PRIVACY STATEMENT
Overview
AutoCognita US LLC, a Washington limited liability company (“AutoCognita,” “Company,” “we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Statement.
This Privacy Statement applies to our websites and application and describes how and why we collect information from you or about you through any website owned and operated by AutoCognita, including https://autocognita.com, any other websites, pages, features, applications, or content we own or operate (collectively our “Website”), how we might use or disclose this information and how you may update or delete certain information about you from our system.
Please read this Privacy Statement carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our services or Website. By accessing or using our services and this Website, you agree to this Privacy Statement. This Privacy Statement may change from time to time. Your continued use of this Website or our services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Statement periodically for updates.
AutoCognita respects all data subject rights to privacy and complies with all applicable data protection laws and regulations.
Definitions
“Personal data” means any information that relates to an identified or identifiable living individual.
Any references in this Privacy Statement to “you” or “your” should be interpreted in the context in which the information is processed.
“Aggregate Information” means information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.
“De-identified Information” information that has been stripped of your personal identifying information (e.g., your name and contact information) such that you cannot reasonably be identified as an individual.
“Service” or “Services” means AutoCognita’s products, applications, software, portals, services, and Website (including but not limited to text, graphics, images, and other material and information) as accessed from time to time by the user, regardless of whether the use is in connection with an account or not.
Personal Data Collection
We collect several types of information from and about users of our Website and Services, including the following categories of information and as explained more fully in this Privacy Statement:
• By which you may be personally identified, such as e-mail address, payment information, or telephone number;
• Any user content you create and provide to us; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information and personal data:
• that you provide to us directly;
• automatically as you navigate through the Website (information collected automatically may include information provided by your browser or device when you visit our website, usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies);
• through the portals connected to our site (as described below); and
• From third parties that may include business partners and affiliates.
We will collect personal data from you so that we can provide you with the services you require. If you do not provide certain information, we may not be able to fulfill your requests.
Personal Data Collected via Applications We Build for Clients
We will collect your e-mail address if you log in to the application as a user who is not connected to a class, or as a teacher.
We will not collect any personal data for students who log in to the application and are connected to a class.
Personal Data Collected via Our Website Portals
REGISTER AN ACCOUNT
We collect personal data when you register an account to access user account-only portals, including your personal data such as e-mail address, payment information, and telephone number.
We may also collect additional personal data that you submit via these portals or about your interactions with the portals. In some circumstances, a portal may be provided or supported by one of our support vendors, which may provide us with additional personal data related to your use of the portal.
PAY ONLINE
If you submit payment for services, we will ask you to provide your name and billing information, including credit card number and expiration date, first and last name, address, city, state, postal code, email, and phone and fax numbers.
Personal Data from Your Communications with Us
When you request information about our Services, request technical or customer support, register for updates from AutoCognita, or otherwise communicate with us, we may collect your first and last name, e-mail address, and phone number. When registering for updates, you may also choose to provide your company and/or practice name, phone number and postal code, but this information is optional. We collect this information for the purpose of providing you with periodic updates regarding new product offerings, clinical research and product or company updates.
Personal Data Collected via Web-Based Technologies
BROWSER OR DEVICE INFORMATION
When you use the Website, we automatically receive certain information provided by the interaction of your mobile phone or web browser and the Website. This information includes your internet website provider name, web browser type, type of mobile device (if applicable), and computer operating system. Such information is collected in anonymous, aggregate form (Aggregate Information) and is typically not considered personal data.
We also collect information on computer operating system, your IP address, the web browser, and information about the Websites visited before accessing the Website.
COOKIES AND WEB BEACONS
We use first- and third-party cookies and web beacons to personalize the content that you see on our Website, analyze our web traffic, and improve your experience while visiting the Website. Most web browsers can be set to disable the use of cookies.
1. A cookie is a small piece of data stored on your computer or mobile device by your web browser and is often used to make websites work, as well as provide website traffic and browsing related information to the website operator.
2. First-Party Cookies are cookies set by our Website, i.e. the website displayed in your URL window.
3. Third-Party Cookies: Some content or applications on our website are served by third parties, including content providers and application providers. Our third-party partners may use cookies alone or in conjunction with web beacons or other tracking technologies already in your browser to collect information about you when you visit our website. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services. Third-party cookies and web technologies are controlled by our advertising partners and not subject to this Privacy Statement. If you have any questions about the practices of such third party, you should contact the responsible third-party directly.
Communications you receive from us, as well as pages of our website, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that enable us to analyze email and website statistics, including visits and click-through rates. The web beacons only collect Aggregate Information and cannot be traced back to you individually.
