CogNeed Privacy Policy

I. What information CogNeed collects

"User Personal Information" is any information about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as a username and password, an email address, a real name, an Internet protocol (IP) address, and a photograph are examples of “User Personal Information.”

User Personal Information does not include aggregated, non-personally identifying information that does not identify a User or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, non-personally identifying information for research purposes and to operate, analyze, improve, and optimize our Website and Service.

Information users provide directly to CogNeed

Registration information

We require some basic information at the time of account creation. When you create your own username (display name) and password, we ask you for a valid email address.

Payment Information

If you sign on to a paid Account with us, we collect your full name, address, and credit card information or SEPA direct debit (SDD) information. Please note, CogNeed does not process or store your credit card information or SDD information, but our third-party payment processor Stripe does.

Profile Information

You may choose to give us more information for your Account profile, such as your full name, an avatar which may include a photograph, your biography, or your location. This information may include User Personal Information. Please note that your profile information may be visible to other Users of our Service.

Information CogNeed automatically collects from your use of the Service

Transactional information

If you have a paid Account with us, we automatically collect certain information about your transactions on the Service, such as the date, time, and amount charged.

Usage information

When you're accessing our Service or Website, we automatically collect the same basic information that most services collect, subject, where necessary, to your consent. This includes information about how you use the Service, such as the pages and content cards you view, the ID of keywords used during a session, the referring site, your IP address and session information, and the date and time of each request. This is information we collect from every visitor to the Website, whether they have an Account or not. This information may include User Personal information.

Cookies

As further described below, we automatically collect information from cookies (such as cookie ID and settings) to keep you logged in, to remember your preferences, to identify you and your device and to analyze your use of our service.

Device information

We may collect certain information about your device, such as its IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer. This information may include User Personal information.

Audio information

When you're using our Service, we collect audio information when CogNeed AI™ detects that you pronounced a keyword associated to a content card. When this happens, we only collect up to 3 seconds of audio, for continuous improvement of CogNeed AI™ and reporting purposes for your Organisation. This information may include User Personal information.

Information we collect from third parties

CogNeed may collect User Personal Information from third parties. For example, this may happen if you receive information about CogNeed from one of our vendors, partners, or affiliates. CogNeed does not purchase User Personal Information from third-party data brokers.

Information CogNeed collects when integrated to your telephony

Usage information

When you're using our Service with a telephony integration, we also collect Usage information when CogNeed AI™ detects that your interlocutor pronounced a keyword associated to a content card.

When this happens, we only collect the transcript of what your interlocutor said, for reporting purposes for your Organisation. This information does not include User Personal information. In other words, we do not collect the voice of your clients and prospects when CogNeed is integrated to your telephony.

II. What information CogNeed does not collect

We do not intentionally collect “Sensitive Personal Information”, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

If you choose to store any Sensitive Personal Information on our servers, you are responsible for complying with any regulatory controls regarding that data.

If you are a child under the age of 16, you may not have an Account on CogNeed. CogNeed does not knowingly collect information from or direct any of our content specifically to children under 16. If we learn or have reason to suspect that you are a User who is under the age of 16, we will have to close your Account. Please see our Terms of Service for information about Account termination. Different countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not have an Account on CogNeed.

We do not intentionally collect User Personal Information that is stored in your other free-form content inputs, such as content cards.

III. How CogNeed uses your information

We may use your information for the following purposes:

We limit our use of your User Personal Information to the purposes listed in this Privacy Policy. If we need to use your User Personal Information for other purposes, we will ask your permission first.

Our legal bases for processing information

To the extent that our processing of your User Personal Information is subject to certain international laws (including, but not limited to, the European Union's General Data Protection Regulation (GDPR)), CogNeed is required to notify you about the legal basis on which we process User Personal Information. CogNeed processes User Personal Information on the following legal bases:

Contract performance

Consent

Legitimate interests

IV. How we share the information we collect

We do not sell your User Personal Information for monetary or other consideration. We do not share your User Personal Information to any third party service provider. We may share your User Personal Information with third parties under one of the following circumstances:

With your consent

We share your User Personal Information, if you consent, after letting you know what information will be shared, with whom, and why. Additionally, you may direct us through your actions on CogNeed to share your User Personal Information. For example, if you join a Project within an Organization, you indicate your willingness to provide its Account/Project owner(s) with the ability to view your email address.

For security purposes

If you are a member of an Organization, CogNeed may share your Display Name, Usage Information, and Device Information with the Account/Project owner(s) of the Organization, to the extent that such information is provided only to investigate or respond to a security incident that affects or compromises the security of that particular Organization.

For legal disclosure

CogNeed strives for transparency in complying with legal process and legal obligations. Unless prevented from doing so by law or court order, or in rare, exigent circumstances, we make a reasonable effort to notify users of any legally compelled or required disclosure of their information. CogNeed may disclose User Personal Information or other information we collect about you to law enforcement if required in response to a valid subpoena, court order, search warrant, a similar government order, or when we believe in good faith that disclosure is necessary to comply with our legal obligations, to protect our property or rights, or those of third parties or the public at large.

