Privacy Policy
This Privacy Policy describes the policies and procedures that govern
Docunexus, Inc.’s (the Company) collection, use and disclosure of Your
information when You use the Kognie Platform (as defined in the
Terms of Service) and informs You about Your privacy rights and how
You are protected by the law.
The Company uses Your Personal data to provide and improve the
services provided by the Kognie Platform. By using these services, You
agree to the collection and use of information in accordance with this
Privacy Policy.
Interpretation
The words of which the initial letter is capitalized have meanings
defined under the following conditions. The following definitions shall
have the same meaning regardless of whether they appear in singular
or in plural.
Definitions
For the purposes of this Privacy Policy:
-
Account means a unique account created for You to access our
Service or parts of our Service.
-
Company (referred to as either "the Company", "We", "Us" or
"Our" in this Agreement) refers to Docunexus, Inc., 15 Morse
Street. Poughkeepsie, NY 12601.
-
Business, for the purpose of the CCPA (California Consumer
Privacy Act), refers to the Company as the legal entity that
collects Consumers' personal information and determines the
purposes and means of the processing of Consumers' personal
information, or on behalf of which such information is collected
and that alone, or jointly with others, determines the purposes
and means of the processing of consumers' personal
information, that does business in the State of California.
-
Data Controller, for the purposes of the GDPR (General Data
Protection Regulation), refers to the Company as the legal
person which alone or jointly with others determines the
purposes and means of the processing of Personal Data.
-
Controller For the purpose of the GDPR, the Company is the
Data Controller.
-
Consumer, for the purpose of the CCPA (California Consumer
Privacy Act), means a natural person who is a California
resident. A resident, as defined in the law, includes (1) every
individual who is in the USA for other than a temporary or
transitory purpose, and (2) every individual who is domiciled in
the USA who is outside the USA for a temporary or transitory
purpose.
-
Cookies are small files that are placed on Your computer,
mobile device or any other device by a website, containing the
details of Your browsing history on that website among its many
uses.
-
Country refers to: New York, United States
-
Device means any device that can access the Service such as a
computer, a cellphone or a digital tablet.
-
Do Not Track (DNT) is a concept that has been promoted by US
regulatory authorities, in particular the U.S. Federal Trade
Commission (FTC), for the Internet industry to develop and
implement a mechanism for allowing internet users to control the
tracking of their online activities across websites.
-
Personal Data is any information that relates to an identified or
identifiable individual.
- For the purposes for GDPR, Personal Data means any
information relating to You such as a name, an identification
number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity.
- For the purposes of the CCPA, Personal Data means any
information that identifies, relates to, describes or is capable
of being associated with, or could reasonably be linked,
directly or indirectly, with You.
-
Sale, for the purpose of the CCPA (California Consumer Privacy
Act), means selling, renting, releasing, disclosing, disseminating,
making available, transferring, or otherwise communicating
orally, in writing, or by electronic or other means, a Consumer's
personal information to another business or a third party for
monetary or other valuable consideration.
-
Service refers to Kognie.com.
-
Service Provider means any natural or legal person who
processes the data on behalf of the Company. It refers to third-
party companies or individuals employed by the Company to
facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist
the Company in analyzing how the Service is used. For the
purpose of the GDPR, Service Providers are considered Data
Processors.
-
Third-party Social Media Service refers to any website or any
social network website through which a User can log in or create
an account to use the Service.
-
Usage Data refers to data collected automatically, either
generated by the use of the Service or from the Service
infrastructure itself (for example, the duration of a page visit).
-
Website refers to Kognie.com
-
You means the individual accessing or using the Service, or the
company, or other legal entity on behalf of which such individual
is accessing or using the Service, as applicable.
-
Under GDPR (General Data Protection Regulation), You can be
referred to as the Data Subject or as the User as you are the
individual using the Service.
