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Privacy Policy

COGENCY GLOBAL INC. (together with its subsidiaries, “COGENCY GLOBAL,” “we” or “us”) values our relationship with you and takes your privacy seriously. The purpose of this Privacy Notice is to identify how we may process, collect, store, share and use (collectively, “use”) the information that we collect from you in connection with your use of our business services or our website https://www.cogencyglobal.com (collectively, our “Services”). This Privacy Notice also identifies your rights with respect to your personal information, all as described in more detail below.

We may update or modify this Privacy Notice at any time, by posting the amended version on this site and including the effective date of the updated version. By accessing and/or using the Services, you accept and agree to the terms of this Privacy Notice and the use of your data and personal information as described in this Privacy Notice. If you do not agree to be bound by this Privacy Notice or any subsequent modifications, you should not access or use the Services or disclose any personal information through any of the Services.

This Privacy Notice was last updated January 1, 2020.

Your privacy and the security of your personal information is, and will always be, important to us. We want to transparently explain how and why we gather, store, share, and use your personal information, as well as outline the controls and choices you have around when and how you choose to share personal information. If we use your personal information, you will have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why we use your information and the jurisdiction in which you are located.

This Privacy Notice contains the following information, which you can access by scrolling down:

  1. How to contact us.
  2. The information we collect about you.
  3. How we may use your information.
  4. Who we may share your information with.
  5. Your rights and options regarding your personal information.
  6. How we safeguard your personal information.
  7. How long we store your personal information.
  8. Links.
  9. Children.
  10. Special notice to non-U.S. users regarding data transfers.
  11. Governing law and jurisdiction.

1. How to contact us.

How to contact us and update your communication preferences and/or information:

You can update your communication preferences and information by updating your contact information in your online profile or account, clicking the “Update your email preferences” link in emails you receive from us or contacting us at the email or postal address below.

Additionally, if you have any questions or concerns about our use of your personal information, please do not hesitate to contact us through any of the methods listed below.

Mail:

COGENCY GLOBAL INC.

Legal Department

122 East 42nd Street, 18th Floor

New York, New York 10168

Phone: +1-800-221-0102

Email: info@cogencyglobal.com

2. The information we collect about you.

Information we collect.

We obtain information about you and your use of our Services, to develop comprehensive statistics related to the use of our Services, to serve our customers better, and for other business-related purposes. The information we collect can include non-personally identifiable information or personal information as further described herein. Please note that if you fail to provide us the information identified herein, we may not be able to perform functions that would require our access to and use of such information.

Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We collect information through any correspondence that you provide to us whether through email, mail, phone calls, or through our Services. Information that you provide might include, but is not limited to, the following: (a) first and last names; (b) demographic information; (c) mailing address; (d) email address; (e) phone number; (f) credit card number; (g) job title; (h) company name; and (i) other information that personally identifies you.

We do not consider personal information to include information that can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

When and how do we collect your information?

We collect information from you both when you provide it voluntarily and also automatically when you use our Services. Most of the personal information we receive relates to Services that you have requested or content you have elected to receive.

In some instances, we automatically collect certain types of information when you use our Services or correspond with us. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons.

A “Cookie” is a small data file that is downloaded onto your computer or mobile device when you use our Services, used to tailor your use of our Services and your preferences, authenticate your access, and/or display relevant information. An “Anonymous Identifier” is a random string of characters that is used for similar reasons as Cookies. We may use Cookies and Anonymous Identifiers to become more familiar with you through the study of analytics.

Some portions of our Services require the use of Cookies for proper functioning. Anonymous Identifiers can be used where Cookie technology is not available. You may refuse to accept Cookies by activating the appropriate “do not track” setting on your web browser. These features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser or block or delete tracking Cookies, we, and our third-party providers, may continue collecting information about your online activities as described in this Privacy Notice. If you select this setting, you may be unable to access or use certain parts of our Services.

