Cogniss Privacy Policy

Effective Date: 27 August 2019

Cogniss (“Cogniss”, “we”, “us” or “our”) aims to empower people to live healthier and happier lives. We respect your privacy and are committed to being transparent about how we collect, use and share your personal information.

This policy applies to all Cogniss services, products, games and mobile applications (“Services”). It explains: 

  • What personal information we collect

  • How we use your information

  • How we share information

  • Your rights and choices

  • Our policies for children

  • How we protect information we collect

  • Other important privacy information 

By using our Services, you confirm you have agreed to the Terms of Use and have read and understood this Privacy Policy.

1. What personal information we collect 

Depending on how you engage with Cogniss Services, we collect different kinds of information from or about you.

Account and profile information

We collect information about you when you register for an account, create or modify your profile, set preferences, or signup for our Services. This includes your name, email address, password, and in some cases your date of birth and gender.

Information you provide to us

We collect and store any content that you create, post, send, and share to our Services. This content includes any comments you post, emails and other communications that you send to us, and information you provide by responding to surveys, submitting a form or participating in promotions. We also track how you engage with messages you receive in connection with our Services, such as notifications to complete a learning activity.

Your use of our Services 

When you access or use our Services, we collect and store certain usage data. This includes the types of content you view or engage with, the frequency and duration of your activities, the scores you achieve in games and your progression through content. 

Your networks and connections
We collect information about the people and groups you are connected to and how you interact with them, such as the people you communicate with the most, or the frequency and types of team challenges you engage in. 

Other users of our Services

Other users of our Services may provide information about you when they create or share content through our Services. For example, you may be mentioned by someone else on their newsfeed.

Websites and apps that use our Services
We collect information when you visit or use third-party websites and apps that use our Services. This includes information about the websites and apps you visit, your use of our Services on those websites and apps, as well as information the developer or publisher of the app or website provides to you or us.

Third-Party Services
If you use a Third-Party Service (such as Google or Facebook) to register for an account, the Third-Party Service may provide us with your Third-Party Service account information on your behalf, such as your name and email address. Your privacy settings on the Third-Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third-Party Service.

Cogniss App Partners

We may collect information about your interest in, and engagement with, our Services from Cogniss App Partners. Cogniss App Partners are individuals or organizations that build apps on the Cogniss platform. 

Device information
We collect information from or about the computers, phones, or other devices where you install or access our Services. We may associate the information we collect from your different devices, which helps us provide consistent services across your devices. Some examples of the device information we may collect include:

  • Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.

  • Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

  • Connection information such as the name of your mobile operator or ISP, browser type, language and timezone, mobile phone number and IP address. 


Payment information

Cogniss does not collect or process any information relating to payments. Purchases made in all Cogniss Services are processed through Apple’s App Store and Google Play. For details about what information is processed in relation to payments, please refer to Apple and Google’s own privacy policies, available at https://www.apple.com/legal/privacy/ and https://policies.google.com/privacy respectively.


Other

We constantly strive to improve our Services, and often introduce new features that may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

2. How we use your information

Our mission is to facilitate effective learning experiences that enrich people’s quality of life. We offer a platform on which developers, designers and others can imagine and create their own solutions to complex learning, health and behavioral challenges. 

With these objectives in mind, we use the personal information we collect about you to:

Provide and personalize our Services. We create and manage your account, and personalize our Services by using information about how you interact with them. For example, we may use your assessment results to provide you with customized insights to help you maintain or improve your learning. We may also use location information to incorporate location-specific challenges or help you locate relevant learning or wellness events near you.

Communicate with you. We communicate with you about our Services and let you know about any changes to our policies and terms. We also use your information to respond to your inquiries.

Improve our Services. We conduct surveys and research in order to test, evaluate, and improve existing products and services, or develop new ones. We may also conduct audits and troubleshooting activities.

Promote and advertise our Services. We may send you tailored marketing communications about products, services, and offers of Cogniss and our partners and measure the success of those campaigns. For example, we may promote a learning app to you based on what we think may interest you. We send these communications through email, notices posted on our websites or apps, and push notifications. You may opt out of receiving these notifications at any time by contacting us at privacy@cogniss.com

Promote safety and security. We help verify accounts and activities to promote safety and security on and off of our Services. This includes enforcing our Terms of Use and other legal terms and policies.

Aggregate insights. We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data to generate statistics about our users, or to publish demographics for a Service or learning and behavioral insights.


We process your personal information for the above purposes on the following grounds:

Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time by contacting us at privacy@cogniss.com.

Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you, like the Terms of Use.

Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

Legitimate interests. We have a legitimate interest in using your personal information in the following cases:

  • To operate the Cogniss business and provide you with tailored communications to assist you in better using Cogniss Services. This may include advertising; however, you may opt out of receiving advertising communications at any time by contacting us at privacy@cogniss.com or by following the unsubscribe instructions in any such communications. 

