We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at email@example.com
If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected when you visit our website https://cognitivemill.com (the "Website")
What information do we collect?
Personal information you disclose to us
We collect email addresses as contact and other similar information.
Information automatically collected
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
- Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
How do we use your information?
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
Will your information be shared with anyone?
We may process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers. We may share or transfer your 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.
How long do we keep your information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
How do we keep your information safe?
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
Do we collect information from minors?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website.
If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org
What are your privacy rights?
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the CONTACT DETAILS provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you would at any time like to review in your account or terminate your account, you can:
If you have questions or comments about your privacy rights, you may email us at email@example.com.
- Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit https://www.aboutads.info/choices/.
- Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
- Contact us using the contact information provided.
Controls for do not track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Do eu residents have specific privacy rights?
The GDPR (General Data Protection Regulation) is an important piece of legislation that is designed to strengthen and unify data protection laws for all individuals within the European Union.
If your company needs to ensure it is GDPR-compliant, it also needs to ensure its providers (i.e. Cognitivemill) are also GDPR compliant. Cognitivemill is GDPR-compliant, and strictly enforces the regulation as to protect the user data we store.
GDPR Privacy Notice
Types of Data collected
If you are a Visitor, User or Business Partner, we may collect one or both of the following types of data from you when you use or access our website, the Services or when you interact with the Technology, as applicable.
The first type of data is aggregated, non-personal, non-identifiable information pertaining to your use of the website or interaction with the Technology (“Non-personal Data “). We are not aware of the identity of the individual from which the Non-personal Data is collected. Non-Personal Data may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preferences, access times and the website’s domain name from which you accessed the Services, etc.), in order to enhance the functionality of the Services and for security and functionality purposes.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data“).
For the avoidance of doubt, if we combine Personal Data with Non-personal Data, the combined data will be treated as Personal Data as long as the data types remain combined. We act as a Processor of a User's Personal Data that we process on behalf of our Business Partners. We are considered to be the Controller of the Personal Data we collect from our Business Partners and Visitors.
The types of data that we collect as well as our reasons for processing such data are specified in the tables below:
Data We Collect from Business Partners and Visitors
|Type of Data||How do we Use it|
|Data Provided Voluntarily: If you voluntarily contact us in any manner, whether via our contact form on our website, request a demo, via email, etc., you may be asked to provide us with your contact information such as your full name and email address as well as your Company name and job title.||We will use this data solely for the purpose of responding to your inquiries and to provide you with the support or information you requested. We will retain our correspondence with you for as long as we find necessary, subject to applicable law.|
|Newsletter & Marketing List Subscription: If you voluntarily subscribe to our newsletter through our website, or otherwise agree to receive our updates and content, you may be requested to provide us with your contact information such as your name, email address and company name. You can unsubscribe at any time using the unsubscribe option within the body of the applicable email correspondence or by contacting us directly.||We use this data solely in order to provide you with the content that you requested to receive. We use Sendgrid byb Twilio for its email marketing services. Please review their privacy policies here: https://www.twilio.com/en-us/legal/data-protection-addendum|
|IP and Technical Data: When you access our website or interact with our Services, we may collect certain online identifiers (e.g. your IP address) as well as technical Non-Personal Data (e.g. the type of operating system, type of browser, device type, access time and date, directing URL and your approximate geographical location).||We use this data for our legitimate interests of: (i) operating, providing, maintaining, protecting, managing, customizing and improving our website and the way in which we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; and (iv) protecting the security of our website. We will obtain your consent, if we are required to do so in accordance with applicable law when we use third party cookies on our website.|
Data We Collect from Users:
|Type of Data||Purpose of Processing|
|Online Identifiers & Technical Usage Personal Data: The Company may collect information regarding a User's interaction with the Services. Such information may include Online Identifiers such as the User's IP address, Advertising ID and IDFA. We may also assign a unique ID to your browser. The Company may also collect technical Data, such as, the type of operating system used, the type of browser, device type, access time and date, certain browsing data (e.g. directing URL) and the User's approximate geographical location.||We use this data for (i) operating, providing, maintaining, protecting, managing, customizing and improving our Services and the way in which we offer them as well as. In some cases, to provide Users with personalized Ads; (ii) enhancing your experience; and (iii) auditing and tracking usage statistics and traffic flow as well as calculating payments related to the Services, we provide to Business Partners. Where required under applicable law, we will require our Business Partner to obtain your consent to collect such data and share it with us. Note that, we use Google Ad Manager to operate our advertising campaigns. Google may use and retain certain types of data subject to its policies. Additional information can be found here.|
How Cognitive Mill collects Data
Depending on the nature of your interaction with the website or the Services, the above mentioned data may be collected as follows:
- Voluntarily – In the event you choose to provide us with information, e.g., when you contact us or if you are a Business Partner and you choose to share other information with us via your use of the Services.