A “Web Beacon” is an object embedded into a web page or an email that collects various data. A Web Beacon functions similarly to a Cookie and can allow us to learn more about your behavior, actions, and preferences. For more information regarding your choices with respect to cookies and other tracking technologies, please see “Your Rights and Options Regarding Your Information” in Section 5 below.

For more information about the information we collect, read on below.

What information do we collect from you?

During the preceding 12 months, we have collected the following categories of personal information that are processed pursuant to the California Consumer Privacy Act (“CCPA”): (a) identifiers, such as your contact information and online account information; (b) Internet and electronic network activity information, including such information as your interactions with the Services and Social Media Platforms (defined below); (c) audio, electronic or visual information; (d) inferences about you, including about your preferences; (e) commercial information including records or products or Services purchased; (f) financial information and other information as described above that may be considered personal information under California Civil Code Section 1798.80; and (g) protected classifications under California or federal law.

For more information about the types of your personal information that we may use and how we use your personal information, see the detailed description below.

Information collected when you elect to receive content through our website (such as by signing up for our blog or email updates, to download articles, or requesting information related to our Services)

Categories of Information

Description of category

Content Registration Information        
This is the personal information that is provided by you or collected by us to enable you to sign up to receive content or information through our website. This may include your name, email address, address, job title and company, phone number, and any personal information that you choose to enter into a blank message box.

Categories of Information                                                                               Description of category

Services Registration Information

This is the personal information that is provided by you or collected by us to enable you to login and access your account and our Services. This may include your name, email address, address, job title, company, and phone number.

Some of the personal information we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal information in order to make your account more personalized.

Services Usage Information

This can be personal information and non-personal information that is collected about you when you are using our Services, and this may include:

o   Information about the Services you have elected.

o   Information about your interactions with our Services which includes the data and time of any information you enter into our Services, and your interactions with other users of our Services.

o   Technical data which may include URL information, Cookie data, Web Beacons, your IP address, the types of devices you are using to access or connect to our Services, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system. Further details about the technical data that is processed by us can be found below.

o  Information from your access or use of any of our pages on social media platforms, such as Facebook, Twitter, or LinkedIn (“Social Media Platforms”). We may receive aggregate information and analysis about your usage of our pages on such Social Media Platforms.

Anonymized Information

We use anonymized and aggregated information that may be created or derived from your personal information or usage of the Services for purposes that include data analysis, improving our Services, advertising, and developing new features and functionality within our Services.

3. How we may use your information.

We will only use your information for the purposes identified below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose described here. If we need to use your personal information for an unrelated purpose or if we change the basis on which we are processing your data, we will notify you and we will explain the legal basis which allows us to do so.

In the table below, we have set out the reasons why we process your information, the associated legal basis we rely upon to legally permit us to process your information, and the categories of information (identified in Section 2) used for these purposes:

 

Why COGENCY GLOBAL processes your information

Legal basis for the processing purpose

Categories of information used by COGENCY GLOBAL for the processing purpose

To provide, personalize, and improve your experience with our Services, for example by providing customized or localized content, recommendations, support, and features through our Services.
  • Performance of a contract
  • Legitimate business interest
  • Content Registration Information
  • Services Registration Information
  • Services Usage Information
  • Anonymized Information

To understand how you access and use our Services to ensure technical functionality of our Services, to prevent or investigate security breaches or other potentially prohibited activities, develop new products and services, and analyze your use of our Services, including your interactions with applications or services made available, linked to, or offered through our Services.

  • Performance of a contract
  • Legitimate business interest
  • Content Registration Information
  • Services Registration Information
  • Services Usage Information
  • Anonymized Information
To communicate with you for Services-related purposes.
  • Performance of a contract
  • Legitimate business interest
  • Content Registration Information
  • Services Registration Information
  • Services Usage Information
  • Anonymized Information

To communicate with you, either directly or through one of our service providers, for: marketing, research, to provide email updates, or other promotional purposes, via email, notifications or other messages, consistent with any permissions you may have communicated to us.

