Privacy Policy

Last updated: September 19th, 2024

This privacy policy (“Privacy Policy”) describes how data is collected by CokePay Mobile Application (“CokePay”), in relation to the use of our mobile application and our services (collectively “Services”), and how data and personal information is collected and used, and your rights in relation to the collection, storage use and sharing of data and personal information. CokePay is Developed by Netclearance Systems, Inc. (NCS) and provided by CC1 Limited Partnership (“CC1”), under licence. CokePay is administered by NCS in coordination with CC1’s service Providers & Affiliates.

Personal information may be requested any time you contact CokePay Service Department or a CokePay-affiliated company. CokePay, NCS and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, Services, content, and advertising. We reserve the right to change any provision of the Privacy Policy at any time. We will send out a notice when changes have been made to the Privacy Policy that materially affect you, and indicate by what time those changes will be implemented, unless otherwise dictated by law. You are encouraged to review the Privacy Policy from time to time.

1. Collection and Use of Personal Information a. What We Collect Personal information is information that can be used to specifically or explicitly identify or contact a single person.  We may collect a variety of information, including your full name, telephone number, address, email address (“Personal Information”), and contact preferences when you create an account, register for special Services, download updated software or participate in a survey, or contact customer support.

When you use the CokePay mobile application or use our Services, we collect information sent to us by the means with which you contacted us, such as your computer, mobile phone, or other device used to access us or the Services. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data, and other information (“Usage Data”). When you use the CokePay Services, we may also collect information about your transactions and your activities on the CokePay mobile application.

In the case you take advantage of our gifting Services, sending information, gift certificates, or products, or invite others to join the Services, CokePay may collect the information you provide about those people such as name, address, email address, and telephone number.

In certain cases, we may work with social media sites. Information received from social media sites is controlled by them, and if information from a social media site is sent to us, you agree that we may collect store, and use this information in accordance with our own Privacy Policy.

b. How We Use It We use your Personal Information to register you, provide you Services, and complete transactions in which you enter with us or using the Services. We may also use your Personal Information for communications; from time to time, we may use your Personal Information to send updates and important notifications, such as changes to our documentation (terms conditions policies, and procedures) and because this communication pertains to the provision of your Services, you may not opt out of receiving these updates. We may also use your Personal Information to improve our products, content and Services. In the case of a promotion of any kind, any Personal Information given may be used to administer such promotion. We may also use this information to send target marketing and promotional offers based on your preferences.

2. Collection and Use of Non-Personal Information What We Collect & How We Use It We may collect non-personal information; data we collect about the use of the Services or about a group or category of Services or users, from which individual identities or other Personal Information has been removed or in anonymized form that does not directly identify you.

We may also collect:

Demographical Information, such as age range, gender, time zone, state, city, area code, zip code, climate characteristics, language preference & device identifier. The items help us determine to whom we should tailor Services.

Transactional Data such as whether a transaction took place, what kind of device was used, was the transaction successful, over what route the transaction came, how long it takes to complete the transaction, et al. These items help us keep up the Services and improve the service we provide to you.

Behavioral Information where a transaction takes place, when a transaction, time of year, time of day, what was purchased, and whether it is a repeat transaction. This information helps us improve the products and Services we provide to you as a consumer and helps us to determine how we should tailor Services.

In the case non-personal information is combined with Personal Information, the result will be treated as Personal Information.

3. Cookies and Other Technologies We may use small text or data files known as “Cookies” (or other technology such as web beacons, pixel tags, “Flash cookies” or other local storage provided by your mobile web browser or other applications).  These are tools that help us recognize you as a return user, customize your user experience (such as content and advertising), and measure our performance in servicing you. This technology can also prevent fraud and minimize risk, ultimately leading to a trusted and enjoyable experience.

Pixel Tags allow us to send messages to users, and also to verify whether a user has viewed a page, a message, or an email. We use this technology and information to minimize messages sent to users.

We use Cookies that are used during individual visits, which expire or are deleted or both, after each visit, and Cookies that remain on your devices until they are erased, or they expire or are otherwise destroyed.

Our Cookies are devised so that they will provide us with useful information to customize your experience with CokePay. In the case you do not want to employ the use of Cookies, you may decline the use of them (should you be allowed by the mobile browser) but doing so may interfere, delay, or destroy the use of our Services. Please refer to the support pages provided by your respective technology to learn how to able, disable, block, suspend, or delete Cookies. Cookies may also be used to tailor a service, such as the provision of ads in an application or on a website. In such case, should those cookies be deleted, it may not stop ads from appearing, but would make the ads more random and of less use or interest to you. Cookies may also be used to remember preferences, and in doing so, speed up transactions and minimize wait times. Should those cookies be blocked or deleted, transactions may take longer.

In the case Cookies are somehow combined with Personal Information, the result would be treated as Personal Information.

The CokePay Services are enabled through Bluetooth technology. In some cases, in order to ensure the Services are properly delivered, the CokePay mobile application may restart the Bluetooth connection in order to perform the Services, and such restarting of the Bluetooth connection may interrupt other Bluetooth connections established with that mobile device.

