Cognem (“Cognem” / “we” / “us”) is dedicated to safeguarding your privacy. This Privacy Policy outlines how we gather, store, utilize, and share information about our users via our website, www.cognem.com (the “Website”), and our services as detailed in our Terms of Use (the “Services”).
Consent: By using the Website or our Services, you agree to the use of your Personal Information as described in this Privacy Policy. Except as outlined in this policy, your Personal Information will not be used for any other purpose without your consent. We do not actively collect Personal Information for the purpose of selling or marketing in a way that specifically identifies individuals. You can withdraw your consent to our processing of your Personal Information at any time, though doing so may affect your ability to continue using the Website and/or the Services.
Collection of Information: We strive to collect, use, and disclose only the information necessary to manage your account, provide the Services, maintain our customer/visitor lists, respond to your inquiries, provide feedback, identify users, and improve our services. We will keep any contact information you provide when signing up for our Services or contacting us confidential and will use it only for the purposes for which it was collected (subject to the exclusions and disclosures listed below), unless you agree to share it with third parties.
The Website and our Services may collect two types of information: Personal Information and Non-Personal Information. This Privacy Policy does not cover the collection, use, or disclosure of the following information, which is not restricted by applicable privacy laws: (a) publicly available information, such as names, addresses, telephone numbers, and email addresses when listed in a directory or available through directory assistance; or (b) Non-Personal Information (as defined below).
Personal Information: “Personal Information” refers to identifiable information such as your name, address, email address, credit card details, birth date, and gender. When collecting this information, we will clearly identify what is being collected and its intended use. Providing Personal Information is always optional, but not providing certain requested information may prevent you from registering to use the Website or accessing certain features. We may gather Personal Information through registration processes, communications with you, information downloads, service purchases, user support, surveys, and information your employer submits about you, including details about your salary, position, benefits plans, and employment contract.
Non-Personal Information: “Non-Personal Information” is anonymous data, such as an Internet Protocol Address (IP Address) stripped of personal details, the domain used to access the Website, and the type and version of browser or operating system used by visitors. Aggregate information, such as demographic statistics (e.g., average age or geographical distribution of users), number of visitors, pages accessed, and average time spent on the Website, is not considered Personal Information. Similarly, business contact information, such as the name, title, business address, or phone number of a business or professional person or an employee of an organization, is not regarded as Personal Information.
Although the collection, use, or disclosure of certain Non-Personal Information through the Internet is not restricted, we provide information in this Privacy Policy for transparency regarding the operation of the Website. Such Non-Personal Information is collected or derived by us during the operation of the Website. For example, our web servers may automatically collect Non-Personal Information provided through your browser or stored in a cookie when you visit the Website.
Use of Information: We collect information for the following purposes:
Registration: To use our Services, you must provide certain Personal Information, such as your name and email address. Your employer will also provide information about you, including your name, email address, employment agreement, position, tax information, and salary. Generally, none of your account registration information will be shared with other users of the Website or our Services, except for your employer’s ability to see the information in your employee profile.
Information Sharing Among Users: Your employer and designated human resources professionals will be able to view certain Personal Information included in your employee profile. They will also be able to see certain actions you take while using the Website, such as vacation requests made through the Services. Your Personal Information will not be visible to any other user besides your employer and their designated human resources professionals.
Transactional Notifications: We send notifications for certain activities related to your use of our Services, regardless of your indicated email preferences. For example, we may notify you of updates to our Terms of Use or Privacy Policy.
Marketing Communications: If you opt-in to receive marketing communications from us, we will keep you informed about our products and services. You can withdraw your consent to receive marketing communications at any time by following the opt-out instructions in each communication or by contacting our marketing department at [email protected]. No information will be shared with third parties/affiliates for marketing/promotional purposes. This excludes text messaging originator opt-in data and consent, which will not be shared with third parties.
Statistics: We collect statistics about the use of Services purchased through the Website. This information is kept confidential, but aggregate statistics that do not personally identify individuals may be made available to other members or third parties.
Employer Statistics: We also collect certain statistics that your employer can compile in aggregate, such as tracking salaries over time, headcounts, and other departmental information. These statistics will only be visible to your employer and their designated human resources staff, not to any other user.
