Last Modified: August 31, 2015
PRIVACY CERTIFICATION: U.S.-EU SAFE HARBOR FRAMEWORK & US-SWISS SAFE HARBOR FRAMEWORK
INFORMATION WE COLLECT
When you use our Services, you may provide Cognitive Advisors with two (2) main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse and use our Services. We collect information from you when you (a) use and/or access our Services, (b) register an account and/or subscribe to Cognitive Advisors, (c) open and/or respond to our emails, (d) contact Cognitive Advisors, (e) visit any page online that displays our content, (f) purchase products and/or services through our Services, and/or (g) provide information to any of our third party vendors and/or partners.
Personally Identifiable Information You Choose to Provide
We may ask for certain personal information from you for the purpose of providing to you content and/or services that you request. We collect personal information such as you or your organization’s: (i) contact information (including name, telephone number, email and address); (ii) learning content (including information, data, text and/or other materials) submitted by you; (iii) username and password (specifically chosen by you and/or your social media user name/handle); (iv) contact information of employees and/or others you share with us; (v) demographic information (including age, birthdate and gender); (vi) location information (such as geographic location of the device you are using) and (vii) preferences and behavior (such as activity stream, job skills and learning paths). Once you register, you have opted in to receive electronic communications from Cognitive Advisors. Cognitive Advisors may also provide you with the opportunity to participate in surveys through our Services. If you participate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.
Non-Personally Identifiable Information We Collect
Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
Aggregate: We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual. We may share user information in the aggregate with third parties.
Other Tracking Technologies: We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address and/or other demographic information. This information is used to maintain the accuracy of information on our website and for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users. In contrast to Cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your personally identifiable information.
HOW WE USE THAT INFORMATION
- operate, maintain and improve our Services;
- answer questions and respond to your requests;
- perform analytics and conduct research;
- send you reminders, support and marketing messages;
- manage our administration of the Services;
- improve the design and content of our Services; and
- analyze programs, products and services we offer.
The information collected in the aggregate enables Cognitive Advisors to better understand your use of the Services and to enhance your enjoyment. We may use financial information to process payment for any purchases made on our Service, enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Services, you agree to receive certain communications from us including but not limited to the following:
Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.
Parties with whom we may share your information:
Sharing between Organizations
As part of the ‘TREK’ learning experience manager, Cognitive Advisors will facilitate the sharing of information between an organization and/or its administrator and the users involved in the analysis process through the Services. As part of the learning technology, you and/or your administrator will have access to learning paths, competencies, field based experiences, curriculum and/or productivity. The parties using the Services may contact each other through the notification system and/or receive feedback.
What happens in the event of a change of control:
If we sell or otherwise transfer part or all of Cognitive Advisors or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.
YOUR INFORMATION CHOICES
We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to Cognitive Advisors, and you can limit the communications that Cognitive Advisors sends to you. If you visit our Services and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such personally identifiable information by contacting Cognitive Advisors, your administrator and/or by changing your preferences on the Service. Please be aware that even after your request for a change is processed, Cognitive Advisors may, for a time, retain residual information about you in its backup and/or archival copies of its database. Please be aware that we may still email you non-commercial emails related to your account and your transactions through our Services. Following termination and/or deactivation of your account, Cognitive Advisors may retain information (including without limitation your profile information) for a commercially reasonable time for backup, archival, and/or audit purposes. In some cases, if you choose not to provide Cognitive Advisors with requested information, you may not be able to use and/or access all of our Services.
How to Opt Out of Collection By Cognitive Advisors And Transfers to Third Parties
Cognitive Advisors will offer users in the E.U. whose personally identifiable information has been transferred to the United States the opportunity to opt out from: (a) the disclosure of personally identifiable information to a non-agent third party; and (b) the use or disclosure of personally identifiable information for a purpose other than the purposes for which the information originally was collected or subsequently authorized by the individual or a compatible purpose. If Cognitive Advisors were to receive “sensitive personal information” (which includes, without limitation, personal information specifying medical and/or health conditions, racial and/or ethnic origin,), Cognitive Advisors will request and obtain affirmative consent before disclosing such information to a non-agent third party and before using such information for a purpose other than the purpose originally disclosed and/or a compatible purpose. Cognitive Advisors will provide you with reasonable mechanisms to exercise your choices should such circumstances arise.
Your California Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to receive: (a) information identifying any third party companies to whom Cognitive Advisors may have disclosed personal information to for direct marketing, within the past year; and (b) a description of the categories of personal information disclosed. To obtain such information, please email your request to firstname.lastname@example.org we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above.
DATA INTEGRITY AND ACCESS
Cognitive Advisors will only process personal information in a way that is set forth herein and relevant for the purpose for which it was collected and/or authorized by you. Upon request, we will grant you reasonable access to personal information that we hold about you. For security purposes, Cognitive Advisors may require verification of identity before providing access to personal information.
SERVICE ELIGIBILITY AND CHANGES
Children and Minors. Cognitive Advisors does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at email@example.com. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Services.
We work hard to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold. Your account is protected by password for your privacy and security. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the internet is not a completely secure environment, Cognitive Advisors cannot warrant the security of any information you transmit to Cognitive Advisors or guarantee that information on the Services may not be accessed, disclosed, altered and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Please do your part to help Cognitive Advisors. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Cognitive Advisors, at all times. Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing your account. We are not responsible for the functionality, privacy and/or security measures of any other organization.
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