  • Consent, if you are located in the European Union

  • Content Registration Information
  • Services Registration Information
  • Services Usage Information
  • Anonymized Information

Legitimate Business Interests

Where we rely on “legitimate business interests” as the reason for processing your information, we have to carry out a balancing exercise to make sure your rights as an individual are not impacted. In some cases, we have set out our balancing test above. Otherwise, as a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal information in accordance with data protection laws on the basis that we have a legitimate business interest.

We have a legitimate business interest in processing your personal information as:

  • We need the information to respond to your inquiries;
  • We need the information to send you information; and
  • We would be unable to provide our Services without processing your information.

We consider that it is reasonable for us to process your personal information for the purposes of our legitimate interests outlined above as (a) we process your personal information only so far as is necessary for such purpose and (b) it can be reasonably expected for us to process your personal information in this way. In most cases, the information is being processed for your benefit as well as ours.

If we wish to process your existing information for a new purpose other than as stated above, and you are located in the European Union, California or any other jurisdiction that has passed a similar data privacy law, we must inform you of that further processing and provide information surrounding your information’s use.

4. Who we may share your information with.

We generally do not “sell” personal information for purposes of the CCPA. As set forth in this Privacy Notice, we disclose personal information to third parties that we engage for business purposes, to help us run our business and perform the Services, to assist us with complying with our legal obligations, and for other business purposes described in this Privacy Notice. During the preceding 12 months, we have disclosed each of the categories of personal information listed in Section 2 for such business purposes. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information.

In connection with our Services, we may share your personal information with the following types of recipients and for the following reasons:

Categories of Recipients

Reasons for sharing

Service providers and others

We use service providers to operate our software and infrastructure, in particular providers which host, store, manage, and maintain our Services, its content and the data we process. This includes any email marketing or information security service providers.

Data analytics providers

We will share your personal information to create general data analytics regarding usage of our Services, on an aggregate basis and without personal identifiers.

Law enforcement and data protection authorities

We will share your personal information with third parties where required by law (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with our Services or where we have another legitimate interest in doing so.

Other legal or regulatory authorities

We will share your personal information for us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using customer order information in the aggregate, including revenues generated in connection with our regulatory tax requirements).

Buyer or successor of our business

We will share your personal information with any buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of title.

Additionally, we will share your personal information with third parties where required or permitted by law, where it is necessary in connection with our Services and/or to investigate or prevent fraud, abusive or unlawful uses or activities, violations of the terms governing use of the Services and/or any law, rule or regulation, or to protect the security or integrity of the Services.

Most of the third parties with whom we may share your personal information are located and store your information in the United States, although some may store your information outside of the United States, the laws of which may differ than those governing your personal information in your country. If you are located in the European Union, and to the extent the data protection laws in such country are deemed by your country to have inadequate data protection, we have put in place certain measures to ensure that your personal information is subject to suitable safeguards in such transfer outside the European Union.

5. Your rights and options regarding your personal information.

If you are located in the European Union, you have the following rights with respect to your data under certain circumstances:

  • The right to request access to your personal information and the following information regarding our use of your personal information:
    • The purpose of such use
    • The categories of your personal information that we have used
    • Who we have disclosed your personal information to
  • The right to request us to correct any inaccurate personal information concerning you.
  • The right to request us to erase your personal information when we no longer need such data in connection with our services or, with respect to “special categories” of personal information, if you withdraw consent to our use of such information.
  • The right to withdraw consent to our use of personal information, if we are relying on consent to use your personal information.
  • The right to request us to restrict our use of your personal information (e.g., suspend our use of your personal information).
  • The right to object to our use of your personal information where we are not using it to perform Services you have requested from us.
  • The right to receive a copy of your personal information.
  • The right to lodge a complaint with the supervising authority of your country.

