Effective Date: June 19, 2026
Last Updated: June 19, 2026
Cope Global LLC, a Delaware limited liability company ("Cope," "we," "us," or "our"), provides a marketplace through which buyers acquire digital and physical products and services offered by independent sellers, and through which certain users promote those offerings for compensation. This Privacy Policy (this "Policy") describes the personal information we collect, how and why we use and disclose it, and the choices and rights available to you.
This Policy forms part of, and is incorporated by reference into, the Cope Global LLC Terms of Service (the "Master Terms"), and should be read together with the Buyer Terms, the Creator Terms, the Affiliate and Revenue Share Terms, and the other Ancillary Policies. Capitalized terms used but not defined in this Policy have the meanings given to them in the Master Terms, including "Platform," "User," "Product," "User Content," "Buyer," "Creator," and "Affiliate." Where this Policy refers to Creators and Affiliates together, it does so for convenience only, as the platform's "Platform Businesses"; that shorthand does not change the distinct roles, rights, and obligations that the Creator Terms and the Affiliate and Revenue Share Terms assign to Creators and to Affiliates respectively.
Because the Products are provided solely by the Creators that offer them, and because Cope acts as a marketplace and as the Creator's limited agent for collecting and settling payment rather than as the seller, this Policy describes Cope's information practices in that role. Each Platform Business is independently responsible, as a separate controller, for its own handling of personal information, as described in this Policy.
This Policy applies to the personal information Cope processes about the people who use or interact with the Platform, including:
This Policy describes Cope's own practices. It does not govern how a Platform Business handles personal information that it controls; each Platform Business acts as an independent controller and should maintain its own privacy notice. Nor does it govern third-party websites or services that we do not operate (see Section 11).
The information we collect depends on how you interact with the Platform. We collect it directly from you, automatically through your use of the Platform, and from third parties.
When you use the Platform, we and our service providers automatically collect certain information using cookies, pixels, software development kits, and similar technologies (described in Section 7), which may include [your IP address and other online identifiers, general location, device and browser type, operating system, language, access times, the pages and content you view, the links you click, referring and exit pages, and other usage and diagnostic data]. We also use tracking technologies to attribute sales to the Affiliates who generate them.
The purposes for which we use personal information are described below. Where the GDPR or UK GDPR applies, we have indicated the legal bases on which we rely in Section 3.1; these purposes may also be relevant under other privacy and data-protection laws that apply to a given individual, and the descriptions below are not limited to any single legal regime.
We use personal information to:
Because Cope offers the Platform to individuals in the EU/EEA, including in Germany and Austria, with German-language presentation and euro pricing, Cope is within the territorial scope of the GDPR under Article 3(2). Where the GDPR or UK GDPR applies, we rely on the following legal bases:
| Processing activity | Legal basis (GDPR Article 6) | Notes |
|---|---|---|
| Creating and maintaining your account; providing the Platform; facilitating and settling Transactions; collecting payment as the Creator's limited agent; providing order-related support and subscription billing | Art. 6(1)(b): performance of a contract (the Platform Agreements) | Based on performance of the Platform Agreements, not on performance of any sale, because Cope is not the seller. |
| Meeting tax and value-added-tax obligations (including statutory collection where Cope is treated as the supplier for electronically supplied services, and applicable U.S. marketplace-facilitator obligations); identity verification, anti-money-laundering, and sanctions screening; regulatory reporting; and retaining required records | Art. 6(1)(c): compliance with a legal obligation | |
| Preventing fraud and abuse; securing the Platform; analytics and service improvement; affiliate attribution; managing our customer relationships; and corporate transactions | Art. 6(1)(f): legitimate interests | Each reliance requires a documented legitimate-interests assessment. |
| Sending marketing communications; setting non-essential cookies and similar technologies; storing saved payment credentials and saved profiles for one-click checkout | Art. 6(1)(a): consent | Consent must be specific, informed, freely given, and withdrawable; we retain records of consent. |
| Taking steps necessary to protect the vital interests of an individual | Art. 6(1)(d): vital interests | Relied on only rarely. |
We share personal information as needed for the purposes described above, as you direct or authorize, and with the categories of recipients below.
The Platform allows Users to submit, post, and share User Content, and includes community and social features (which may include, for example, forums, comments, messaging, live video, challenges, reviews, and ratings). User Content, and any personal information you choose to include in it, may be visible to other Users and, depending on the feature and your settings, to the public. You should not include sensitive personal information in User Content. Creators that operate community spaces may set their own rules for those spaces and may have access to information about the people who participate in them.
The Platform also offers AI-assisted tools, which may include automated content generation, catalog and listing assistance, transcription, sales automation, recommendations, and fraud-detection support. To provide these tools, we and our service providers may process behavioral, usage, transaction, and content information. A Creator controls whether AI-generated content the Creator produces is published, and is responsible for that content. We do not use these tools to make decisions that produce legal or similarly significant effects concerning you based solely on automated processing, except as permitted by applicable law; where we do, you have the rights described in Section 14.1, including, where applicable, the right to obtain human review of, to express your point of view on, and to contest the decision. Where required, we will provide meaningful information about the logic involved and the significance and consequences of such processing.
