CogNeed Privacy Policy

Terms in capital letters used but not defined in these Acceptable Use Policies have the meanings ascribed to them in our Terms of Service. "You" and "your" refer to the "Client" or "Users," and "We," "us," "our" refer to "CogNeed."

"User Personal Information" refers to all information about one of our users that could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as an email address, a name, an IP address, and a photograph are examples of "user personal information." A pseudonym, a username, or, in the case of CogNeed, a "display name," may contain user personal information, as applicable.

User personal information does not include aggregated and non-personally identifiable information that does not allow for the identification of a user or cannot be reasonably linked or connected with them. We may use such aggregated and non-personally identifiable information for research purposes and to operate, analyze, improve, and optimize our website and Services.

When you create an Account on CogNeed, you agree to this Privacy Policy. For each User Account, active consent to the analysis and recording of data as defined below will be offered at the first login and necessary for the use of the Services. These processing activities aim to assist users, monitor, and improve their performance.

I. What information CogNeed collects

Information users provide directly to CogNeed

Registration information

We require some basic information at the time of account creation. When you create your User Account, we ask for a valid email address.

Payment Information

If you subscribe to a paid CogNeed account, we ask for your full name, address, and your credit card information or SEPA Direct Debit (SDD) information. Please note that CogNeed does not process nor store your credit card or SDD information; this is done directly within Stripe, our third-party electronic payment system.

Profile Information

You may choose to give us more profile information about your account, such as your full name in your "display name" or information regarding your usage preferences. This information may include 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, our third-party electronic payment system, Stripe, automatically collects certain information about your transactions on the Service, such as the date, time, and amount charged.

Usage information

When you access our Service or website, we automatically collect the same basic information that most services collect, subject to your consent, where applicable. This includes information about how you use the Service or website, such as session information, content cards and pages you visit, voice commands spoken in session, posted comments, compliance elements of your sessions, as well as the date, time, and information of each request sent to our servers. This information may include user personal information.

Audio information

When you use our Service, we process audio information from your sessions. These audio informations are transcribed and analyzed in real-time but are not recorded.

Transcription Information

When you use our Service and CogNeed AI™ detects that you have spoken a voice command of your project, we record the transcription of the sentence including that voice command for reporting purposes for your organization. This information may include user personal information.

If your organization has opted to activate CogNeed's transcription functionality, transcriptions of all audio are recorded for analysis and reporting purposes for your organization.

Information we collect from third parties

CogNeed may collect personal information about users from third parties. For example, this can occur 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 use our Service integrated with your telephony, we may also collect additional usage information such as:

Under no circumstances do we record the voice of your clients and prospects when CogNeed is integrated with 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, trade union membership, or processing genetic data, biometric data for the purpose of uniquely identifying a natural person, health data, or data concerning a person's sex life or sexual orientation.

If you choose to store sensitive personal information on our servers, you are responsible for complying with all regulatory controls regarding these data.

If you are a child under the age of 18, you cannot have an account on CogNeed. CogNeed does not knowingly collect information from children under 18 nor does it target its Service to children under 18. If we learn or have reason to suspect that you are a user who is under the age of 18, we will have to close your account. Please see our Terms of Service for more information on account termination. Different countries may have different minimum age limits, and if you have not reached the minimum age to consent to data collection in your country, you may not be able to have an account on CogNeed.

We do not intentionally collect user personal information that is posted in your other free-form content entries, 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 for 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 inform you of 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 in exchange for monetary or other consideration. We do not share your user personal information with third-party service providers not mentioned. We may share your user personal information with third parties in one of the following circumstances:

With your consent

We share your user personal information, if you consent to it, after informing you which information will be shared, with whom, and why. Moreover, 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 owner(s) and project manager(s) the ability to see 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 organization's Account owner(s) and project manager(s), insofar as this information is provided solely to investigate or respond to a security incident affecting or compromising the security of that particular organization.

For legal disclosure

CogNeed strives to be transparent in complying with legal procedures and obligations. Unless prohibited by law or a court order, or in rare and urgent circumstances, we make reasonable efforts to notify users of any legally constrained or required disclosure of their information. CogNeed may disclose user personal information or other information we collect about you to law enforcement if necessary 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 such a change of ownership occurs, we will ensure that it is subject to terms that preserve the confidentiality of user personal information, and we will inform you on our website or via email before any transfer of your user personal information. The organization receiving user personal information will need to honor all commitments made in our privacy policy or Terms of Service.

