COGNICOR Privacy Notice
EFFECTIVE DATE: January 22, 2018
NOTE: This policy covers most of our products and web services. If any product or service has any
additional clauses, it will be specified in their respective agreements.
We at COGNICOR respect your privacy and are committed to protecting the personal information you share
with us. In this Privacy Notice (“Notice”), we describe how we collect, use, and disclose information that we
obtain through our website www.cognicor.com or cira.cognicor.com (the “Site”) and how we use and
disclose that information. This Notice applies only to www.cognicor.com or cira.cognicor.com and not to the
websites of any affiliated businesses.
By visiting the Site, you agree that your personal information will be handled as described in this Notice.
reference into this Notice.
With respect to the collection of your information, if you do not want your personal information collected,
please do not submit it to us. If you have already submitted information and would like to review, correct or
remove it from our records, please contact us at firstname.lastname@example.org
By visiting and using the Site, you are deemed to have agreed to the provisions of this Privacy Notice,
unless you are in the EEA or Switzerland in which case you are acknowledging that you have been provided
this Privacy Notice.
1. What Information Do We Collect About You and Why?
We may collect information about you directly from you and from third parties, as well as automatically
through your use of our Site.
Information We Collect Directly From You. If you subscribe to our newsletters or complete the web form on
the Contact Us page, we ask you to fill out a brief form that requests information such as your name,
company, title, e-mail address, and telephone, as well as your areas of interest and of course the content of
your message to us. Similarly, if you provide comments on any blog or community page we may host, you
will need to log in – although you may do that via your social network account such as Facebook, Twitter, or
Of course, if you have given us permission to send you surveys, we collect information from you when you
respond to a survey.
Our Site may include social media features, such as the Facebook, YouTube, and Twitter buttons. These
features may also collect your IP address, which page you are visiting on our Site, and may set a cookie
(see below) to enable the feature to function properly. These features may also give you the option to post
information about your activities on our Site to your profile page to share with others within your network.
Your interactions with these features are governed by the privacy notice of the company providing them.
Information We Collect Automatically. We may automatically collect the following information about your use
of our Site through cookies, web beacons, and other technologies: your domain name; your browser type
and operating system; web pages you view; links you click; your IP address; the length of time you visit our
Site; and the referring URL, or the webpage that led you to our Site. We may combine this information with
other information that we have collected about you, including, where applicable, your user name, name, and
other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for
2.How We Use Your Information?
We use your information, including your personal information, for the following purposes:
To communicate with you about your use of our Services, to respond to your inquiries or request for
information, and for other marketing and client service purposes.
To tailor the content and information that we may send, to offer location customization, and
personalized help and instructions, and to otherwise personalize your experiences while using the Site.
For marketing purposes. For example, we may use your information, such as your email address, to
send you news and newsletters, or to otherwise contact you about services or information we think may
To better understand how visitors access and use our Site, both on an aggregated and
individualized basis, in order to improve our Site and respond to member desires and preferences, and for
other research and analytical purposes.
If we would like to use your personal information for any purposes other than those described, we will obtain
your prior consent.
3.How We Share Your Information?
We may share your information, including personal information, as follows:
Other Site Visitors. If you post a comment on the blog pages or any other public area of the Site,
your comment and identity will be available to, and searchable by, all users of the Site. This does not apply
to any information you provide in a Contact Us inquiry.
Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries;
however, if we do so, their use and disclosure of your personally identifiable information will be subject to
Service Providers. We may disclose the information we collect from you to third party vendors,
service providers, contractors or agents who perform functions on our behalf.
Business Transfers. If we are acquired by or merged with another organization, if substantially all of
our assets are transferred to another organization, or as part of a bankruptcy proceeding, we may transfer
the information we have collected from you to the other organization.
In Response to Legal Process. We also may disclose the information we collect from you in order to
comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court
order or a subpoena.
To Protect Us and Others. We also may disclose the information we collect from you where we
believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud,
Notice, or as evidence in litigation in which COGNICOR is involved.
Aggregate and De-Identified Information. We may share demographic information in aggregate
terms for reporting purposes, research, or similar purposes.
We only share personal information with our service providers for the purpose of performing services on our
behalf. We require that these parties only process the personal information for limited and specified
purposes consistent with this Notice.
If we would like to share your personal information for any purposes other than those described, we will
obtain your prior consent.
4.How Long We Keep Your Personal Information?