System Logs & Cookies: We use cookies to track content usage and traffic on the Website. A cookie is a text file placed on your hard disk by a web server. The Website uses cookies to compile aggregate statistics about Website usage, such as the number of users, duration of visits, and pages viewed. This information helps us improve the Website’s content. You can set your browser to notify you when you receive a cookie, allowing you to decide whether to accept it. Disabling cookies may limit your ability to use some features of the Website. We do not link cookie information to any personally identifiable information you provide while on the Website.
Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded along with your registration information in our databases.
Advertisements: Advertisements on the Website may be delivered by us or third-party web advertisers. These advertisers may set cookies that allow their advertisement server to recognize your computer each time they send an online advertisement. This enables advertisement servers to compile information about where or whether you viewed their advertisements and which advertisements you clicked on, allowing them to deliver targeted ads they believe will interest you. This Privacy Policy applies to cookies set by us but does not cover cookies set by third-party advertisers. For their privacy practices, consult the relevant third-party advertiser’s privacy policy.
If we intend to use your Personal Information for any purposes not identified above in the future, we will inform you by updating this Privacy Policy. See the section titled ‘Amendment of this Policy’ for more details.
Disclosures & Transfers: We have implemented contractual and organizational safeguards with our agents to ensure the proper protection of your Personal Information (see further Security below). Beyond these measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see Important Exceptions below).
As of the date of this Privacy Policy, we share Personal Information about you in respect of the Website only with our agents and partners, such as service providers, analytics providers, and website hosting services. Our primary servers are located in Canada, so your Personal Information may be accessible to the Canadian government or its agencies under a lawful order, despite the safeguards we have in place. No Personal Information is stored or shared outside of Canada.
We may employ third parties to help improve the Website and/or Services. These third parties may have limited access to user information solely to help improve the Website and/or Services and will be contractually restricted from using member information for any other purpose.
Important Exceptions: We may disclose your Personal Information to third parties without your consent if necessary to identify, contact, or take legal action against someone causing injury or interference with our rights or property, other Website members, users of the Services, or anyone else who could be harmed by such activities. We may disclose Personal Information when required by law and in good faith.
Your Personal Information may also be disclosed in connection with a corporate reorganization, merger, or sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out for such purposes. The acquiring entity will be required to use the information as permitted by this Privacy Policy.
Security: The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information securely. We take technical, contractual, administrative, and physical security steps to protect the Personal Information you provide. We have procedures in place to limit the dissemination of your Personal Information to designated staff necessary to fulfill the purposes communicated to you.
In certain areas, such as when you provide sensitive employment information, the Website uses 256-bit Secure Sockets Layer (SSL) encryption technology to help protect the security of your information during transmission.
You are also responsible for protecting the security of your Personal Information. For example, never share your email account information or password for the Services with third parties.
Retention: We will retain your Personal Information as long as it is necessary for the identified purposes or as required by law, which may extend beyond the termination of our relationship with you. We may keep certain data to prevent fraud, future abuse, or for legitimate business purposes, such as analyzing aggregated, non-personally identifiable data, account recovery, or if required by law. All retained personal information will remain subject to this Privacy Policy. If you request the removal of your name from our databases, complete deletion of all your Personal Information may not be possible due to technological and legal constraints.
Amendment of this Policy: We reserve the right to change this Privacy Policy at any time. If we make changes, we will post an appropriate notice on the homepage at www.cognem.com. Non-material changes (such as clarifications) will become effective on the date the change is posted. Material changes will become effective 30 days from their posting on the Website. Unless stated otherwise, our current Privacy Policy applies to all Personal Information we hold about you. The date of the latest update is indicated at the bottom of this document. We recommend printing a copy of this Privacy Policy for your reference and revisiting this policy periodically to ensure you are aware of any changes. Your continued use of the Website signifies your acceptance of any changes.
Access and Accuracy: You have the right to access the Personal Information we hold about you to verify it and to receive a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, though in certain circumstances we may not be able to disclose all relevant information, such as where the information also pertains to another user. In such cases, we will provide reasons for the denial upon request. We strive to deal with all access and modification requests in a timely manner.
We make every reasonable effort to keep your Personal Information accurate and up-to-date and will provide mechanisms for you to update, correct, delete, or add to your Personal Information as appropriate. We will transmit amended Personal Information to parties to whom we are permitted to disclose your information. Having accurate Personal Information enables us to provide you with the best possible service.
Contact Us: You can help keep us informed of any changes, such as a change of address or telephone number. If you would like to access your information, have any questions, comments, or suggestions, or find any errors in our information about you, please contact our Cognem security team at [email protected].