If you want to exercise any of the rights listed above, please contact us through one of the methods listed in Section 1 above.

Depending on where you live, you may have certain rights with respect to personal information that we have collected and used under certain circumstances, which may include the following:

  • The right to request the following information regarding our use of your personal information:
    • The purpose of such use and the categories of your personal information that we have used
    • The categories of sources for personal information we have collected about you
    • The categories of third parties with whom we have disclosed your personal information
    • If we have disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained
  • The right to request us to erase your personal information when we no longer need such information in connection with our Services (subject to certain exceptions).
  • The right to receive a copy of your personal information.

If you choose to exercise your CCPA rights, we will not charge you different prices or provide different qualify of services unless those differences are related to your personal information or otherwise permitted by law.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Please understand that we are required to verify your request and may require you to provide some information to enable us to carry out such verification. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you reside in a jurisdiction where one or more of these rights are granted to you under applicable law, and you wish to exercise any such right, please contact us by either:

Phone: +1-800-221-0102

Email: info@cogencyglobal.com

Web Form: https://www.cogencyglobal.com/contact-us-cogency-global

Under California law, individuals that live in California and have provided their information to us may request information about our disclosure of certain information to third parties for their direct marketing purposes. In response to your written request, we will provide a list of the categories of information disclosed to third parties for third party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. If you would like to exercise your rights under California law, please send your written request to the address in Section 1 above.

6. How we safeguard your personal information.

We have put in place appropriate security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Other than third parties with whom we share personal information in connection with our performance of Services, third parties we engage in our business who may have access to your personal information will only process your personal information on our instructions and they are required to only use your data as necessary to perform their contract with us.

While we are committed to protecting your personal information, please note that information communicated over the Internet is never 100% secure. Any transmission of personal information is at your own risk.

7. How long we store your personal information.

We may store your personal information as long as you use our Services to provide you with such Services and for legitimate business purposes.

We may store your personal information following completion of transactions with you to the extent required to comply with our legal, accounting, or reporting requirements and to provide information about our Services (such as your order history) requested by you. Additionally, we may continue to store your personal information contained in our standard back-ups.

Upon your request, we will delete or de-identify your personal information, unless we are legally required or allowed to maintain such personal information.

8. Links.

Our Services may provide links to third-party websites that we do not control. We cannot be held responsible for third parties’ privacy practices or content provided on these websites. If you click on one of these links, please understand that you are leaving our Service and any information you provide will not be covered by this Privacy Notice. Please read that website’s privacy policy before providing any information.

9. Children.

Our Services are not directed to children under the age of eighteen (18) years. By using our Services, you represent that you are at least eighteen (18) years old. If you do not meet this age requirement, then you must not access or use our Services.

We do not knowingly collect information from children under the age of thirteen (13) years old. If you are under the age of thirteen (13) years old, please do not use our Services and do not provide any information to us. For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.

If you think we have collected information from a child under the age of thirteen (13) through our Services, please contact us through one of the methods listed in Section 1 above. If we learn that we have collected the information of a child under the age of thirteen (13) years old, we will take reasonable steps to delete such information.

10. Special notice to non-U.S. users regarding data transfers.

If you are located outside the United States and are using our Services, you should be aware that your personal information will be transferred to the U.S., the laws of which may be deemed by your country to have inadequate data protection. If you are located in a country outside the U.S. and submit personal information to us, you consent to the general use and disclosure of such information as provided in this Privacy Notice and to the transfer and/or storage of that information to the U.S.

11. Governing law and jurisdiction.

This Privacy Notice shall be construed, governed, and enforced under the laws of Delaware (without regard to rules governing conflicts of laws provisions). You agree that venue for all actions, arising out of or relating in any way to your use of our Services, shall be in federal or state court of competent jurisdiction located in Delaware within one (1) year after the claim arises. Each party waives any objections based on forum non conveniens and waives any objection to venue of any action instituted hereunder to the extent that an action is brought in the courts identified above.