Cognitive Systems Corp. Privacy Policy   
Last Updated: 08 25 2023  
1.0 Introduction 
Cognitive Systems Corp. (“Cognitive”) is a technology company headquartered in Waterloo, Ontario,  which focuses on providing WiFi Motion Services to businesses who then provide such services to  End Users. Cognitive does not generally contract with End Users directly. This Policy applies to the  extent applicable to End Users for whom Cognitive receives or processes personal information. Users  who receive such services through third parties should contact the third party (e.g. the ISP provising  the service) for disclosure of the third party’s Privacy Policy.  
For more information about our services, please refer to our website: 
www.cognitivesystems.com 
This Privacy Policy is applicable to Cognitive (“we”, “our” or “us”) as related to our services, which  collectively include: 
• the use of www.cognitivesystems.com (“Website”), 
• social media messages and marketing campaigns, and  
• the use of our products, services, and associated application(s) (“Application”).  
This Privacy Policy sets out the essential details relating to your personal data relationships with  Cognitive as: 
• Website visitor 
• End-user of the Application (“End User”) 
• Prospective client 
• Job applicant, and 
• Partners 
Clients contract the use of our Application and give access to their employees and other third  parties, as solely decided by them, by creating users who access the Application with their email  address and credentials. The Clients’ administrators grant End Users roles, which result in different  permissions and access rights to the information held in the Client account.  
2.0 Personal information we collect 
2.1 Information you choose to provide to us 
WHEN 
We may ask you to provide personal information when: 
• You use the Website to download articles, data sheets or eBooks 
• You request a free trial or demo 
• You refer a third party to us 
• You connect with us directly via phone calls or video conferencing platforms • We or Client account administrators grant you access to the Application 
• You or Client account administrators upload or enter personal information into the  Application  
• You participate in a marketing/sales promotion 
• You attend trade events and other industry networking events 
• You register or attend a webinar or other event 
• You participate in programs we may offer from time to time 
• You participate in chats 
• You pay for our Services.  
If you choose to provide us with a third party’s Personal Information (the person’s name, email and  company) when taking part in our referral program, you represent that you have the third party’s  permission to do so.  
WHAT 
The personal information we collect may include first and last name, business email address, phone  number, company name.  
As an End User of the Application, we may collect your name, business email address and any  comments you make in the Application. 
In addition, we may collect data uploaded by you or other users of the Application that may be  required to use Cognitive services. We expect all users to follow their organization’s privacy policy  and any applicable regulatory requirements when uploading, accessing and using personal  information into our Application. The data uploaded may include personal information like:  
• employee names, email addresses, and contractual agreements, 
• vendor names, email addresses, contractual agreements or other personal data necessary for  Cognitive services, 
• customer names and email addresses used to provide services within Cognitive’s platform • MAC address of devices used to detect motion 
As a Job Applicant, we may also collect your resume and cover letter. 
2.2 Information we collect automatically 
WHEN 
We collect information about your visits to the Website and the Application when you land on any of  our web pages through cookies and similar tracking technology.  
For further information about the types of Cookies we use, you can access our Cookie policy at this  link https://www.cognitivesystems.com/privacy-policy.  
WHAT 
We collect generic data related to frequency of hits, proportions of repeat visits, and regional access.  Unless you select to enter information on a form in order to access protected information or services,  we will not collect personal information such as your name, company name, postal address,  telephone number of email address.  
We collect information for the following purposes:  
● Improving your website experience  
● Specific areas of interest in our products and services  
● Understanding the demographics of groups interested in our products and services  
Cognitive Systems will not pass information submitted or collected through this website to  organizations which are not affiliates of Cognitive Systems. We do not sell information to third  parties. 
We may also collect information when you open email messages from us or click on links within  those email messages. 
3.0 How we use personal information  
We use your Personal Information to: 
• Deliver the contracted Services and allow full use of the Application functionality as  purchased by the Clients 
• Deliver training and support to our Application End Users and/or carry out the transactions  you have requested 
• Process payments for Application subscriptions 
• Send communications to you about: 
o new Application features and upgrades 
o our services and offerings  
o event announcements  
o product notices and changes to our terms and policies  
o particular programs in which you have chosen to participate  
o promotional offers and surveys
o scheduling demos and managing free trials 
• Advertise and market our products and services, including delivering interest-based  advertisements on this Website and other sites or content syndication platforms and  websites. 
• Carry out market research to understand how to improve our Services and their delivery • Create and manage marketing campaigns 
• Generate sales leads and increase our market share 
• Analyze user clicks and usage of the Application and Website to improve user experience and  maximize usage of our Services 
• Manage our Website and Application in order to maintain and deliver the contracted  functionality and services,  
• Enforce our Website and Application Terms and/or separate contracts (if applicable) with you • Prevent fraud and other prohibited or illegal activities 
• Protect the security or integrity of the Website, Application, our business or Services; or • Otherwise, as disclosed to you at the point of collection or as required or permitted by law. 
Please note that sometimes we may record the video conferencing call in which you participate in  order to analyze and improve our staff’s communication skills. If we do so, we will be announcing it  at the beginning of the conference call as well as in the meeting invite and we will be providing a link  to our Privacy Policy in the meeting invites and on the registration page.  
We do not sell your information to any third party.  
4.0 How we share personal information 
Our Application and Services 
Service Providers 
We may use third parties to help us provide our Services. They will have access to your information  as collected by the Website or the Application, as reasonably necessary to perform the contracted  tasks on our behalf. We sign contractual agreements to obligate them to protect the personal  information, to only use it to deliver the contracted services to us, to prohibit them from selling it  and not to disclose it without our knowledge and permission.  