Collecting and Using Your Personal Data
Personal Data
While using the Kognie Platform, it may ask You to provide it with
certain personally identifiable information (PII) that can be used to
contact or identify You. PII may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data
Usage Data is collected automatically when using the Kognie Platform.
Usage Data may include information such as Your Device's Internet
Protocol address (e.g. IP address), browser type, browser version, the
pages of the Kognie that You visit, the time and date of Your visit, the
time spent on those pages, unique device identifiers and other
diagnostic data.
When You access the Kognie Platform by or through a mobile device, it
may collect certain information automatically, including, but not limited
to, the type of mobile device You use, Your mobile device unique ID,
the IP address of Your mobile device, Your mobile operating system,
the type of mobile Internet browser You use, unique device identifiers
and other diagnostic data.
The Kognie may also collect information that Your browser sends
whenever You visit it or when You access it by or through a mobile
device
Information from Third-Party Social Media Service
The Company allows You to create an account and log in to use the
Kognie Platform through the following Third-party Social Media
Services:
* Twitter
* Facebook
* Google
If You decide to register through any of these Third-Party Social Media
Service, We may collect Personal data that is already associated with
Your Third-Party Social Media Service's account, such as Your name,
Your email address, Your activities or Your contact list associated with
that account.
You may also have the option of sharing additional information with the
Company through Your Third-Party Social Media Service's account. If
You choose to provide such information and Personal Data, during
registration or otherwise, You are giving the Company permission to
use, share, and store it in a manner consistent with this Privacy Policy.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity
on Our Service and store certain information. Tracking technologies
used are beacons, tags, and scripts to collect and track information and
to improve and analyze Our Service. The technologies We use may
include:
-
Cookies or Browser Cookies. A cookie is a small file placed on
Your Device. You can instruct Your browser to refuse all Cookies
or to indicate when a Cookie is being sent. However, if You do
not accept Cookies, You may not be able to use some parts of
the Kognie Platform. Unless you have adjusted Your browser
setting so that it will refuse Cookies, the Kognie Platform may
use Cookies.
-
Flash Cookies. Certain features of the Kognie Platform may use
local stored objects (or Flash Cookies) to collect and store
information about Your preferences or Your activity on the
Kognie Platform. Flash Cookies are not managed by the same
browser settings as those used for Browser Cookies. For more
information on how You can delete Flash Cookies, please read
"Where can I change the settings for disabling, or deleting local
shared objects?" available at https://helpx.adobe.com/flashplayer/kb/disable-local-shared-objectsflash.html#main_Where_can_I_change_the_settings_for_disabli
ng__or_deleting_local_shared_objects_
-
Web Beacons. Certain sections of the Kognie Platform and our
emails may contain small electronic files known as web beacons
(also referred to as clear gifs, pixel tags, and single-pixel gifs)
that permit the Company, for example, to count users who have
visited those pages or opened an email and for other related
website statistics (for example, recording the popularity of a
certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies
remain on Your personal computer or mobile device when You go
offline, while Session Cookies are deleted as soon as You close Your
web browser. Learn more about cookies: What Are Cookies?.
We use both Session and Persistent Cookies for the purposes set out
below:
-
Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Us
- Purpose: These Cookies are essential to provide You with
services available through the Kognie Platform and to enable
You to use some of its features. They help to authenticate users
and prevent fraudulent use of user accounts. Without these
Cookies, the services that You have asked for cannot be
provided, and We only use these Cookies to provide You with
those services.
-
Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: The Company
- Purpose: These Cookies identify if users have accepted the use
of cookies on the Website.
-
Functionality Cookies
- Type: Persistent Cookies
- Administered by: The Company
- Purpose: These Cookies allow the Kognie Platform to remember
choices You make when You use the Kognie Platform, such as
remembering your login details or language preference. The
purpose of these Cookies is to provide You with a more personal
experience and to avoid You having to re-enter your preferences
every time You use the Kognie Platform.