4. Disclosure to Third Parties From time to time we may make certain proprietary or Personal Information available to service providers and affiliates with whom we work, in order to provide our products and Services or who assist in promotional and marketing activities. Personal Information will not be shared or sold to third parties for their marketing purposes, and only be shared by us to fulfill or improve products, Services, and promotional and marketing activities.

We will from time to time employ or contract with service providers who provide Services such as customer support, managing data, delivering products and Services, conducting research, and assessing your interest in the products and Services. These service providers are obligated to keep your Personal Information protected.

When necessitated or compelled by law, legal process, or legitimate requests from authorities (foreign or domestic) including subpoena, it may become necessary for us to disclose Personal Information.  We may also disclose Personal Information for purposes of public importance, such as enforcement of the law, public health and safety, or national security.

5. Protection of Personal Information CokePay uses multiple safeguards to protect your Personal Information against misappropriation, loss, theft, unauthorized access, alteration, and destruction. These include physical devices, technical know-how, policies and procedures, and administrative steps.

6. Integrity and Retention of Personal Information CC1, NCS and the CokePay Service Providers & Affiliates have a commitment to privacy which we communicate and reiterate to our staff and partners. We strictly enforce privacy and security. Should you wish to close your account and end your relationship with CokePay, you should request your petition in writing in the “Contact Us” section under the “Help” menu, or by email at , or by mail at PO Box 51985, Toa Baja, PR 00950, and we will “close” such account, but retain Personal Information to collect fees or redeem value, resolve disputes, or assist with any action required or permitted by law. You must include your email address, and User ID, linked to your account, in all your communications. Please note that any remaining balance is nonrefundable.

7. Access to Your Information We also commit to the accuracy of information, and you may review and edit your Personal Information, including partial or total edits of such information, by logging into your account settings and profile. To verify it is accurate & change it. Should this not be available to you, you may contact us through the contact information listed in Section 12 of this Privacy Policy for assistance.

8. Children We do not knowingly collect information on children under the age of 13, unless through a special program, a parent has set up an account on behalf of that child, and verified consent from the parent has been provided. In the case we learn that information has been collected on a child under the age of 13 without the appropriate parental consent, action will be taken to remove such information as quickly as possible. For more information, please review CokePay Terms of Sale and Account.

9. Location-Based Services The CokePay mobile application may collect, use and share location data, including precise location data and real-time geolocation data in combination with Transactional Data in order to provide information in real-time. This information is anonymized and aggregated and will not personally identify users.

10. Third Party Sites And Services The CokePay mobile application links to third party websites and locations, and encourage use of their Services. Our products and Services may contain offers or offer products and Services from third parties. Any information gathered by third parties is governed by those third parties’ privacy policies. You are encouraged to verify the Privacy Policy of every service you use.

11. International Users CokePay is not intended for international use at this time, therefore international participation is not expected or encouraged. As this is the case there are no reasonable means for CokePay to determine whether Personal Information is coming from overseas, and disclaims any liability should an unintended user somehow register Personal Information. In the case we learn that information has been collected on unintended users without the appropriate information “safe harbor” framework, action will be taken to remove such information as quickly as possible.

12. Who To Talk To About Your Privacy Questions If you have any questions comments or concerns regarding this Privacy Policy, please contact us in writing in the “Contact Us” section under the “Help” menu or send us an email at  or in writing at CokePay, PO Box 51985, Toa Baja, PR 00950.

13. Electronic delivery of communications. You agree and consent to receive electronically all communications, agreements, documents, notices, and disclosures (collectively, “Communications”) that we provide in connection with your CokePay account (“Account”) and your use of our Services. You agree that we may rely on your information as complete and accurate.

Communications include, but are not limited to: agreements and policies you agree to (e.g., the CokePay Terms of Sale and Account, User’s Terms of Service, and the CokePay Privacy Policy), including updates to these agreements or policies; information related to any Account, including transaction information or confirmations and history.

14. Withdrawing Consent. You may withdraw your consent to receive Communications electronically by emailing us at , or in writing at CokePay, PO Box 51985, Toa Baja, PR 00950. Please note that you must include the email address, and User ID, linked to your account.

15. Requesting paper copies of electronic Communications. If you would like a paper copy of any Communication previously sent to you, you may contact us and make a request for a paper copy, up to 3 months after the date of the Communication. Requests made after 3 months may not be able to be met. Paper copies of Communications will be sent by first-class US mail. In order for us to send you paper copies, you must have a current street address on file or provide it to us.

16. Maintaining Accurate Contact Information. For receiving electronic communications, you agree to keep the email address you give us to use to communicate with you up to date, complete and accurate. You agree to update your contact information when needed and acknowledge that if we do not have accurate contact information, we may not be able to communicate with you. For receiving any written, physical communications from the CokePay Service Department, you must provide your complete and accurate physical address for receipt of US mail.

We may update our Privacy Policy. When such an update is deemed material, we will post a notice describing the update.

17. How We Respond to Do Not Track Signals

Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our mobile application.

18. Transfer of your Personal Information

Your information, including Personal Information, is processed at our CokePay Service Porviders facilities and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to a jurisdiction unless there are adequate controls in place including the security of your Personal Information.