- Automatically – Your data may be collected automatically including via cookies (as explained below) and other similar tracking technologies. We will ask for your consent to collect Personal Data and offer you the choice to opt-out of such collection if we are required to do so in accordance with applicable law.
Who do we disclose Information to?
We do not share your Personal Data with third parties except as specifically mentioned herein:
- Third Party service providers – we may disclose your Personal Data to third parties that perform services on our behalf (e.g. tracking, servers, service functionality and support, marketing, etc.). These entities may be located in a different jurisdiction than you and are prohibited from using your Personal Data for any purposes other than providing us with the requested services;
Our third parties help us use your personal information, as described above, and include:
|SendGrid by Twilio||https://www.twilio.com/en-us/legal/data-protection-addendum|
|Government third parties, including government agencies, regulatory bodies and law enforcement agencies as required, authorized or permitted by law|
Third Party Rights – we may share your Personal Data, solely to the extent needed to prevent harm to the rights (including intellectual property rights and other legal rights), property or safety of us, our Visitors, Business Partners and their Users, yourself or any other third party.
Policy Enforcement – we may share your Personal Data, solely to the extent needed in order to enforce our policies including investigations of potential violations thereof, to establish or exercise our rights to defend against legal claims or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
Legal Requirement – we may disclose or share your Personal Data, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with a court injunction, etc.) or for the purpose of collaborating with law enforcement agencies; or
Affiliated Companies and Corporate Transaction – we may share your Personal Data with a parent company, subsidiaries, joint ventures, or other companies under common control with the Company ("Affiliated Companies") solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided however, that our Affiliated Companies or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data.
Your Individual Rights
- Right to be informed: we clearly inform our users about the use that will be made of their data
- Right of access: our users can access all their data, without restriction, from the Crisp apps
- Right of rectification: it's as simple as contacting us, we'll process all your rectification queries
- Right of erasure: it's as simple as contacting us, we'll process all your erasure queries
- Right to restrict processing: we don't process the data of our customers (and our customers end-users)
- Right to data portability: our users may contact us anytime if they wish to get an export of their data (this may take time, however, as the data is fragmented amongst multiple isolated data-stores)
- Right to object: we handle all requests on this matter from our users and users' end-users (contact us)
- Right not to be subject to automated decision-making including profiling: we don't do that (and never will)
Please review our Privacy Rights Policy to learn more.
Change in Control or Sale
We can also share your personal information as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your information, but only in the manner set out in this Policy unless you agree otherwise.
International transfers of personal information (for users in the Designated Countries)
For our users in the Designated Countries, where we transfer your personal information to a third party provider that is not located in the Designated Country and is not subject to an adequacy decision by the EU Commission, we will require those third party providers to enter into an agreement that provides appropriate safeguards for your information.
Our team closely monitors any unauthorized system access, and has put in place multiple preventive measures to reduce the attack surface on our systems and services.
We generally retain your personal information as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.
Data Protection Officer
Cognitivemill has a designated Data Protection Officer, as required by GDPR:
Do california residents have specific privacy rights?
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on theWebsite, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
- every individual who is in the State of California for other than a temporary or transitory purpose and
- every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
|A. Identifiers||Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name||YES|
|B. Personal information categories listed in the California Customer Records statute||Name, contact information, education, employment, employment history and financial information||NO|
|C. Protected classification characteristics under California or federal law||Gender and date of birth||NO|
|D. Commercial information||Transaction information, purchase history, financial details and payment information||NO|
|E. Biometric information||Fingerprints and voiceprints||NO|
|F. Internet or other similar network activity||Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements||NO|
|G. Geolocation data||Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements||NO|
|G. Geolocation data||Device location||NO|
|H. Audio, electronic, visual, thermal, olfactory, or similar information||Images and audio, video or call recordings created in connection with our business activities||NO|
|I. Professional or employment-related information||Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us||NO|
|J. Education Information||Student records and directory information||NO|
|K. Inferences drawn from other personal information||Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics||NO|
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at firstname.lastname@example.org go or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.
Cognitivemill.com has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Cognitivemill.com will not sell personal information in the future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- you may object to the processing of your personal data
- you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
- you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at support@Cognitivemill.com or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Do we make updates to this notice?
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
How can you contact us about this notice?
If you have questions or comments about this notice, you may email us at email@example.com or by post to:
1313 N. Market Street, Suite 5100, Wilmington, Delaware 19801
How can you review, update, or delete the data we collect from you?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please support@Cognitivemill.com