-
Tracking and Performance Cookies
- Type: Persistent Cookies
- Type: Persistent Cookies
- Purpose: These Cookies are used to track information about
traffic to the Kognie Platform and how users use the Kognie
Platform. The information gathered via these Cookies may
directly or indirectly identify you as an individual visitor. This is
because the information collected is typically linked to a
pseudonymous identifier associated with the device you use to
access the Website. We may also use these Cookies to test new
pages, features or new functionality of the Kognie Platform to
see how our users react to them.
-
Targeting and Advertising Cookies
- Type: Persistent Cookies
- Administered by: Third-Parties
- Purpose: These Cookies track your browsing habits to enable Us
to show advertising which is more likely to be of interest to You.
These Cookies use information about your browsing history to
group You with other users who have similar interests. Based on
that information, and with Our permission, third party advertisers
can place Cookies to enable them to show adverts which We
think will be relevant to your interests while You are on third
party websites.
For more information about the cookies we use and your choices
regarding cookies, please visit our Cookies Policy or the Cookies
section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
-
To provide and maintain the Kognie Platform, including to
monitor the usage of the Kognie Platform.
-
To manage Your Account: to manage Your registration as a
user of the Kognie Platform. The Personal Data You provide can
give You access to different functionalities of the Kognie Platform
that are available to You as a registered user.
-
For the performance of a contract: the development,
compliance and undertaking of the purchase contract for the
products, items or services You have purchased or of any other
contract with the Company through the Kognie Platform.
-
To contact You: To contact You by email, telephone calls, SMS,
or other equivalent forms of electronic communication, such as a
mobile application's push notifications regarding updates or
informative communications related to the functionalities,
products or contracted services, including the security updates,
when necessary or reasonable for their implementation.
-
To provide You with news, special offers and general
information about other goods, services and events which we
offer that are similar to those that you have already purchased or
enquired about unless You have opted not to receive such
information.
-
To manage Your requests: To attend and manage Your
requests to the Kognie Platform or to the Company.
-
To deliver targeted advertising to You: We may use Your
information to develop and display content and advertising (and
work with third-party vendors who do so) tailored to Your
interests and/or location and to measure its effectiveness.
-
For business transfers: We may use Your information to
evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or
all of Our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which Personal
Data held by Us about the users of the Kognie Platform is among
the assets transferred.
-
For business transfers: We may use Your information to
evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or
all of Our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which Personal
Data held by Us about the users of the Kognie Platform is among
the assets transferred.
We may share Your personal information in the following situations:
-
With Service Providers: We may share Your personal
information with Service Providers to monitor and analyze the
use of the Kognie Platform, to show advertisements to You to
help support and maintain the Kognie Platform, to advertise on
third party websites to You after You visited the Kognie Platform,
for payment processing, to contact You.
-
For business transfers: We may share or transfer Your
personal information in connection with, or during negotiations
of, any merger, sale of Company assets, financing, or acquisition
of all or a portion of Our business to another company.
-
With Affiliates: We may share Your information with Our
affiliates, in which case we will require those affiliates to honor
this Privacy Policy. Affiliates include any other subsidiaries, joint
venture partners or other companies that the Company controls
or that are under common control with the Company.
-
With business partners: We may share Your information with
the business partners of the Company in order to offer You
certain products, services or promotions.
-
With other users: when You share personal information or
otherwise interact in the public areas with other users, such
information may be viewed by all users and may be publicly
distributed outside. If You interact with other users or register
through a Third-Party Social Media Service, Your contacts on the
Third-Party Social Media Service may see Your name, profile,
pictures and description of Your activity. Similarly, other users
will be able to view descriptions of Your activity, communicate
with You and view Your profile.
