights, you have the right not to be retaliated against.  

How to Make a Consumer Request

For California residents: (a) you can exercise your rights to opt-out of the selling and/or sharing of your Personal Information or to limit the use of your Sensitive Personal Information (to the extent applicable to you) by: (i) clicking the link provided above or (ii) enabling the setting in a browser that supports an opt-out preference signal (also known as universal opt-out mechanisms); and (b) for all other requests (to the extent applicable to you), you can make a request by sending us an email at information@goctsi.com  or by calling us at 1-877-741-2278.

When you make certain requests (e.g., a request to know, delete and/or correct; or a request for access or data portability), to help protect your privacy and maintain security, we will take steps to verify your identity.  Our verification procedure may differ depending on whether you have an account with us or not and the request you are making.  The following generally describes the verification processes we use:  

• Verification for Non-Accountholders.  If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
  
  • For valid requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
  • For valid requests to know specific pieces of Personal Information, right of access and right to data portability, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us.  
  • For valid requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion.  We will act in good faith when determining the appropriate standard to apply.

We may also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative.  

If there is no reasonable method by which we can verify your identity, we will state so in response, including an explanation of why we have no reasonable method to verify your identity.

If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request.  

There may be situations where we cannot grant your request.  For example, if you ask us to delete Personal Information that we are obligated to keep to comply with applicable law we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your Personal Information serves a legitimate purpose such as for security purposes.  Your request may also be denied if it compromises the privacy of others, is overly repetitive or extremely burdensome to fulfill.  

We will respond to valid requests to know, requests to correct and / or delete no later than 45 calendar days.  If we cannot verify your request within 45 days, we may deny your request.  If necessary, we may take up to an additional 45 days to respond to your request but in such an event we will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.   

Valid requests under “Right of Access” and “Right to Data Portability” will be transmitted securely. If we cannot fulfill your request, we will notify you of that decision and the reasons why within 45 days. At that point if you believe our decision was in error, you may have the right to submit an appeal using the method(s) above.  If the result is the same, you can also seek assistance and/or redress from your state attorney general.

Nevada Privacy Notice

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity.  Our uses of your Personal Information are not sales under Nevada law, so no opt-out right applies.

10. How to Contact Us.

If you have any questions or concerns about our privacy policies and practices, please feel free to contact us by calling us at 1-877-741-2278. or by emailing us at information@goctsi.com.