Cognni Privacy Policy for the Cognni Website, and Cognni Services

Last updated: Feb 2021

1. General

We value your interest in Cognni Ltd (“Cognni”) and its proprietary owned branded "Cognni" services. This privacy policy concerns personal data of the Cognni website (the "Website") users collected by Cognni and/or used during business related operation – online and offline. These interactions where we collect and/or use your data may include, without limitation, buying or using Cognni services or our customer support, including, but not limited to, visiting the Website, Cognni's social media channels and blogs.

Please keep in mind when reading this privacy policy that the Cognni services do not store content. Cognni provides a security service that tracks and protects content, but does not store the content itself. This privacy policy outlines how we protect metadata about your content and your interactions with the Cognni services.

2. Data Usage

2.1. Usage of Data Provided Directly by You.

Personal data that you share with Cognni may be used for the following purposes:

· Enabling the online purchase of Cognni services

· Enabling you to activate or register certain services or features, or enhance functionality

· Developing, operating, improving, delivering, maintaining and implementing our services' functionality (document tracking, access control, etc.)

· Providing you with information about Cognni services

· Storing your preferences for future interactions and communications from Cognni

· Resolving customer and/or service issues

· Enhancing the safety and security of our services

· Collecting and handling feedback

· Complying with applicable laws and regulations

· Enforcing our terms and conditions, this privacy policy, and other usage policies

· Protecting our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to allow us to pursue available remedies or limit any damages that we may sustain.

· Providing you with personalized messages, special offers and advertisements that are relevant to your personal interests, based on the information you have shared with us and on the information that we have collected through cookies or similar techniques regarding your use of the Cognni services and/or the Website/social media/blogs.

2.2. Usage of Data Provided by 3rd Parties.

While interacting with a business customer, supplier, or business partner on your behalf, we may request from them your personal data for purposes that include, but are not limited to:

· Implementing normal service functionality, e.g. document tracking, access control

· Customer relationship management

· Information access facilitation

· Communication improvements

· Customer interaction analysis

· Security programs integration or implementation

· Assisting us in our participation in certification programs

· Addressing your service-related requests, updating you about their status as well as answering your questions

· Sending you satisfaction surveys after your request is resolved or your question is answered

3. Data Collection - Types

3.1. Personal Data Collected in the Purchase Process

The purchase process involves communication with Cognni in which you might be asked for data that could be classified as " Personal Data". This data might be incorporated into the services and includes, but is not limited to, the following:

· Your name

· Your email address

· Your telephone number

· Details about services that you have purchased

· Financial/transaction information, such as credit card and payment information

3.2. Personal Data Collected via Social Media

None

3.3. Personal Data Collected via the Website

In addition, we may collect personal data via cookies or similar techniques, including, but not limited to:

· Your IP address

· Your cookie ID

· Device specific information such as your web browser, hardware model, operating system version, advertising identifiers, unique device identifiers and language preferences

· The advertisements you view or click through

· Electronic communications protocols

· Web pages visited on the Websit

· Your user preferences

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive. Like many sites, we use these cookies to collect information. When entering the Website, you will be requested to actively consent to the Website's usage of the cookies. You may decline the option to allow the Website to use these cookies, but if you do so, you may not be able to use some features of the Website.

3.4. Personal Data Collected Through Normal Use of Our Services

As part of normal use of the Cognni Services, in order to provide various functionalities such as document tracking, audit trail, access control and other features, certain personal data may be collected, stored, and shared with authorized users, including, but not limited to, email addresses, passwords, filenames, and audit trail information of file access including date/timestamps, the user that accesses a file, IP addresses of the user, file forwarding activity, and changes to the file security profile. However, Cognni never stores the content of the files themselves – we only store information about the policies surrounding what users can do with those files. When such information is collected, we are acting on behalf of customers who have subscribed to our services and it is the customer, not Cognni, that sets the policies surrounding how other users can access, process and use those files. If you do not want this information about your use of files to be collected, please contact the customer directly.

For a complete list of fields and activities please see the section on privacy and personal data of the Cognni EULA / TOS.

3.5. Personal Data Collected via 3rd Parties

During the course of communications with Cognni on behalf of a supplier, business partner or customer, we may collect, without limitation:

Your name;

· Your email address

· Your telephone number

· Your IP address

· Name and address of the company you work for

4. Data Collection - Vectors

4.1. Collecting Data Directly From You

Cognni may collect personal data from you by through various means, including, but not limited to:

· Registering as a Cognni user

· Registering a purchase

· Your communications with Cognni can be product- or service-related, and may include the contents of your questions to us, or requests that you addressed to us

· Contact information collection forms throughout the Website, e.g., when downloading white papers and information sheets

· Communicating with one of our Cognni Customer Care representatives by email, phone or in writing

· Ordering a service

· Participating in social media activities related to a Cognni promotion, e.g., clicking "like" or "share"

· Asking to receive messages on your mobile phone/device

· Subscribing to a Cognni newsletter

· Sending us a completed reply card, included with your Cognni services

· Voluntarily participating in service testing or surveys

· When using Cognni connected services and/or apps, you may be asked whether you wish to share data with Cognni, e.g. sharing your contact, organizational, or location data

· Cookies placed on your computer or mobile device when you visit the website

· Social Listening: Cognni may search the Internet for relevant and publicly available content and use it to improve its services, resolve consumer issues and provide targeted marketing

4.2. Collecting Your Data via 3rd Parties

During the course of communications with Cognni on behalf of a supplier, business partner or a customer, we may collect your data through various means, including, but not limited to:

· Authentication process via 3rd-party systems, such as Microsoft OAuth or Google SSO

· Registering purchases

· Provision of services by or on behalf of Cognni

· Communications with Cognni

· Developing partnerships

· When accessing Cognni facilities or systems

· Participating in fairs, events or promotions

· Voluntarily participating in testing or surveys

Personal data may also reach us when we purchase another company of which you are a customer. If you do not want Cognni to use your personal data that has not been provided by you, you may let us know at any time by contacting Cognni directly at the following email: compliance@cognni.ai

5. Sharing Your Personal Data with Others

5.1. Circumstances

Cognni may share your personal data with service providers, business partners and other third parties, to the extent permitted by applicable law.