Aggregate, non-personally identifying information

We share certain aggregated and non-personally identifiable information with others about how our users, collectively, use CogNeed, or how our users respond to our offerings, such as during 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 or become a member of an Organization, its Account owners and project managers may receive your user personal information. If you accept an invitation to an Organization, the Account owners and project managers of that Organization will be able to see your full email address.

Please note that CogNeed may share your username, usage information, and device information with the Account owners and project managers of the organization of which you are a member.

Please contact the Account owners and project managers for more information on how they might process your user personal information within their organization and on ways for you to access, update, modify, or delete the user personal information stored in the Account.

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

If you are already a user of CogNeed, you can access, update, modify, or delete the basic information of your user profile by editing your user profile or contacting CogNeed Support. You can control the information we collect about you by limiting the information in your profile, keeping your information up to date, or contacting CogNeed Support.

If CogNeed processes information about you, such as information CogNeed receives from third parties, and you do not have an account, you may, subject to applicable law, access, update, modify, 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 the information we have about you.

Data retention and deletion of data

Generally, CogNeed retains information provided by the user as long as their account is active or as long as needed to provide Services. Conversely, personal information that CogNeed automatically collects from your use of the Service is retained for a maximum of 2 years, after which it is automatically deleted.

If you wish to cancel your account or delete your user personal information, you can 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 unless required by law, we will delete your complete profile within 90 days following your request.

You can contact CogNeed Support to request the erasure of data we process based on 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 the hard drives of computers or mobile devices of visitors.

We use cookies solely to provide and secure our Service. For example, we use them to authenticate you, keep you logged in, and tailor our Service to your language preferences. We use our own cookies for analytics purposes, but we 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's 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 reasonably necessary measures to protect user personal information from unauthorized access, alteration, or destruction; maintain the accuracy of data; and help ensure the appropriate use of user personal information.

CogNeed implements a written data security program. Our program:

In the event of a data breach affecting your user personal information, we will act quickly to mitigate the impact and inform affected users without undue delay.

Data transmission within the CogNeed information system is encrypted using SSH, HTTPS (TLS), and "encryption at rest" protocols. Our data is stored and duplicated in France, in AWS data centers in the Paris region with a high level of physical and network security, and is encrypted.

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

IX. CogNeed's global privacy practices

CogNeed is the data controller responsible for processing your personal information in connection with the Service, except where you and CogNeed have entered into a separate agreement covering 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 we collect in France in accordance with this Privacy Policy. However, we recognize that we have users from different countries and regions with varying privacy expectations, and we strive to meet those needs even when France and the European Union do not share the same privacy framework as other countries.

We provide the same high level of privacy protection, as described in this privacy policy, to all our users worldwide, regardless of their country of origin or location, and we pride ourselves on the levels of notice, choice, accountability, security, data integrity, access, and recourse we offer.

We work hard to comply with applicable data privacy laws wherever we operate, in collaboration with our Data Protection Officer within a multidisciplinary team overseeing our privacy compliance efforts.

In particular:

Cross-border data transfers

We are committed to complying 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, p. 1-88).

As a result, CogNeed stores and processes data only in France, in AWS data centers in the Paris region.

X. How we communicate with you

We use your email address to communicate with you, if you have consented to it, and only for the reasons for which you have consented. For example, if you contact our support team with a request, we will respond to you via email.

CogNeed may occasionally send notification emails about changes to a Service you use, new features, requests for feedback, significant policy changes, or to offer customer support. We also send marketing emails based on your preferences and in accordance with applicable laws and regulations. An "unsubscribe" link is included at the bottom of each of the marketing emails we send to 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 tiny clear image that tells us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our emails more effective for you and to ensure we are not sending you unwanted emails.

XI. Resolving complaints

If you have any concerns about how CogNeed processes your user personal information, please let us know immediately. We want to help. You can contact us directly at CogNeed Support with the subject line "Privacy Issues." We will respond promptly - within 30 days at the latest.

Dispute resolution process

In the unlikely event that a dispute arises between you and CogNeed regarding our processing of your user personal information, we will do our best to resolve it. Additionally, if you reside in an EU Member State, you have the right to lodge a complaint with your local supervisory authority.

XII. Changes to our Privacy Policy

While most changes are likely to be minor, CogNeed may modify this Privacy Policy from time to time. We will notify Users of significant changes to this Privacy Policy via our Website at least 30 days before the change takes effect by posting a notice on our homepage or by sending an email to the primary email address listed in your CogNeed account.

XIII. Contacting CogNeed

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