Change in control or sale

We may share User Personal Information if we are involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our Website or by email before any transfer of your User Personal Information. The Organization receiving any User Personal Information will have to honor any promises we made in our Privacy Policy or Terms of Service.

Aggregate, non-personally identifying information

We share certain aggregated, non-personally identifying information with others about how our users, collectively, use CogNeed, or how our users respond to our other offerings, such as our conferences or events.

V. Other important information

Organisations

You may indicate, through your actions on CogNeed, that you are willing to share your User Personal Information. If you collaborate on or become a member of an Organization, then its Account/Project owner(s) may receive your User Personal Information. If you accept an invitation to an Organization, then the Account/Project owner(s) of that Organisation will be able to see your full email address.

Please note, CogNeed may share your username, Usage Information, and Device Information with the Account/Project owner(s) of the Organization you are a member of, to the extent that your User Personal Information is provided only to investigate or respond to a security incident that affects or compromises the security of that particular Organization.

Please contact the Account/Project owner(s) for more information about how they might process your User Personal Information in their Organization and the ways for you to access, update, alter, or delete the User Personal Information stored in the Account.

VI. How you can access and control the information we collect

If you're already a CogNeed user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting CogNeed Support. You can control the information we collect about you by limiting what information is in your profile, by keeping your information current, or by contacting CogNeed Support.

If CogNeed processes information about you, such as information CogNeed receives from third parties, and you do not have an account, then you may, subject to applicable law, access, update, alter, delete, or object to the processing of your personal information by contacting CogNeed Support.

Data portability

As a CogNeed User, you can always take your data with you. You can contact CogNeed Support to download information we have about you.

Data retention and deletion of data

Generally, CogNeed retains User Personal Information for as long as your account is active or as needed to provide you services, within a maximum of 6 months.

If you would like to cancel your account or delete your User Personal Information, you may do so in your user profile or by contacting CogNeed Support. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile within 90 days of your request.

You may contact CogNeed Support to request the erasure of the data we process on the basis of consent within 90 days.

VII. Our use of cookies and tracking

Cookies

CogNeed only uses strictly necessary cookies. Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors.

We use cookies solely to provide, secure, and improve our service. For example, we use them to keep you logged in, remember your preferences, identify your device for security purposes, analyse your use of our service, compile statistical reports, and provide information for future development of CogNeed. We use our own cookies for analytics purposes, but do not use any third-party analytics service providers.

By using our service, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept these cookies, you will not be able to log in or use our service.

VIII. How CogNeed secures your information

CogNeed takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information.

CogNeed enforces a written security information program. Our program:

In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected Users without undue delay.

Transmission of data in CogNeed informational system is encrypted using SSH, HTTPS (TLS), and encryption at rest. Our data is stored in France, in AWS Paris data centers with high level of physical and network security, and is encrypted.

No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

IX. CogNeed's global privacy practices

CogNeed is the controller responsible for the processing of your personal information in connection with the Service, except when you and CogNeed have entered into a separate agreement that covers data privacy (such as a Data Processing Agreement).

Our address is : CogNeed, 8 place Jeanne d’Arc, 78120 Rambouillet.

We store and process the information that we collect in France in accordance with this Privacy Policy. However, we understand that we have Users from different countries and regions with different privacy expectations, and we try to meet those needs even when France and the European Union does not have the same privacy framework as other countries.

We provide the same high standard of privacy protection—as described in this Privacy Policy—to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business, working with our Data Protection Officer as part of a cross-functional team that oversees our privacy compliance efforts.

In particular:

Cross-border data transfers

We are commited to comply with the General data protection regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, pp. 1–88).

Therefore, CogNeed only stores and processes User Personal Information inside of France, in AWS Paris data centers. We do not operate cross-border data transfers, excepted to store and process it in France when you use our Service elsewhere.

X. How we communicate with you

We use your email address to communicate with you, if you've said that's okay, and only for the reasons you’ve said that’s okay. For example, if you contact our Support team with a request, we respond to you via email.

CogNeed may occasionally send notification emails about changes in a Service you’re using, new features, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There's an “unsubscribe” link located at the bottom of each of the marketing emails we send you. Please note that you cannot opt out of receiving important communications from us, such as emails from our Support team or system emails.

Our emails may contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email.

XI. Resolving complaints

If you have concerns about the way CogNeed is handling your User Personal Information, please let us know immediately. We want to help. You may contact us directly at CogNeed Support with the subject line "Privacy Concerns." We will respond promptly — within 45 days at the latest.

Dispute resolution process

In the unlikely event that a dispute arises between you and CogNeed regarding our handling of your User Personal Information, we will do our best to resolve it. Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority.

XII. Changes to our Privacy Policy

Although most changes are likely to be minor, CogNeed may change our Privacy Policy from time to time. We will provide notification to Users of material changes to this Privacy Policy through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address specified in your CogNeed account.

XIII. Contacting CogNeed

Questions regarding CogNeed's Privacy Policy or information practices should be directed to CogNeed Support.