-
With Your consent: We may disclose Your personal information
for any other purpose with Your consent
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is
necessary for the purposes set out in this Privacy Policy. We will retain
and use Your Personal Data to the extent necessary to comply with our
legal obligations (for example, if we are required to retain your data to
comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
The Company will also retain Usage Data for internal analysis
purposes. Usage Data is generally retained for a shorter period of time,
except when this data is used to strengthen the security or to improve
the functionality of the Kognie Platform, or We are legally obligated to
retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the
Company's operating offices and in any other places where the parties
involved in the processing are located. It means that this information
may be transferred to — and maintained on — computers located
outside of Your state, province, country or other governmental
jurisdiction where the data protection laws may differ than those from
Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of
such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that
Your data is treated securely and in accordance with this Privacy Policy
and no transfer of Your Personal Data will take place to an organization
or a country unless there are adequate controls in place including the
security of Your data and other personal information.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your
Personal Data is transferred and becomes subject to a different Privacy
Policy.
Law enforcement
Under certain circumstances, the Company may be required to
disclose Your Personal Data if required to do so by law or in response
to valid requests by public authorities (e.g. a court or a government
agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief
that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with
the Kognie Platform
- Protect the personal safety of Users of the Kognie Platform or
the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember
that no method of transmission over the Internet, or method of
electronic storage is 100% secure. While We strive to use commercially
acceptable means to protect Your Personal Data, We cannot
guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal
Data. These third-party vendors collect, store, use, process and
transfer information about Your activity on the Kognie Platform in
accordance with their Privacy Policies.
Analytics
We may use third-party Service providers to monitor and analyze the
use of the Kognie Platform.
Google Analytics
- Google Analytics is a web analytics service offered by Google
that tracks and reports website traffic. Google uses the data
collected to track and monitor the use of the Kognie Platform.
This data is shared with other Google services. Google may use
the collected data to contextualize and personalize the ads of its
own advertising network.
- You can opt-out of having made your activity on the Kognie
Platform available to Google Analytics by installing the Google
Analytics opt-out browser add-on. The add-on prevents the
Google Analytics JavaScript (ga.js, analytics.js and dc.js) from
sharing information with Google Analytics about visits activity.
- For more information on the privacy practices of Google, please
visit the Google Privacy & Terms web
page: https://policies.google.com/privacy
Firebase
Mixpanel
- Mixpanel is provided by Mixpanel Inc.
- You can prevent Mixpanel from using your information for
analytics purposes by opting-out. To opt-out of Mixpanel service,
please visit this page: https://mixpanel.com/optout/
- For more information on what type of information Mixpanel
collects, please visit the Terms of Use page of
Mixpanel: https://mixpanel.com/terms
Amplitude
Advertising
- We may use Service Providers to show advertisements to You to help
support and maintain Our Service.
Google AdSense & DoubleClick Cookie
- Google, as a third party vendor, uses cookies to serve ads on
the Kognie Platform. Google's use of the DoubleClick cookie
enables it and its partners to serve ads to our users based on
their visit to the Kognie Platform or other websites on the
Internet.
- You may opt out of the use of the DoubleClick Cookie for
interest-based advertising by visiting the Google Ads Settings
web page: http://www.google.com/ads/preferences/
Facebook
Linkedin
Email Marketing
We may use Your Personal Data to contact You with newsletters,
marketing or promotional materials and other information that may be
of interest to You. You may opt-out of receiving any, or all, of these
communications from Us by following the unsubscribe link or
instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send
emails to You.
User
Payments
We may provide paid products and/or services within the Kognie
Platform. In that case, we may use third-party services for payment
processing (e.g. payment processors).
We will not store or collect Your payment card details. That information
is provided directly to Our third-party payment processors whose use of
Your personal information is governed by their Privacy Policy. These
payment processors adhere to the standards set by PCI-DSS as
managed by the PCI Security Standards Council, which is a joint effort
of brands like Visa, Mastercard, American Express and Discover. PCIDSS requirements help ensure the secure handling of payment
information
PayPal
Behavioral Remarketing
The Company uses remarketing services to advertise to You after You
accessed or visited the Kognie Platform. We and Our third-party
vendors use cookies and non-cookie technologies to help Us recognize
Your Device and understand how You use the Kognie Platform so that
We can improve the Kognie Platform to reflect Your interests and serve
You advertisements that are likely to be of more interest to You.
