Last Revised: 28 September 2023
Our websites, products and services are designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives and not their individual capacities
A Note About Children. We do not intentionally gather personal information from visitors who are under the age of 13. If a child under 13 submits personal information to Cogniac and we learn that the personal information is the information of a child under 13, we will attempt to delete the information. If you believe that we might have any personal information from a child under 13, please contact us at: firstname.lastname@example.org.
Types of Data We May Collect About You
We collect and use different types of data from and about you including:
Information You Provide to Us.
Information Collected via Technology.
Other Information Collected
Cookies and Automatic Data Collection Technologies
Use of Your Personal information.
General use. In general, personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your personal information in the following ways:
Service delivery, which may include using your personal information to:
Service personalization, which may include using your personal information to:
Interest-based advertising, which may include using your personal information to:
Service analytics, which may include using your personal information to:
Compliance with law and co-operation with authorities, which may include using your personal information to:
Protection and enforcement of rights, which may include using your personal information to:
To manage our recruiting and process employment applications, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics
Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent.
Disclosure of Your Personal Information
We may share your personal information with:
Other Types of Third Party Disclosures
We may also disclose your personal information to third parties:
Accessing and Correcting Your Personal Information
You may also send us an email at email@example.com to request access to, correct, or delete personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement.
Jurisdiction Specific Rights
We are based in the United States. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.
By submitting your personal data or engaging with our Websites, you consent to this transfer, storing, or processing.
When we are acting as a processor, the controller will identify the legal basis for the transfer of personal data to Cogniac and you should view their Privacy Notice/Policy for further information.
In terms of the General Data Protection Regulation (GDPR), if you are a EU/EEA or UK data subject, you have rights to understand and request how we collect, use, and disclose Personal Data in our capacity as a data controller, to the extent permitted by applicable law.
EU-US Data Privacy Framework (EU-US DPF)
Personal data may be transferred from the European Union/UK/Switzerland to the United States (U.S.). The E.U-U.S. Data Privacy Framework (EU-U.S. DPF) has been determined as ‘adequate’ by the European Commission which means that personal data can be transferred to organizations in the U.S. who have signed up to the EU-U.S. DPF without the need for any further safeguards to be in place.
Cogniac complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
Transfers to third parties/controllers/processors
Cogniac has set out above where we may transfer personal data to third party controllers and processors. In those cases we ensure that there is a contract in place that sets out that personal data may only be processed for limited and specified purposes and that the recipient will provide the same level of protection as the DPF Principles and that they will notify Cogniac if it can no longer meet that obligation. Cogniac remains liable under the DPF Principles if the receiving organization (processor/agent) processes in a manner which is inconsistent with the DPF Principles unless that organization can prove that it is not responsible for the event giving rise to the damage.
We may need to disclose your personal data in response to lawful requests by public authorities including to meet national security or law enforcement requirements.
Independent Dispute Resolution
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Cogniac commits to resolve DPF Principles-related complaints about our collection and use of your personal data.
EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Cogniac at firstname.lastname@example.org.
You can always submit a complaint directly to your local data protection authority (i.e., EU/EEA Member State data protection authority; UK Information Commissioner’s Office (ICO) or Gibraltar Regulatory Authority (GRA); or the Swiss Federal Data Protection and Information Commissioner. Your data protection authority may refer your complaint directly to the U.S. Department of Commerce’s International Trade Administration (ITA) on your behalf. If referred to the ITA, the DPF team will then work with the organization to seek to resolve your concern.
If your complaint is not resolved after following the recourse mechanisms described above, you may have the ability to invoke binding arbitration. Additional information is available here for EU/EEA and UK (and Gibraltar) individuals and here for Swiss individuals.
We are also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) who have jurisdiction over Cogniac’s compliance with the EU-US DPF, the UK extension to the EU-US DPF and the Swiss-US Data Privacy Framework (Swiss US DPF). You may also be able to invoke binding arbitration in certain circumstances.
California Privacy Rights
Cogniac is not subject to the California Consumer Privacy Act of 2018 as amended (“CCPA”) but this will be kept under review in case the position changes.
The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers employing security protections.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.
Attn: Data Protection Officer
Address: 160 W. Santa Clara St, Suite 1575, San Jose CA 95113