We may create and use de-identified and aggregated information that does not identify you, for purposes including analytics, research, reporting, security, product development, and the development, training, and improvement of our AI and machine-learning models and features. Where we hold information in de-identified form, we will maintain and use it in that form and will not attempt to re-identify it, except as permitted by applicable law.
We and our service providers use cookies, pixels, software development kits, and similar technologies to operate and secure the Platform, remember your preferences, measure and improve our communications and marketing, prevent fraud, and understand how the Platform is used.
You can manage many of these technologies through our cookie banner and settings and through your browser and device controls.
The Platform is intended for adults; you must be at least 18 to use it, consistent with the Master Terms and the Buyer Terms. We do not knowingly collect personal information from children under [13/16]. If you believe a child has provided us personal information, please contact us and we will take appropriate steps to delete it.
We maintain administrative, technical, and organizational measures designed to protect personal information against unauthorized access, use, alteration, and disclosure, which may include [encryption of data in transit and at rest where appropriate, secure payment processing, access controls, personnel training, and monitoring]. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a personal-information breach occurs, we will notify affected individuals and authorities as and where required by applicable law.
The Platform may link to, or integrate with, websites and services that we do not own or control, including Creators' own sites, payment and financing providers, and social and connected-account services. This Policy does not apply to those third parties. When you access or use a third-party website or service, you do so subject to that third party's own terms and privacy policy, and we encourage you to review them. We are not responsible for the content or the privacy or security practices of any third party, and the inclusion of a link or integration does not imply our endorsement.
Cope is based in the United States, and the personal information we process about individuals in the EU/EEA and the United Kingdom may be transferred to, stored in, or accessed from the United States and other countries, which may not provide the same level of data protection as your home country. Where we transfer such personal information to a country that has not been recognized as providing an adequate level of protection, we put in place appropriate safeguards. [Transfer mechanisms: Standard Contractual Clauses, and/or certification under the EU-US Data Privacy Framework].
We keep personal information for as long as necessary to fulfill the purposes described in this Policy, and afterward as necessary to comply with our legal obligations (including tax, accounting, anti-money-laundering, and other regulatory obligations), to resolve disputes, to maintain business records, and to enforce our agreements. Where required to meet financial and regulatory obligations, certain records may be kept for up to [7–10] years. When personal information is no longer needed, we delete or de-identify it.
Residents of certain regions have additional rights, described below. We honor these rights to the extent the relevant law applies to Cope.
Cope processes personal information about individuals in the EU/EEA and the United Kingdom as a controller within the meaning of the GDPR and the UK GDPR. The legal bases on which we rely for that processing are set out in Section 3.1, and the rights described below apply to it. Subject to the conditions and exceptions in those laws, you have the right to:
To exercise these rights, contact us using the details in Section 15. We may need to verify your identity, and some rights are subject to limitations under applicable law. We will respond within the time required by law.
EU Representative. Because Cope is not established in the EU, Cope has appointed a representative in the EU under Article 27 of the GDPR: [Yanco Williams / EU member-state address]. You may contact our EU representative on data-protection matters using those details.
United Kingdom. [The UK GDPR may apply to the extent Cope offers the Platform to individuals in the United Kingdom.]
Residents of certain U.S. states with comprehensive privacy laws [including, where applicable, California, Delaware, Florida, Virginia, Colorado, Connecticut, Utah, and others] may have the rights below, subject to the conditions and exceptions in the applicable law and only to the extent that law applies to Cope:
We do not "sell" personal information for money. To the extent applicable U.S. state privacy law applies to Cope, some of our advertising and analytics activity (including certain uses of cookies and similar technologies) may be considered a "sale" or "sharing" of personal information; we do not "sell" or "share" sensitive personal information, and we do not knowingly "sell" or "share" the personal information of individuals under 16. To the extent we are subject to these laws, you may exercise an opt-out through [a "Your Privacy Choices" / "Do Not Sell or Share My Personal Information" link — to be implemented] and your cookie settings, and where the California Consumer Privacy Act applies to us, we will treat a recognized opt-out preference signal (such as Global Privacy Control) as a valid opt-out of "sale" and "sharing."
To exercise any of these rights, contact us as described in Section 15. We will verify your request by matching the information you provide against our records, and an authorized agent may submit a request with proof of authorization.
If you have questions about this Policy or wish to exercise your rights, you can reach us:
For privacy and data-protection inquiries, please identify your request so we can route it appropriately.
This Policy is effective as of the date stated above. We may update it from time to time to reflect changes in our practices or in applicable law. If we make changes that materially affect how we process personal information we have already collected from you, we will provide notice in a way reasonably designed to bring the changes to your attention before they take effect, which may include posting a prominent notice on the Platform, sending an email, or presenting the updated Policy when you next sign in, and, where required by applicable law, we will provide notice and obtain any consent before further processing. We encourage you to review this Policy periodically. Your continued use of the Platform after the updated Policy takes effect constitutes acceptance of it, except where applicable law requires otherwise.