We typically only retain your information for the time necessary to realize our legitimate business purposes
and to comply with the law.
We will typically retain personal information for the longer of the period a) required by law or b) a time-bound
determination of business need.
5. User Generated Content
We invite you to post content on our Site and provide responses to our blog, including your comments,
pictures, and any other information that you would like to be available on our Site. If you post content to our
Site, all of the information that you post will be available to all visitors to our Site. If you post your own
content on our Site, your posting may become public and we cannot prevent such information from being
used in a manner that may violate this Notice, the law, or your personal privacy.
Our Site may contain links to third-party websites and social media. Any access to and use of such linked
websites is not governed by this Notice, but instead is governed by the privacy policies of those third party
websites. We are not responsible for the information practices of such third party websites.
7.Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss,
misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our
efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by,
among other things, signing off after using a shared computer, choosing a robust password that nobody
else knows or can easily guess, and keeping your log-in and password private. We are not responsible for
any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password
8.Access To My Personal Information
We make good faith efforts to provide you with access to your personal information and either to correct this
data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by
law or for legitimate business purposes.
You may modify personal information that you have submitted by contacting us and requesting a copy of
whatever identifiable information you have provided to us. Please note that copies of information that you
have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a
period of time.
9.What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic solicitations or informational emails to you. You may opt-out of such communications
by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business
days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other
information we think may interest you, we may still send you e-mails about your account or any services you
have requested or received from us.
Our Site is not intended for children under the age of 16.
We do not knowingly collect information from children. In the event that we learn that we have collected
personal on the Site from a child under age 16, we will delete that information promptly. If you believe that
we might have any information from a child under 16, please contact us at email@example.com.
11.Visiting our Site from outside the United States
If you are visiting our Site from outside the United States, please be aware that your information will typically
be transferred to, stored, and processed in the United States where our servers are located and our central
database is operated. The data protection and other laws of the United States and other countries might not
be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to
ensure that your personal information is protected. By using our services, you understand that your
information may be transferred to our facilities and those third parties with whom we share it as described in
this Privacy Notice.
12.Visiting our Site from the European Economic Area (EEA)
The Legal Basis for Using European Personal Information
When we collect information about you through our Site and you have not applied to participate in our
Programs as a startup or an expert, the legal basis on which we process your personal information is
fulfillment of an agreement between us, namely, to provide you with the internship/employment
consideration or the COGNICOR Newsletters and other information marketing in response to your request.
To the extent that we transfer personal information from the EEA to a jurisdiction outside the EEA that has
not been adduced by the European Commission as providing adequate data protections (such as the US),
we will ensure that such personal information is safeguarded through appropriate contractual terms.
Rights for EEA Residents
In addition, if you are a resident of the EEA, you have the right to:
Find out if we use your personal information, to access your personal information, and receive
copies of your personal information.
Withdraw any express consent that you have provided to the processing of your personal
information at any time without penalty.
Access your personal information and have it corrected or amended if it is inaccurate or incomplete.
Obtain a transferable copy of some of your personal information which can be transferred to another
provider when the personal information was processed based on your consent.
If you believe your personal information is inaccurate, no longer necessary for our business
purposes, or if you object to our processing of your personal information, you also have the right to request
that we restrict the processing of your data pending our investigation and/or verification of your claim.
Request your personal information be deleted or restricted under certain circumstances. For
example, if COGNICOR is using your personal information on the basis of your consent and has no other
legal basis to use such, you may request your personal information be deleted when you withdraw your
If you wish to exercise any of these rights, or raise a complaint on how we have handled your personal
information, please contact us at the Contact Us details below.
If you are not satisfied with our response, or believe we are processing your personal information in violation
of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data
Protection Authority) in your EEA country. For our operations within the EEA, our Lead Supervisory
Authority is the UK Information Commissioner’s Office (www.ico.org.uk)
If you have questions about the privacy aspects of our Site or would like to make a complaint about this
Notice, please e-mail us at firstname.lastname@example.org; or
write us at CogniCor Technologies Inc., 8 The Green, Suite A, Dover , Kent county, Delaware 19901
Changes to this Notice:
This Notice is current as of the Effective Date set forth above. We may change this Notice from time to time,
so please be sure to check back periodically. We will post any changes to this Notice on our Site, at
https://cognicor.com. If we make any changes to this Notice that materially affect our practices with regard
to the personal information we have previously collected from you, we will endeavor to provide you with
notice in advance of such change by highlighting the change on our Site.