These third-party vendors collect, store, use, process and transfer
information about Your activity on the Kognie Platform in accordance
with their Privacy Policies and to enable Us to:
- Measure and analyze traffic and browsing activity on the Kognie
Platform
- Show advertisements for our products and/or services to You on
third-party websites or apps
- Measure and analyze the performance of Our advertising
campaign
Some of these third-party vendors may use non-cookie technologies
that may not be impacted by browser settings that block cookies. Your
browser may not permit You to block such technologies. You can use
the following third-party tools to decline the collection and use of
information for the purpose of serving You interest-based advertising:
You may opt-out of all personalized advertising by enabling privacy
features on Your mobile device such as Limit Ad Tracking (iOS) and
Opt Out of Ads Personalization (Android). See Your mobile device Help
system for more information.
We may share information, such as hashed email addresses (if
available) or other online identifiers collected on the Kognie Platform
with these third-party vendors. This allows Our third-party vendors to
recognize and deliver You ads across devices and browsers. To read
more about the technologies used by these third-party vendors and
their cross-device capabilities please refer to the Privacy Policy of each
vendor listed below.
The third-party vendors we use are:
Google Ads (AdWords)
- Google Ads (AdWords) remarketing service is provided by
Google Inc.
- You can opt-out of Google Analytics for Display Advertising and
customize the Google Display Network ads by visiting the
Google Ads Settings page: http://www.google.com/settings/ads
- Google also recommends installing the Google Analytics Opt-out
Browser Add-on - https://tools.google.com/dlpage/gaoptout - for
your web browser. Google Analytics Opt-out Browser Add-on
provides visitors with the ability to prevent their data from being
collected and used by Google Analytics.
- For more information on the privacy practices of Google, please
visit the Google Privacy & Terms web
page: https://policies.google.com/privacy
Twitter
Facebook
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
-
Consent: You have given Your consent for processing Personal
Data for one or more specific purposes.
-
Performance of a contract: Provision of Personal Data is
necessary for the performance of an agreement with You and/or
for any pre-contractual obligations thereof.
-
Legal obligations: Processing Personal Data is necessary for
compliance with a legal obligation to which the Company is
subject.
-
Vital interests: Processing Personal Data is necessary in order
to protect Your vital interests or of another natural person.
-
Public interests: Processing Personal Data is related to a task
that is carried out in the public interest or in the exercise of
official authority vested in the Company.
-
Legitimate interests: Processing Personal Data is necessary
for the purposes of the legitimate interests pursued by the
Company
In any case, the Company will gladly help to clarify the specific legal
basis that applies to the processing, and in particular whether the
provision of Personal Data is a statutory or contractual requirement, or
a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your
Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are
within the EU, to:
-
Request access to Your Personal Data. The right to access,
update or delete the information We have on You. Whenever
made possible, you can access, update or request deletion of
Your Personal Data directly within Your account settings section.
If you are unable to perform these actions yourself, please
contact Us to assist You. This also enables You to receive a
copy of the Personal Data We hold about You.
-
Request correction of the Personal Data that We hold about
You. You have the right to have any incomplete or inaccurate
information We hold about You corrected.
-
Object to processing of Your Personal Data. This right exists
where We are relying on a legitimate interest as the legal basis
for Our processing and there is something about Your particular
situation, which makes You want to object to our processing of
Your Personal Data on this ground. You also have the right to
object where We are processing Your Personal Data for direct
marketing purposes.
-
Request erasure of Your Personal Data. You have the right to
ask Us to delete or remove Personal Data when there is no good
reason for Us to continue processing it.
-
Request the transfer of Your Personal Data. We will provide
to You, or to a third-party You have chosen, Your Personal Data Request access to Your Personal Data. The right to access,
update or delete the information We have on You. Whenever
made possible, you can access, update or request deletion of
Your Personal Data directly within Your account settings section.