When you first visit our Website, you will be asked to consent to our use of cookies, and you can withhold, withdraw, or change your consent at any time.
You can refuse the use of cookies by changing the settings on your browser or by clicking on the cookies consent mechanism. However, if you block certain cookies such as strictly necessary cookies for the functioning of our website you may not be able to access all or parts of our website.
Personal Data Use
How we use your information and personal data collected about your or that you provide to us as explained in this Privacy Statement will depend on how you interact with our Website and User Portal and the personal data you have shared with us. We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, for research, and to market our products and Services, as described below.
TO PROVIDE YOU WITH SERVICES
We use the personal data and information collected as described in this Privacy Statement to operate, provide, analyze, and improve our services. These activities may include, among other things, using your information in a manner consistent with this Privacy Statement to:
• Open your account, enable purchases, and process payments;
• Communicate with you and implement your requests;
• Contact you about your account and any relevant information about our services;
• Enforce our Terms of Service and other agreements;
• Monitor, detect, investigate and prevent prohibited or illegal behavior on our Website and in connection with our services, to combat spam and other security risks; and
• Perform research and development activities.
RESPOND TO YOUR REQUESTS AND PROVIDE CUSTOMER SUPPORT
We use your personal data to respond to your requests, including communications, requests for updates, bill payment, and supply orders.
RESEARCH
We will never use your personal information to conduct research without your consent. We may use your personal information to determine your eligibility for research, and/or to contact you to seek your consent to use or share your personal information for research. You will not be paid for this use.
ENHANCE WEBSITE AND USER EXPERIENCE
We use the information regarding the use of our website to analyze and administer the site and track user movement for web analytics purposes. This website usage information enables us to provide you with an ever-improving site, service, and general offering. Except where you have provided consent for us to use your identifiable personal data for our analytics research, we only use Aggregate Information.
MANAGE ACCOUNT
If you have created an account, we will use your personal data to administer your account and allow you to access and use the appropriate website portals. If necessary, we will also use your personal data to verify your identity and provide you with access to your account should you become locked out or forget your login and password.
CONDUCT MARKETING AND ADVERTISING
If you request to be updated about our products, services, company news, or other information, we will use the contact information you provided to send you the requested information, to provide you with marketing communications, and to keep you informed about product updates, events, webinars, or other materials.
TO CREATE DE-IDENTIFIED AND/OR AGGREGATE INFORMATION
We may use your personal data to create de-identified and/or aggregate information, such as demographic information, information about the effectiveness of our services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, publications, making de-identified and/or aggregated information available to third parties, and any other legally permissible purposes.
MEET LEGAL AND REGULATORY OBLIGATION
In certain circumstances, we use your personal data if we are required to by law or legal proceeding. We will only share the information we are required to disclose by law and only when we are required to do so, including to meet national security or law enforcement requirements.
SECURITY AND FRAUD PREVENTION
When necessary, we will use your personal data to preserve the security of our website, systems, and personal data in our control. If necessary, we will also use your personal data to investigate possible fraud, to identify violations of this Privacy Statement and our Terms of Service, and to prevent any attempted harm to you and our services.
Personal Data Sharing and Disclosure
We disclose your personal data to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
DISCLOSURES TO PROVIDE OUR SERVICES
• BUSINESS PARTNERS: We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
• SUPPORT VENDORS: When necessary, we share your data with third-party vendors working on our behalf to provide specific business support services, including payment processing, website hosting and management, and career applications. Such third-party vendors will only receive information necessary to provide the respective services and will be bound by confidentiality agreements limiting the use of such information.
• AFFILIATES: We may share your personal information with our company affiliates.
• WEBSITE ANALYTICS COMPANIES: We share Aggregate Information regarding visitors to our website with third-party website analytics companies. These companies use this Aggregate Information to provide us with insight regarding our web usage patterns. As we only share Aggregate Information, this information cannot be traced back to you individually by either us or the website analytics vendors. We use Google Analytics to provide us website usage and analytic reports, which necessitates us sharing your Aggregate Information. You may choose not to share your data with Google by installing the Google Analytics opt-out browser add-on, which instructs your browser not to provide your website usage data to Google Analytics. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout to install the browser add-on. Please note that installing the Google Analytics opt-out browser add-on will only disable the use of Google Analytics and will not prevent data from being sent to the website itself or to other web analytics services.
LEGAL REQUIREMENTS
We may be legally required to disclose your personal data, if such disclosure is:
• required by subpoena, law, or other legal process;
• necessary to assist law enforcement officials or government enforcement agencies; and/or
• necessary to protect us from legal action or claims from third parties including you and/or other Members.
