Last updated 28 July 2020
Just to be clear, when we refer to Cognician, we mean Cognician Software (Pty) Ltd (whose principal place of business is at Office 4, Kings Cross, 9 Queens Park Avenue, Salt River, 7925, South Africa), including its associated and subsidiary company, Cognician, Inc. (whose principal place of business is at Suite 1628, 535 Mission St, San Francisco, CA 94105, USA).
Looking after your personal data is a huge responsibility for us. We will continue to do our best to protect your personal data as best we can and be transparent about what data we collect and why we collect it.
We do not, and will never, engage in practices such as benefiting from selling your personal information to third parties.
A Look at the Use of Your Personal Data
We need to collect your personal data when you interact with certain components of our website and platform in order for us to deliver certain services or products to you. This will only take place on the basis of your full consent.
We Collect Your Personal Data for Very Specific Purposes
We Collect Both Personal and Non-Personal Data
Our Data Protection Officer
We have appointed a Data Protection Officer (DPO) in compliance with the GDPR. The DPO is formally responsible for data protection and ensuring compliance with GDPR requirements. You can reach our company DPO at email@example.com.
Keeping Your Data Secure
We do our best to secure your personal data and to protect your information from unauthorized access, alteration, disclosure, or destruction. While handling your personal data, we ensure that the appropriate security measures are in place and international standards are followed to protect the security of your personal data when transferred or when stored.
It Is Important to Take Note of Your Rights
If you are a resident of the EEA or the UK, you have the following data protection rights:
To object to our processing of your personal data or to exercise any of your rights, you can simply submit a request to our Data Protection Officer at firstname.lastname@example.org.
The personal data we collect might be disclosed to the following third parties:
Subsidiaries, Affiliates, and/or Trusted Partners
We will not transfer your personal data to organizations, states, or countries that do not have adequate data protection measures in place. To facilitate our global operations, we transfer information to either Ireland or the United States and allow access to that information from countries in which the Cognician-affiliated entities have operations for the purposes described in this policy.
Certain recipients (sub-processors) (i.e., our suppliers who process your personal data on our behalf) may also transfer personal data outside the country in which you are a resident. Where such transfers occur, we will protect your personal data when it is transferred outside of the EEA, the UK, or Switzerland by processing it in a territory which the European Commission has determined provides an adequate level of protection for personal data, or otherwise ensuring appropriate safeguards are in place to protect your personal data.
Legal Mechanism for Transfers
For transfers of your personal data to recipients (sub-processors) who are located outside of the EEA, the UK, or Switzerland, we will rely on EU-US Privacy Shield, Swiss-EU Privacy Shield, or European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.
Requirements for Sub-Processor Engagement
When engaging any sub-processor, we will:
EU-US Privacy Shield
In compliance with the Privacy Shield Principles, Cognician commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Protection Officer at email@example.com.
Cognician has further committed to cooperate with the panel established by the EU data protection authorities with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
In general, we retain your personal information as needed to fulfill the purposes for which it was collected, i.e., we will process and store your personal data as necessary in order to fulfill our business requirements and contractual or legal obligations.
Cookies are small text files that are stored in the web browser on your device by websites you visit. They enable a website to ‘remember’ information about your activity as a user and also serve a number of purposes, like storing your preferences and simplifying navigation and login functionality.
A Note on Web Analytics
We implement Google Analytics features that use Display Advertising information for Google Analytics Demographics and Interest Reporting. We collect information about how you interact with our platform and services on our website. You can opt out of Google Analytics for Display Advertising to prevent your data from being used by Google Analytics by going to the Google Analytics opt-out page.
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