  • To analyze and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring Cogniss is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.

  • To provide and improve our Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.

  • To anonymize and subsequently use anonymized information.

Protecting you and others. To protect your vital interests, or those of others. 

Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our Cogniss App Partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness.  

3. How we share information

We share personal information in the following ways:

People you share and communicate with

Any content you share and communicate using our products and services will be visible to friends connected to you through the Cogniss social network. Any content you share on social networks or public forums outside of Cogniss will be made visible according to your settings on those respective platforms. In some cases, people you share and communicate with may download or re-share this content with others on and off our Services. 

People that see content others share about you

Other people may use our Services to share content about you with the audience they choose. If you have concerns with someone’s post, you can report them using the in-app reporting feature or by emailing us at contact@cogniss.com.

Apps, websites and third-party integrations on or using our products and services

When you use third-party apps, websites or other services that use, or are integrated with, our Services, they may receive information about what you post or share. Information collected by these apps, websites or integrated services is subject to their own terms and policies. 

Sharing with third-party partners and organizations

We occasionally work with third party companies who help us provide and improve our Services. For example, anonymized data (data with all user identifiable information removed) may be made available to research organizations for the purposes of conducting Cogniss-approved research. We do not share information that personally identifies you with advertising, measurement or analytics partners unless you give us permission, or if we have aggregated the information so that it does not personally identify you. 

Cogniss App Partners

We may share information with Cogniss App Partners that is specific only to their Cogniss app. Cogniss App Partners do not have access to data collected on other Cogniss apps. These partners may specify additional ways in which they will use and share your data. Cogniss App Partners must process data in a manner consistent with the rights and obligations outlined in this Privacy Policy and the agreements we enter into with them. 

4. Your rights and choices 

Data retention

We keep your personal data only as long as necessary to provide you with our Services and for legitimate and essential business purposes, including those described above.

Deleting your account

You can close your account at any time. When you close your account, you will no longer be able to access it. Things you have posted and accumulated, such as your status updates, personalized avatars, badges and achievements, will be removed and archived. Keep in mind information that others have shared about you is not part of your account and will not be removed when you close your account.

If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

  • If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;

  • Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,

  • Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it.

Rights to access and control your personal data

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.

For personal data that we have about you, you may choose to:

  • Delete Data: You can ask us to delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

  • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

  • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

  • Right to Access and/or Take Your Data: In most cases, you can access a copy of your personal data by inputting your unique access code into Cogniss Insights at http://insights.cogniss.com/. Alternatively, can ask us for a copy of your personal data.

You can access, update, change or delete personal information either directly in your account or by requesting us to do so at privacy@cogniss.com.


5. Our policies for children

We recognize the need to provide further privacy protections with respect to personal information we may collect from children when using the Services. The term "children" refers to individuals under 16 years of age. 

We are committed to protecting children from cyber bullying and stranger danger. In order to provide the best possible protection to children, Cogniss apps aimed at users under the age of 16 feature a ‘Kid Safe’ mode. Kid Safe mode only allows users to connect with other users known to them in the real world. Kid Safe mode removes free texting between users, restricting communications to the use of emoticons and pre-defined messages.

When we intend to collect personal information from children, we take additional steps to protect children's privacy, including:

  • Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online or app-based activity; and

  • Giving parents or legal guardians access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.

Parents who believe that their child has submitted personal information to us and would like to have it deleted can contact us at privacy@cogniss.com.


6. How we protect information we collect

While no service is completely secure, we are dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.

7. Other important privacy information

International data transfers

We operate internationally and may transfer your personal information to Australia and third parties in locations around the world for the purposes described in this Privacy Policy. Specifically, Cogniss uses certain vendors in providing our Services. All services either fully comply with GDPR regulations or are to implement it shortly.

Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard its privacy. If you have a complaint about our privacy compliance, please contact us at privacy@cogniss.com.   

Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a Cogniss account, irrespective of which country you live in. If you later wish to withdraw your consent, you can delete your Cogniss account as described in the ‘Your Rights and Choices’ section.

Changes to this policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our website. If we make material changes to it or the ways we process personal information, we will notify you before they take effect (by, for example, sending you an email and/or push notification).

We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit.  This will help ensure you better understand your relationship with us, including the ways we process your personal information.

How to contact Cogniss

If you have questions, comments or complaints about this Privacy Policy or would like to exercise your rights and choices, please email us at privacy@cogniss.com, contact us via our contact form at http://www.cogniss.com/contactus/, or write to us at the address below: 


5 Blackfriars Street
Chippendale NSW 2008
Australia