If you are unable to perform these actions yourself, please
contact Us to assist You. This also enables You to receive a
copy of the Personal Data We hold about You.
-
Withdraw Your consent. You have the right to withdraw Your
consent on using your Personal Data. If You withdraw Your
consent, We may not be able to provide You with access to
certain specific functionalities of the Kognie Platform.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify
Your identity before responding to such requests. If You make a
request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our
collection and use of Your Personal Data. For more information, if You
are in the European Economic Area (EEA), please contact Your local
data protection authority in the EEA.
CCPA Privacy
This privacy notice section for California residents supplements the
information contained in Our Privacy Policy and it applies solely to all
visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references,
is capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular Consumer or Device. The
following is a list of categories of personal information which we may
collect or may have been collected from California residents within the
last twelve (12) months.
Please note that the categories and examples provided in the list below
are those defined in the CCPA. This does not mean that all examples
of that category of personal information were in fact collected by the
Company, but reflects our good faith belief to the best of our knowledge
that some of that information from the applicable category may be and
may have been collected. For example, certain categories of personal
information would only be collected if You provided such personal
information directly to the Company.
Category A: Identifiers.
- Examples: A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email
address, account name, driver's license number, passport
number, student id number or other similar identifiers.
- Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Examples: A name, signature, Social Security number, physical
characteristics or description, address, telephone number,
passport number, driver's license or state identification card
number, insurance policy number, education, employment,
employment history, bank account number, credit card number,
debit card number, or any other financial information, medical
information, or health insurance information. Some personal
information included in this category may overlap with other
categories.
- Collected: Yes
Category C: Protected classification characteristics under California or federal law.
- Examples: Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status, medical
condition, physical or mental disability, sex (including gender,
gender identity, gender expression, pregnancy or childbirth and
related medical conditions), sexual orientation, veteran or military
status, genetic information (including familial genetic
information).
- Collected: No.
Category D: Commercial information.
- Examples: Records and history of products or services
purchased or considered.
- Collected: Yes.
Category E: Biometric information.
- Examples: Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a template or
other identifier or identifying information, such as, fingerprints,
faceprints, and voiceprints, iris or retina scans, keystroke, gait, or
other physical patterns, and sleep, health, or exercise data.
- Collected: No.
Category F: Internet or other similar network activity.
- Examples: Interaction with our Service or advertisement.
- Collected: Yes.
Category G: Geolocation data.
- Examples: Approximate physical location.
- Collected: No.
Category H: Sensory data.
- Examples: Audio, electronic, visual, thermal, olfactory, or similar
information.
- Collected: No.
Category I: Professional or employment-related information.
- Examples: Current or past job history or performance
evaluations.
- Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
- Examples: Education records directly related to a student
maintained by an educational institution or party acting on its
behalf, such as grades, transcripts, class lists, student
schedules, student identification codes, student financial
information, or student disciplinary records.
- Collected: Only student identification codes voluntarily supplied
by students.
Category K: Inferences drawn from other personal information.
- Examples: Profile reflecting a person's preferences,
characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.
- Collected: No.
Under CCPA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA's scope, such as:
- Health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the
California Confidentiality of Medical Information Act (CMIA) or
clinical trial data.
- Personal Information covered by certain sector-specific privacy
laws, including the Fair Credit Reporting Act (FRCA), the
Gramm-Leach-Bliley Act (GLBA) or California Financial
Information Privacy Act (FIPA), and the Driver's Privacy
Protection Act of 1994.
Sources of Personal Information
We obtain the categories of personal information listed above from the
following categories of sources:
-
Directly from You. For example, from the forms You complete
on the Kognie Platform, preferences You express or provide
through the Kognie Platform, or from Your purchases on the
Kognie Platform.
-
Indirectly from You. For example, from observing Your activity
on the Kognie Platform.