For example:

Cognni may disclose generic aggregated demographic information not linked to any personal identification information regarding visitors and users to business partners, trusted affiliates, and advertisers.

Cognni may sell you a service in a joint marketing activity with another company (business partner). The agreements with these business partners will limit the purposes for which your personal data can be used and disclosed and will require your personal data to be adequately safeguarded. We will inform you in the event that such a relationship exists and these companies’ identity before processing your data for such joint marketing efforts.

Cognni might disclose your data to other companies such as IT and communications service providers, testing companies, data management support partners and other parties bearing a necessary relationship for Cognni to provide its services.

While you interact with Cognni as a business customer, supplier or business partner, Cognni may disclose personal data available in reports and other materials provided by you and/or your company that conforms to an engagement with another business partner and/or a supplier.

In the event that Cognni sells a business or a part of a business to another company, such a transfer of ownership could include the transfer of your personal data directly related to the business of the purchasing company.

As we believe to be necessary or appropriate, we may disclose personal information: (a)as we are required to do under applicable laws, including laws outside your country of residence; (b) in order to comply with legal process; (c) in order to respond to requests from public and government authorities, including public and government authorities outside your country of residence, including national security or law enforcement requirements; (d) in order to enforce Cognni EULA / TOS and this privacy policy; (e) in order to protect our operations or those of any of our affiliates; (f) in order to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) in order to allow us to pursue available remedies or limit the damages that we may sustain.

Our services are controlled and operated by us from Israel and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than the State of Israel. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our services you consent to the transfer of information to countries outside of your country of residence, including Israel. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

5.2. Consent

In the event that we are required by law to obtain your consent, or when we think that your consent is appropriate in the circumstances, we will obtain your consent before we share your personal data.

5.3. Terms of Disclosure

Cognni will disclose personal data only in conformance with this privacy policy.

6. Exercising Your Rights

6.1. Access to personal data

Once you have given us your personal data, we will enable you to update, modify or, when legally possible, delete it (upon your written request). You can also withdraw the consent you have granted us to collect your personal data at any time, or request to be informed about your personal data at our possession. For these purposes, you can contact us at compliance@cognni.ai

Cognni has the right, but not the obligation, to retain and use such information stored in our databases and other information obtained from your current or previous interactions with our services for a reasonable period of time, not exceeding any legal requirements or limitations, to resolve disputes, troubleshoot problems and enforce Cognni’s rights and the terms and conditions of this privacy policy.

6.2. Opt-In/Out

Our commercial messages to you will include an opt-out option.

If you choose not to receive from us personalized offers or information, please inform us by selecting "opt-out" on emails or other messages you receive.

Where required by applicable law, we will ask you to "opt-in" or affirmatively consent to the processing of your personal data.

6.3. Right to File a Complaint

In any case your rights to privacy had been breached or materially altered by us, or in case our Terms and Conditions or this Privacy Policy violates applicable law, you can always file a complaint to the competent data protection regulator in Israel, being the Bureau of Privacy Protection of the Ministry of Justice.

7. Cloud

Cognni stores personal data in cloud servers located in sites around the world. Cognni takes the required measures to protect this data in and outside the cloud to ensure that it is used only for the purposes mentioned in this privacy policy. Any cloud service provider we use is required to uphold to the same standards of protection of your personal information as described in this privacy policy. Transmitting your personal information abroad requires your specific consent, such as under the Israeli Data Protection Regulations (Transferring Databases Outside the State Borders)-2001, then your specific consent is hereby provided.

8. Personal Data Protection

Cognni uses various procedures and technologies to protect your personal data. These are sensitive to the type of processed data and involve various techniques, including, but not limited to:

· Access controls

· Firewalls

· Secure servers

· Data encryption

For more detailed information about your personal data, including how and where it is stored and protected, please contact us at compliance@cognni.ai

Please keep in mind that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to or from our site is at your own risk. You should only access the Website and services within a secure environment.

9. Special Information for Parents

While the website and services are not intentionally targeted at children under the age of 16, it is Cognni's policy to comply with the law when it requires parent or guardian permission before children's information is collected, used or disclosed.

Cognni strongly recommends that parents take an active role in supervising the online activities of their children. If you believe we have collected personal data from a person who is under the age of 16, please contact us at compliance@cognni.ai

10. Privacy Policy Changes

Cognni reserves the right to update this privacy policy when required.

The revision will be noted on the privacy policy and becomes effective immediately.

In the event that you do not agree to the revision, you should update your preferences or stop using Cognni. Continuing to access Cognni pages or using its services after the changes become effective confirms that you agree to be bound by the revised privacy policy.

11. GDPR

Cognni adheres to the guidelines of GDPR that require privacy policies to be concise, transparent, intelligible, and easily accessible which are an important part of fair processing.

12. Contacting Cognni

If you have any concerns or questions you feel were not adequately addressed in this policy, or would like to find out more information about your personal data being handled by Cognni, please contact us at compliance@cognni.ai

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