Privacy Policy of Cognits ("Website")

Cognits and Data Controller

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

1. 'Personal Data' means any details about you, from which your identity is apparent or can be uncovered. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services, or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information. If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you, our Services. Any information you provide to us that is not required is voluntary.
2. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Cognits.
3. Any use of Cookies – or of other tracking tools – by this Website or by the Cognits of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
4. Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Cognits.
5. Generally, we will not collect sensitive information about you unless we are required to do so by law or unless you provide consent. Sensitive information includes information about your race or ethnicity, political opinions, religious beliefs, criminal record, sexual information, and health or biometric information.

How Your Personal Data is Used

Our primary purpose in requesting Personal Data is to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Data in the following ways

1. To maintain legal and regulatory compliance.
2. To enforce our terms in our user agreement.
3. To provide customer service when you contact us to resolve any questions, or disputes, collect fees, or to troubleshoot problems.
4. To ensure quality control.
5. To enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations.
6. To enhance your experience.

Mode and Place of Processing The Data

Cognits takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Cognits, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Cognits. The updated list of these parties may be requested from the Cognits at any time.

Legal Basis of Processing

The Cognits may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations, the Cognits may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• Processing is necessary for compliance with a legal obligation to which the Cognits is subject; In any case, the Cognits 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.

Place

The Data is processed at the Cognits' operating offices are located.

Information We Collect From You Automatically

To the extent permitted under the applicable law, we may collect certain types of information automatically (“Usage Date”), such as whenever you interact with or use the Website. This information helps us address customer support issues, improve the performance of our Website, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. The Usage Data will be stored in a cloud-based solution, such as __ and the servers will be hosted in the state _.

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore: Personal Data collected for the purposes of the Cognits’ legitimate interests shall be retained for up to 1 year to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Cognits within the relevant sections of this document or by contacting the Cognits.

The Cognits may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Cognits may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

The Purposes of Processing

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed Information on The Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Google Analytics (Google LLC). Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

• Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This service is used for:

  • Displaying content from external platform: This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
  • Analytics: The services contained in this section enable the Cognits to monitor and analyze web traffic and can be used to keep track of User behavior.
  • Tag Management: This type of service helps the Cognits to manage the tags or scripts needed on this Website in a centralized fashion.

We are not responsible, liable, or subject to claims based on the practices and policies of this provider.

Limitation of Liability

Third parties may advertise on our application or it may contain links to other sites not operated by us. In doing so, those parties, their agents, or other companies working for them may use technology that automatically collects your IP address when they send an advertisement that appears on our site to your browser. They may also use other technology such as cookies or JavaScript to personalize the content of and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this Privacy Policy does not cover the information practices of these third parties.

Legal Basis of Using Personal Data

We can sell disclose, collect reveal, trade, or rent your Personal Data to others inside or outside of your jurisdiction. We can do such actions if one of te following applies:

• Users have given their consent by submitting a form on our website.
• Provision of Data is necessary for the performance of the service.
• We need to verify your identity, or we need to detect and prevent fraud.
• We need to share it with other companies in the event of a corporate sale, merger, reorganization, dissolution, or similar event;
• Regulatory bodies, government agencies, or law enforcement bodies request that Personal Data or processing is necessary for compliance with a legal obligation to which COGNITS is subject.

The Rights of Users

Users may exercise certain rights regarding their Data processed by Cognits.

In particular, Users have the right to do the following:

Rights of Users	Description	Guaranteed by Cognits
Withdraw your consent at any time	Users have the right to withdraw consent where they have previously given their consent to the storing of their Personal Data.
Access your Personal Data	Users have the right to learn if their Personal Data is being stored or processed by COGNITS and obtain a copy of the Personal Data undergoing storage or processing (if applicable).
Verify and seek rectification	Users have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.
Restrict the storage or processing of your Personal Data	Users have the right, under certain circumstances, to restrict the storing of their Personal Data.
Have your Personal Data deleted or otherwise removed	Users have the right, under certain circumstances, to obtain the erasure of their Personal Data from COGNITS.

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Cognits through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Cognits as early as possible and always within one month.

Information Not Contained in This Policy

More details concerning the collection or processing of Personal Data may be requested from the Cognits at any time. Please see the contact information at the beginning of this document.

Changes to This Privacy

The Cognits reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Cognits. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User's consent, the Cognits shall collect new consent from the User, where required.

Definitions and Legal References

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Controller (Or Cognits)

___, entity that determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is Cognits.

Website.

This Website

This means www.cognits.co which the Personal Data of the User is collected and processed.

Cookies

Small sets of data stored in the User's device.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include: (i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.