Privacy Policy

IMPORTANT: PLEASE READ CAREFULLY

Effective as of February 14, 2020.

Who we are:

Cogni, Inc. ("Cogni," "we", "our", or "us") is a financial services company. When you use our services, you'll share some information with us that could be used to identify you or that is associated with information that identifies you ("Personal Information"). Our goal is to clearly inform you about the information we collect, how we use it, and whom we share it with. This Privacy Policy applies to Personal Information that we gather or collect via our website or our app (collectively, the "Services"). It does not apply to any Personal Information collected by third party websites not operated by us.

You may also email us at privacy@getcogni.com with any privacy-related questions you have.

The information we collect:

There are three basic categories of information we collect:

Personal Information you provide to us

We may collect Personal Information that you choose to share with us. For example, when you set up an account, we need to collect important details about you, such as your name, phone number, date of birth, unique username, location, social security number, and email address. We may also collect any communications between you and Company and any other information you provide to Company. To help the government fight the funding of terrorism and money laundering activities, we obtain, verify and record information about beneficial owners, including you, of Clients and other permitted users of Services. This means that when you access or use our Services, we may ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see other identifying documents, such as a driver's license. If, for any reason, you are unable to provide the information necessary to verify your identity, you are not permitted to access or use the Services. Please ensure that you only send us an image of yourself. Do not include any images of others.

Automatically-collected data

We, and our third-party partners, collect certain Personal Information automatically when you visit our online services, read our e-mails, access or use our Services, or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and other technology (collectively, "Tracking Technologies").

We, and our third-party partners, use these Tracking Technologies and other tools to automatically collect usage and device information, such as:

Do Not Track Signals. We are unable to respond to Do Not Track signals set by your browser at this time. If you would prefer not to accept cookies, most browsers will allow you to (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies and these browser settings that block cookies may have no effect on such techniques. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about - including how to manage privacy and storage settings for Flash cookies - on Adobe's website. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.

Information we get from third parties

We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.

How we use your information:

To provide the Services, we may use your Personal Information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

For internal business purposes, we may use Personal Information for its internal business purposes, including to:

For marketing purposes, we may analyze and use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include:

Non-personal Information

We may also use non-personally identifiable information that does not personally identify you, including by aggregating and/or de-identifying Personal Information, in order to understand better how our visitors use the Services, research our visitors' demographics, interests, and behavior, improve the Services, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use non-personally identifiable information in any manner permitted by law. When any non-personally identifiable information is combined with other information that identifies you, it will be treated as Personal Information in accordance with this Privacy Policy.

Sharing of your Personal Information:

We may share your Personal Information in the instances described below.

Third party tracking and online advertising:

We may participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history or other information. We may share or we may permit third-party services to collect information about your use of our website over time so that they may play or display ads on our website, online platform or in connection with our Service, on other devices you may use, and on other websites, apps, or services. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.

We may use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We may share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

Please review the section title 'Your choices' below to understanding your choices regarding third party tacking and online advertising.

How long we keep your information:

We will retain your information for as long as you use our Services, to resolve disputes, establish legal defenses, conduct audits, enforce our agreements, comply with applicable laws or as long as we otherwise deem appropriate. We also maintain your Personal Information as part of our standard backup procedures.

Links to Other's Sites and Services:

Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them, we do not endorse, approve or make any representations about third-party websites or domains. We encourage you to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and you visit them at your own risk.

Social Media:

Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.

How we store and protect your Personal Information:

Data storage and transfer: Your information collected through our Service may be stored and processed in the United States or any other country in which Company or its parent, subsidiaries, affiliates, or service providers maintain facilities or otherwise stores information. If you are located in other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. In addition, information collected about you may be stored on the block chain or using cloud-based services. Information recorded on the block chain or information stored in the cloud may be maintained by third-party networks in locations in which such third-party networks operate or maintain data storage or processing facilities.

Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Your choices:

If you no longer want to receive email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. You will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding us and you will not be able to opt out of those communications (e.g., communications regarding updates to our Privacy Policy).

We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.

Cookies and Flash cookies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.

Blocking or deleting cookies may negatively impact your experience using the Service, as some features and services on our Service may not work properly.

Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe's website. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.

Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative's online resources at http://www.networkadvertising.org/choices and/or the DAA's resources at www.aboutads.info/choices.

Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI's and DAA's online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android). You may also be able to opt-out of some - but not all - interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Changes to this Privacy Policy

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically. When we change the policy in a material manner, we will let you know and update the 'last updated' date at the top of this page. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this Privacy Policy means that you are consenting to the changes.

Other Rights and Important Information:

Children's Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, please let us know by contacting us at privacy@getcogni.com. If we learn that we have collected any personal information from children under 13, we will use commercially-reasonable efforts to delete such information.

California "Shine the Light" Law

If you are a user of the Services and a California resident, California's "Shine the Light" law (California Civil Code §1798.83) permits you to request and obtain from us once a year, free of charge, information regarding our disclosure of your personal information (if any) to third parties for direct marketing purposes. If this law applies to you and you would like to make such a request, please submit your request in writing in compliance with the below section (Contact Us).

Contact Us:

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@getcogni.com

California Privacy Notice

Last Updated: [November 6, 2019]

Scope of Disclosures

This California Privacy Notice (the "CA Disclosures") supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California ("consumers" or "you").

These CA Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined the CCPA.

Personal Information Disclosures

When we use the term "personal information" in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these Disclosures, personal information does not include:

Collection and Use of Personal Information

We collect various categories of Personal Information in connection with our Services. Please review the Privacy Policy, including the 'Information we collect' section, to learn more about the personal information we collect.

In the last 12 months, we have collected the following categories of personal information:

Category of Personal Information CollectedCollectedCategories of Sources
Identifiers, such as your name, address, phone number, email address, date of birth or other similar identifiers.
  • Directly from you
  • Your browser or device
California Customer Records (Cal. Civ. Code § 1798.80(e))
  • Directly from you
  • Your browser or device
Protected Classification Characteristics
Commercial Information
Biometric Information
Internet/Network Information
  • Your browser or device
Geolocation Data
  • Your browser
Sensory Information
Profession/Employment Information
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
Other Personal Information
Inferences

Purposes for Collecting Personal Information

We collect personal information from and about you for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to 'How we use your information' and 'The information we collect' in our Privacy Statement.

Disclosure of Personal Information and Recipients of Personal Information

We do not sell personal information and will not sell personal information unless we provide proper notice to consumers and, in the case of personal information collected prior to that notice, we obtain explicit consent for the sale of personal information relating to those individuals we previously interacted with.

As described in our Privacy Policy, we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;

  • The categories of personal information we have collected about you;

  • The categories of sources of the personal information;

  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and

  • The business or commercial purposes for collecting or selling the personal information.

The Right to Request Deletion

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

How to Exercise Your California Consumer Rights

To exercise your Right to Know and/or your Right to Deletion, please submit a request by:

We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To Exercise Your Right to Opt Out of Personal Information Sales

Unless you have exercised your Right to Opt Out of Personal Information Sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@getcogni.com.

At this time, we do not sell your Personal Information.

Minors Under Age 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at [insert email] to inform us if you, or your minor child, are under the age of 16.

Authorized Agent

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@getcogni.com.

Alternatively, inquiries may be addressed to:

Cogni, Inc.
175 Varick Street,
New York, New York 10014

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