Privacy Policy

Last Updated: September 04, 2024

This Privacy Policy explains how Cognition AI, Inc (“we”, “our” or “us”) collect, use, disclose, and safeguard your information when you use our software-as-a-service offerings that we make available to individuals via www.cognition.ai, along with any associated software, apps and websites (collectively, the “Services”).

If you reside outside of the UK and European Economic Area (the “EEA”), accessing and using our Services means that you acknowledge this Privacy Policy and our data practices. For the purposes of UK and EEA law, Cognition AI, Inc is the controller of your data.

It is important that you understand how we use your information. You should read this page in full, but below are key highlights and some helpful links:

• Our goal is to simplify your experience. If you do not wish for your personal information to be collected, used, or disclosed as described in this Privacy Policy, or you are under 18 years of age, you should stop accessing our Services.
• We collect and use your information in order to provide and improve our Services and your experience, protect the security and integrity of our platform, and meet our legal obligations.
  • To learn more, explore Section 1. Information We Collect and Section 2. How We Use Your Information.
• We share your information with trusted third parties and service providers in order to offer our Services, fulfill legal requirements and for the purposes set out more fully below.
• If you have any questions, or to exercise any available rights, please contact us at privacy@cognition.ai.

1. Information We Collect

We collect, and in the past 12 months have collected, the following personal information about you:

Information You Provide To Us	Description
Basic Information	First name, last name, email address, password, and phone number.
User Content	Any personal information collected when you use our Services, including personal information that may be provided in the input, file uploads, feedback or output.
Communications	Any communications that we exchange, including communications with interfaces such as our chatbots, survey responses, or feedback.

Information Collected Automatically	Description
App, browser, and device information	Information about the device, operating system, or browser you are using IP address Other device characteristics (e.g. plugins, the network you connect to)
Services usage data	Activity Information: Information regarding your interaction with the Services, such as about what you view or click while visiting our site, features that you interact with, emails you have opened and clickstream data (e.g., how much time is spent on a page, content viewed or interacted with, text entered) Diagnostic and Troubleshooting Information: Information about how our Services are performing when you use them, e.g., service related diagnostics and performance information, including timestamps, crash data, website performance logs, and error messages or reports
Information from cookies and similar technologies	We use cookies to operate and administer our Services, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or notify you when a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website**.** While your browser settings may allow you to transmit a “Do Not Track” or “opt-out preference” signal, our website is not designed to respond to such signals and we do not use or disclose personal information in a manner that would legally require us to recognize opt-out preference signals.

Personal information does not include information that has been de-identified, anonymized or aggregated. When data is de-identified or anonymized, we maintain it in that form and do not attempt to re-identify the information.

2. How We Use Your Information

We use your personal information to deliver, personalize, operate, improve, create, and develop our Services, to provide you with a secure, smooth, efficient and customized experience as you use our Services, and for legal compliance, and loss prevention. We only use your account password to create and maintain your account and to provide you with the Services. Learn more about how we use your personal information and our legal basis for each such use case below.

Why and How We Use Your Information	Information Categories Used	Legal basis of Processing (where applicable)
To create and maintain your account	Basic Information	Necessary to perform our contract with you
To provide you with Services	Basic Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us	Necessary to perform our contract with you
To provide customer support	Basic Information, Communications, Services usage data (including location information), App, browser, and device information	We rely on our legitimate interests or those of third parties (like other users and in some cases, the general public) where they are not outweighed by your rights and freedoms. In the EEA and UK, you have the right to object to, and seek restrictions of this processing (“Legitimate Interests”) - specifically, our interest in being responsive to your requests and ensuring you have the best use of the Services
To send Service communications	Basic Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us	Necessary to perform our contract with you Legitimate Interests - specifically, our interest in ensuring you have the best use of the Services
To promote safety, security, and integrity of our Services	Basic Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us	Legitimate Interests - specifically, our interest in ensuring and maintain the effective operations and delivery of the Services
To comply with legal and regulatory obligations We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities	Basic Information, Communications, App, browser, and device information, Services usage data, Additional information you submit to us	To comply with our legal obligations Legitimate Interests - specifically, our interest in complying with legal obligations, requests and our corporate responsibilities where we operate
To customize your experience with our Services and otherwise improve our Services	Basic Information, Communications, App, browser, and device information, Services usage data	Legitimate Interests - specifically, it is in our interest to understand how you interact with the Services in order to customize and/or improve our products and Services and enable accurate and reliable reporting
Where not otherwise required by law, and depending on the circumstances, we may preserve and share your information: In response to requests from third parties, law enforcement, or other governmental authorities To promote the safety, security, and integrity of the Services, network, our users, employees, and the public	Basic Information, Communications, App, browser, and device information, Services usage data	Legitimate Interests - specifically, it is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of the Services, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our personnel and property or the Service) our users or others, to defend our legal rights and resolve disputes, to secure our platform and network, to verify accounts and activity, to combat harmful conduct, to prevent and address fraud, abuse and other bad experiences to prevent death or imminent bodily harm
To research and innovate	Basic Information, Communications, Service Usage Data	Legitimate Interests - specifically, it is in our interest and our users interest to improve and iterate our Services through information obtained from users, surveys, reviews, and feedback

3. How and Why We Share Your Information

We do not sell or share your personal information with third parties for targeted advertising purposes, nor have we done so in the past 12 months. We also do not have actual knowledge that we sell or share for targeted advertising purposes personal information about individuals under 16 years old. We work with service providers and other third parties to help us provide our Services, and as a result we need to provide certain information with these third parties as described below.