-
Automatically from You. For example, through cookies We or
our Service Providers set on Your Device as You navigate
through our Service.
-
From Service Providers. For example, third-party vendors to
monitor and analyze the use of the Kognie Platform, third-party
vendors to provide advertising on the Kognie Platform, thirdparty vendors to deliver targeted advertising to You, third-party
vendors for payment processing, or other third-party vendors that
We use to provide the Kognie Platform to You.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for "business
purposes" or "commercial purposes" (as defined under the CCPA),
which may include the following examples:
- To operate the Kognie Platform and provide You with the Kognie
Platform.
- To provide You with support and to respond to Your inquiries,
including to investigate and address Your concerns and monitor
and improve the Kognie Platform.
- To fulfill or meet the reason You provided the information. For
example, if You share Your contact information to ask a question
about the Kognie Platform, We will use that personal information
to respond to Your inquiry. If You provide Your personal
information to purchase a product or service, We will use that
information to process Your payment and facilitate delivery.
- To respond to law enforcement requests and as required by
applicable law, court order, or governmental regulations.
- As described to You when collecting Your personal information
or as otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious,
deceptive, fraudulent or illegal activity, including, when
necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not
intended to be exhaustive. For more details on how we use this
information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or
use the personal information We collected for materially different,
unrelated, or incompatible purposes We will update this Privacy Policy.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last
twelve (12) months the following categories of personal information for
business or commercial purposes:
- Category A: Identifiers
- Category B: Personal information categories listed in the
California Customer Records statute (Cal. Civ. Code §
1798.80(e))
- Category D: Commercial information
- Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the
CCPA. This does not mean that all examples of that category of
personal information were in fact disclosed, but reflects our good faith
belief to the best of our knowledge that some of that information from
the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a
commercial purpose, We enter a contract that describes the purpose
and requires the recipient to both keep that personal information
confidential and not use it for any purpose except performing the
contract.
Sale of Personal Information
As defined in the CCPA, "sell" and "sale" mean selling, renting,
releasing, disclosing, disseminating, making available, transferring, or
otherwise communicating orally, in writing, or by electronic or other
means, a consumer's personal information by the business to a third
party for valuable consideration. This means that We may have
received some kind of benefit in return for sharing personal information,
but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the
CCPA. This does not mean that all examples of that category of
personal information were in fact sold, but reflects our good faith belief
to the best of our knowledge that some of that information from the
applicable category may be and may have been shared for value in
return.
We may sell the following categories of personal information:
- Category A: Identifiers
- Category B: Personal information categories listed in the
California Customer Records statute (Cal. Civ. Code §
1798.80(e))
- Category D: Commercial information
- Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the above
categories with the following categories of third parties:
- Service Providers
- Payment processors
- Our affiliates
- Our business partners
- Third party vendors to whom You or Your agents authorize Us to
disclose Your personal information in connection with products
or services We provide to You
Sale of Personal Information of Minors Under 16 Years of Age
We do not sell the personal information of Consumers We actually
know are less than 16 years of age, unless We receive affirmative
authorization (the "right to opt-in") from either the Consumer who is
between 13 and 16 years of age, or the parent or guardian of a
Consumer less than 13 years of age. Consumers who opt-in to the sale
of personal information may opt-out of future sales at any time. To
exercise the right to opt-out, You (or Your authorized representative)
may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16)
has provided Us with personal information, please contact Us with
sufficient detail to enable Us to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding
their personal information. If You are a resident of California, You have
the following rights:
-
The right to notice. You have the right to be notified which
categories of Personal Data are being collected and the
purposes for which the Personal Data is being used.