SECURITY AND FRAUD PREVENTION EFFORTS
When necessary, we will share your personal data to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or suspected violations of this Privacy Statement, our agreements or arrangements with you or other policies in effect from time to time to which you are subject, or as otherwise required by law.
SALE OF BUSINESS
We reserve the right to transfer your personal information in the event we sell or transfer all or a portion of our business or its assets to which your personal data relates. Should this event occur, we will let you know.
Your Choices and Rights
YOUR PRIVACY CHOICES
The privacy choices you may have about your personal information are determined by applicable law and are described below.
• Email Communications: If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails and/or you may send us a return email asking to be omitted from future email distributions. Please note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Statement).
• Text Messages and Phone Calls. If you receive an unwanted text message and/or phone calls from us, you may opt out of receiving future text messages and/or phone calls from us by following the instructions in the text message and/or phone call you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
• Tracking Technologies and Advertising: you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. We do not control third parties’ collections or use of you information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
YOUR PRIVACY RIGHTS
Your rights in relation to your personal data are:
• The right of access: you have the right to request a copy of your personal data
• The right to rectification: you have the right to have inaccurate, incomplete or obsolete data rectified
• The right to erasure: you have the right to ask for your personal data to be deleted in situations set forth by applicable laws
• The right to restrict processing: you have the right to request the restriction of processing of your personal data under certain circumstances
• The right to data portability: you have the right to request a copy of your personal data in a machine-readable format
• The right to object: you have the right to object to the processing of your personal data
• Rights in relation to automated decision making and profiling: you have the right to request human intervention on automated decisions
• The right to withdraw your consent where the collection and processing of your personal data is based on your consent
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below or as otherwise instructed in any additional privacy notices provided at the time we collect your personal data. We will process such requests in accordance with applicable laws.
COMPLAINT AND CONCERNS
We value your concerns and would like to have to opportunity to address them first. Please contact us at support@autocognita.com. You shall have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes data protection laws.
Children Under the Age of 18
AutoCognita is committed to protecting the privacy of children as well as adults. A parent or guardian may collect a sample from, create an account for, and provide information related to, his or her child who is under the age of 18. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to AutoCognita about his or her child is kept secure and that the information submitted is accurate.
If you believe your child is providing or has submitted personal data to AutoCognita and you wish to remove any personal data about your child, please contact our Data Protection Officer at the address provided in the "Contact Information" section below. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.
California Privacy Rights
If you are a resident of the State of California and you have provided your personal data to us, you have the right to request a list of all third parties to which we have disclosed your personal data for direct marketing purposes. If you exercise your right to submit such a request to us, we will send you the following information:
• The categories of information we have disclosed to any third party for any third party's direct marketing purposes during the preceding year; and
• The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
• You may make such a request by contacting us at the address provided at the end of this Privacy Statement under the heading "Contact Information."
If you are a California resident and would like a copy of this Privacy Statement, please submit a written request to:
California law also requires that we disclose how we respond to "do-not-track requests" from our users. At this time, we do not currently respond to "do-not-track" requests from our users' browsers.
Under California Civil Code Section 1789.3, California users are entitled to the following specific consumer rights notice: If you have a question or complaint regarding our Website, please send an email to support@autocognita.com. You may also contact us by writing to:
AutoCognita
1050 Larrabee Ave #104 PMB 304
Bellingham, WA 98225
ATTN: Support
Students may reach the Consumer Information Center of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N-112, Sacramento, California 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
Other Important Information
THIRD-PARTY WEBSITES
The website may contain links to other websites that are not under our direct control. This Privacy Statement applies only to our websites and not to any third-party websites, which may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. You access such linked websites at your own risk.
You should check the privacy policies, if any, of those individual websites to see how the operators of those third-party websites will utilize your personal information. In addition, these websites may contain a link to websites of our affiliates. The websites of our affiliates are not subject to this Privacy Statement, and you should check their individual privacy policies to see how the operators of such websites will use your personal information.
SECURITY
We take steps to ensure that your information is treated securely and in accordance with this Privacy Statement. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
DATA RETENTION
We store the personal data we collect as described in this Privacy Statement for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
PRIVACY STATEMENT CHANGES
We reserve the right to modify this Privacy Statement at any time. You can find the most current version of our Privacy Statement at any time by clicking on the "Privacy Statement" link at the bottom of our website. If we make material changes to this Privacy Statement, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. Any changes we make to our Privacy Statement are effective as of this Last Updated date and replace any prior privacy statement.
CONTACT
To ask questions or comment about this Privacy Statement and our privacy practices, or submit a complaint, please contact us at:
AutoCognita
1050 Larrabee Ave #104 PMB 304
Bellingham, WA 98225
ATTN: Support