We disclose, and in the past 12 months, we’ve disclosed, the categories of personal data set forth in Section 1 with the following categories of third parties:

• Third Party Service Providers - We provide personal information to third party service providers who help us provide our Services.
• Other Third Parties - Certain features allow you to display or share information with other users or third parties. For example, you may share Devin AI conversations with other users via shared links. Be sure you trust any user or third party with whom you share information.
• Professional Advisors, authorities, and regulators - We share your information with our advisors, regulators, tax authorities, law enforcement, and government agencies to:
  • Respond pursuant to applicable law or regulations, court orders, legal process or government requests;
  • Comply with our reporting and information sharing obligations and regulatory authorities
  • Detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues; and
  • Protect the rights, property, safety of us, our users, or others, including to prevent death or imminent bodily harm.
• Your employer or related organisation - If you create an account using an email address belonging or relating to your employer or another organisation, we may share the fact that you have an account and certain account information (such as your email address) with your employer or organisation to, for example, enable you to be added to their business or enterprise account. In addition, administrators of any enterprise or business account may be able to access certain information associated with and control your account.
• To our affiliates or others within our corporate group, as a matter of our legitimate interests to efficiently provide the Services**.**
• Asset Transfer or Company Acquisition - We may choose to buy or sell assets, and may share and/or transfer information about our users in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, merged, reorganized, or if we go out of business, enter bankruptcy, or go through some other change of control or similar event, your personal information could be transferred in connection with that transaction.
• When you request or direct us to disclose information, with your consent or to perform our contract with you**.**

Our Services may contain links to other websites not operated or controlled by Cognition AI, Inc, including social media services ( “Third-Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies

4. Security

We implement commercially reasonable technical, administrative, and organizational measures intended to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, these measures are not a guarantee of absolute security and you acknowledge and accept that your use of our Services is ultimately at your own risk.

5. Retention

We retain your personal information as needed to provide our Service to you, comply with legal obligations, or protect ours or others interests. How long we retain personal information includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, or information preservation requirements. We also keep certain information where necessary to protect the safety, security, and integrity of our Services or users.

In line with these considerations, we delete information that is no longer needed for the above purposes or when you request deletion of your information.

6. Children’s Personal Information

The Services are not intended for children, and we do not knowingly request or collect any personal information from children. As set out in our Terms, users must be at least 18 years old in order to access the Services.

7. International Transfers

To facilitate our operations, Cognition, our third-party partners, and service providers may transfer, store, and process your personal information throughout the world, including the EU, UK and the US. If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon certain legal mechanisms to facilitate these transfers of your personal information, including in some cases the European Commission’s Standard Contractual Clauses and relevant local clauses (e.g., the UK’s International Data Transfer Addendum) to facilitate the international and onward transfer of European personal data to third countries. You can contact us at the address below to view a copy or request more information about these mechanisms.

8. Your Privacy Rights and Choices

Depending on where you live, you may be able to exercise certain privacy rights related to your personal information. If any of the rights listed below are not provided for under law for your jurisdiction, we have absolute discretion in providing these rights.

• Right to access/know and portability: You may have the right to request that we provide you a copy of your personal information held by us, or for details relating to the ways in which we use and disclose your personal information, and how we have used or disclosed your personal information in the past. You may also have the right to request that we provide certain personal information in a structured, commonly used, machine-readable format and make this available to you or a designated third party.
• Right to deletion/erasure: You may have the right to request to erase your personal information. If you end your Services, we will retain or delete information associated with your account as described in Section 5.
• Right to rectification/correction: You may have the right to request us to rectify or update any of your personal information that is incomplete or inaccurate.
• Right to object or restrict processing: You may have the right to restrict or object to us using or transferring your personal information based on our legitimate interests, in the public interest or for direct marketing. We may continue to process your personal information where permitted or required by applicable law.
• Right to withdraw your consent: To the extent processing of your personal information is based on your consent, you may withdraw your consent at any time. The lawfulness of our processing before you withdraw your consent will not be affected by such withdrawal.
• Right to Appeal: If we deny your request, you may have the right to appeal our decision regarding your privacy request.
• Right to lodge a complaint: You have the right to lodge a complaint with your local data protection authority.

You may submit a request to exercise these rights by contacting us at privacy@cognition.ai. We will not discriminate against you for exercising any of your rights provided to you under law. To protect your privacy and security, we may take steps to verify your identity before complying with your request, including to ask for further information, and we may decline your request if we are unable to verify your identity.

Under certain US data privacy laws, you may also designate an authorized agent to make these requests on your behalf. Before accepting a request from an agent, we will require that the agent provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

The above rights are not absolute, and may only apply or be denied in certain circumstances.

9. How to Contact Us With Questions

If you have any questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at privacy@cognition.ai.

10. Changes to this Privacy Policy

We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.