Last Updated: March 5, 2020
Collection of Information
Information You Provide to Us
We collect information when you register for an account, participate in interactive features, fill out a form or a survey, make a purchase, communicate with us via social media sites, request customer support, or otherwise communicate with us. The information you may provide includes your name, email, password, street address, payment method information, Employer, Employer address, feedback and survey responses, and other information about you included within your messages to us.
Other Information About Your Use of the Services
When you use our Services, we collect the following information about you:
Usage Information: Whenever you use our Services, we collect usage information, such as the sessions you use, videos you view, what screens or features you access, and other similar types of usage information.
Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product description, price, date, and time and date of the transaction.
Log Information: We collect standard log files when you use our Services, which include the type of web browser you use, app version, access times and dates, pages viewed, your IP address, and the page you visited before navigating to our websites.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type, carrier and region).
Information we Generate: We generate some information about you based on other information we have collected. For example, like most platforms, we use your IP address to derive the approximate location of your device. We also use your first name to make an educated guess about your gender and use information about your activity to help determine the likelihood of you continuing to use our Services in the future (which we hope will be the case!).
Use of Information
We use the data we collect (including personal information, where applicable) to:
Provide, operate, maintain, improve, and promote the Website and Services;
Enable you to access and use the Website and Services;
Process and complete transactions, and send you related information, including assessment results and newsletters;
Send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
Send commercial communications, in line with your communication preferences, such as providing you with information about products and services, features, newsletters, offers, promotions, and events about us and our partners; and send other news or information about us and our partners.
Monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
Comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
Personalize the Websites and Services, including providing features or content that match your interests and preferences.
If you are a contractor, perform our contract with you or to take steps at your request before entering into a contract with you, comply with legal obligations, pursue our legitimate interests related to human resources, business and safety /security and protect our legal position in the event of legal proceedings.
CogDiv takes all reasonable steps to protect the data that we receive from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We utilize appropriate physical, digital, and administrative protocols to keep your information secure. Notwithstanding, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the Services may not be secure. Therefore, take special care in deciding what information you send to us via email.
Sharing of Information
With companies and contractors that perform services for us, including email service providers, payment processors, fraud prevention vendors and other service providers;
In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements:
If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of CogDiv or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
Between and among CogDiv and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
With your consent or at your direction. For instance, you may choose to share actions you take on our Services with third-party social media services via the integrated tools we provide via our Services.
We also share aggregated or other information not subject to obligations under the data protection laws of your jurisdiction with third parties. For example, we sometimes share aggregate information with research organizations to help facilitate their research
3rd Party Advertising and Analytics Services
CogDiv is based in the United States and processes information in the United States, which may not provide equivalent levels of data protection as your home jurisdiction.
You may update certain account information you provide to us (such as your name or email address) by contacting us at email@example.com. If you wish to disable your account, please contact us at firstname.lastname@example.org, but note that we retain certain information when required or permitted by law. We also retain cached or archived copies of information about you for a certain period of time.
You may opt out of receiving promotional emails from CogDiv by following the instructions in those emails or by logging into your account. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Information for Individuals in Switzerland UK and the EEA
The sections below apply to you if you use our Services while in Switzerland, the United Kingdom or the European Economic Area (collectively, “Europe”). Legal Basis for Processing
When we process your personal data we will only do so in the following situations:
As necessary to perform our responsibilities under our contract with you (like processing payments and providing the products or services you have requested);
When we have a legitimate interest in processing your personal data, including to communicate with you about changes to our Services, to help secure and improve our Services (including to prevent fraud) and to analyze use of our Services;
As necessary to comply with our legal obligations; and When we have your consent to do so.
We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.
Data Subject Requests
Subject to certain limits and conditions provided under law, you have the following rights:
You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or made available in a portable form.
You also have the right to object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim).
When we ask for your consent, you may withdraw that consent at any time.
You have the right to file a complaint regarding our data protection practices with a supervisory authority. Please see this directory for contact details:https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
If you would like to exercise any of these rights and can’t do so directly via the Services or your device, you may contact us as indicated below.
Information for California Residents
This section provides additional disclosures required by the California Consumer Privacy Act (or “CCPA”).
In the last 12 months, we collected the following categories of personal information: identifiers (such as name, contact information and device identifiers), internet or other electronic network activity information (such as browsing behavior), approximate geolocation data, inferences (such as approximate location or product interests) and other personal information (such as payment method information, user credentials or health-related information). For more details about the personal information we collect, including the categories of sources, please see the “Collection of Information” section above. We collect this information for the business and commercial purposes described in the “Use of Information” section above. We share this information with the categories of third parties described in the “Sharing of Information” section above. Subject to certain limitations and exceptions, the CCPA provides California consumers the right to request to know more details about the categories and specific pieces of personal information, to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
We do not “sell” the personal information we collect (and will not sell it in the future without providing a right to opt out). California consumers may make a rights request by emailing us at email@example.com. We will verify your request by asking you to provide information that matches information we have on file about you. Consumers can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.