-
The right to request. Under CCPA, You have the right to
request that We disclose information to You about Our collection,
use, sale, disclosure for business purposes and share of
personal information. Once We receive and confirm Your
request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We
collected about You
- Our business or commercial purpose for collecting or selling that
personal information
- The categories of third parties with whom We share that
personal information
- The specific pieces of personal information We collected about
You
- If we sold Your personal information or disclosed Your personal
information for a business purpose, We will disclose to You:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
-
The right to say no to the sale of Personal Data (optout). You have the right to direct Us to not sell Your personal
information. To submit an opt-out request please contact Us.
-
The right to delete Personal Data. You have the right to
request the deletion of Your Personal Data, subject to certain
exceptions. Once We receive and confirm Your request, We will
delete (and direct Our Service Providers to delete) Your personal
information from our records, unless an exception applies. We
may deny Your deletion request if retaining the information is
necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the personal
information, provide a good or service that You requested, take
actions reasonably anticipated within the context of our ongoing
business relationship with You, or otherwise perform our contract
with You.
- Detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible for
such activities.
- Debug products to identify and repair errors that impair existing
intended functionality.
- Exercise free speech, ensure the right of another consumer to
exercise their free speech rights, or exercise another right
provided for by law.
- Comply with the California Electronic Communications Privacy
Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or
statistical research in the public interest that adheres to all other
applicable ethics and privacy laws, when the information's
deletion may likely render impossible or seriously impair the
research's achievement, if You previously provided informed
consent.
- Enable solely internal uses that are reasonably aligned with
consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are
compatible with the context in which You provided it.
-
The right not to be discriminated against. You have the right
not to be discriminated against for exercising any of Your
consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including
the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for
goods or services or a different level or quality of goods or
services
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are
a California resident, You can contact Us:
Only You, or a person registered with the California Secretary of State
that You authorize to act on Your behalf, may make a verifiable request
related to Your personal information.
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify
You are the person about whom We collected personal
information or an authorized representative
- Describe Your request with sufficient detail that allows Us to
properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required
information if we cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge
within 45 days of receiving Your verifiable request. The time period to
provide the required information may be extended once by an
additional 45 days when reasonable necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period
preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your
personal information that is readily useable and should allow You to
transmit the information from one entity to another entity without
hindrance.
Do Not Sell My Personal Information
You have the right to opt-out of the sale of Your personal information.
Once We receive and confirm a verifiable consumer request from You,
we will stop selling Your personal information. To exercise Your right to
opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or
advertising partners) may use technology on the Service that sells
personal information as defined by the CCPA law. If you wish to opt out
of the use of Your personal information for interest-based advertising
purposes and these potential sales as defined under CCPA law, you
may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You
may need to opt out on every browser that You use.
Website
You can opt out of receiving ads that are personalized as served by our
Service Providers by following our instructions presented on the
Service:
The opt out will place a cookie on Your computer that is unique to the
browser You use to opt out. If you change browsers or delete the
cookies saved by your browser, You will need to opt out again.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of
information about the apps You use in order to serve You ads that are
targeted to Your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads
Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from Your
mobile device by changing the preferences on Your mobile device.
You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing
activities. If You are visiting such websites, You can set Your
preferences in Your web browser to inform websites that You do not
want to be tracked. You can enable or disable DNT by visiting the
preferences or settings page of Your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light
law), California residents with an established business relationship with
us can request information once a year about sharing their Personal
Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the
Light law, and if You are a California resident, You can contact Us
using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow
California residents under the age of 18 who are registered users of
online sites, services or applications to request and obtain removal of
content or information they have publicly posted.
To request removal of such data, and if You are a California resident,
You can contact Us using the contact information provided below, and
include the email address associated with Your account.
Be aware that Your request does not guarantee complete or
comprehensive removal of content or information posted online and
that the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated
by Us. If You click on a third party link, You will be directed to that third
party's site. We strongly advise You to review the Privacy Policy of
every site You visit.
We have no control over and assume no responsibility for the content,
privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You
of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our
Service, prior to the change becoming effective and update the "Last
updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any
changes. Changes to this Privacy Policy are effective when they are
posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us
at contact@kognie.com