Service  Provider  Name 
Business  purpose 
  
 
Information  collected by  the service  provider 
Data  
location 

  
  
  
  
Legal disclosures 
It is possible that we may need to disclose personal information when required by law, subpoena, or  other legal processes as identified in the applicable legislation.  
We attempt to notify our clients about legal demands for their personal data when appropriate in  our judgment unless prohibited by law or court order or when the request is an emergency. 
Change in Control 
We can also share your personal data 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  data, but only in the manner set out in this Privacy Policy unless you agree otherwise. 
5.0 How we secure personal information 
We are committed to protecting the security of all of the personal information we collect and use.  
We use a variety of physical, administrative and technical safeguards designed to help protect it from  unauthorized access, use and disclosure. We have implemented best-practice standards and controls  in compliance with internationally recognized security frameworks. We use encryption technologies  to protect data at rest and in transit.  
6.0 Your rights 
We provide the same suite of Services to all of our Clients and End-Users worldwide. 
We offer the following rights to all individuals regardless of their location or applicable privacy  regulations. 
For personal information we have about you, you can: 
• Access your personal information or request a copy.
You have the right to obtain information about what personal information we process about you or  to obtain a copy of your personal information.  
If you have provided personal information to us, or you are an End User of the Application, you may  contact us to obtain an outline of what information we have about you or a copy of the information.  
• You have the right to be notified of what personal information we collect about  you and how we use it, disclose it and protect it. 
This Privacy Policy describes what personal information we collect and our privacy practices. We may  also have additional privacy notices and statements available to you at the point of providing  information to us directly. 
• Change or correct your personal information. 
You have the right to update/correct your personal information or ask us to do it on your behalf.  
You can edit your information through the Application or ask us to change or correct it by contacting  us at privacy@cognitivesystems.com.  
• Delete or erase your personal information. 
You have the right to request deletion of your personal information at any time. We will  communicate back to you within reasonable timelines the result of your request. We may not be able  to delete or erase your personal information, but we will inform you of these reasons and any further  actions available to you. 
• Object to the processing of your personal information 
You have the right to object to our processing of your personal information for direct marketing  purposes. This means that we will stop using your personal information for these purposes. 
• Ask us to restrict the processing of your personal information 
You may have the right to ask us to limit the way that we use your personal information.  
• Export your personal data. 
You have the right to request that we export to you in a machine-readable format all of the personal  information we have about you. 
We do not process personal information through the use of automated means.  
If you would like to exercise any of the rights described above, please contact us  at privacy@cognitivesystems.com. 
You also have the right to lodge a complaint with the local organizations in charge of enforcing the  privacy legislation applicable in your territory.
7.0 How long we keep your personal information 
We retain information as long as it is necessary to provide the Services to you and our Clients,  subject to any legal obligations to further retain such information. 
We may also retain information to comply with the law, prevent fraud, collect fees, resolve disputes,  troubleshoot problems, assist with investigations, enforce our Terms of Service and take other  actions permitted by law.  
The information we retain will be handled in accordance with this Privacy Policy. 
Information connected to you that is no longer necessary and relevant to provide our Services may  be de-identified or aggregated with other non-personal data to provide insights which are  commercially valuable to Cognitive Systems Corp, such as statistics of the use of the Services.  
8.0 Other Important Information 
We process data in locations in the USA, Canada and Europe and rely on legally-provided  mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection  and sharing obligations.  
We will only collect and process personal data about you where we have a lawful reason for its  collection. 
When you visit our Website and provide us with your personal information, we collect and use it with  your consent.  
As an Application End User, you consent to our collection of your personal information when you log  in for the first time. However, your Internet Service Provider has control of the Application and may  upload and share additional personal information. It is your Internet Service Provider’s responsibility  to ensure the collection, use and sharing of the personal information uploaded to the Application  complies with all applicable legislation.  
You can review the terms and conditions of use here at our website, or at the applicable website of  your Internet Service Provider. 
Where we rely on your consent to process personal data, you have the right to withdraw or decline  your consent at any time. If you have any questions about the lawful bases upon which we collect  and use your personal data, please contact us at privacy@cognitivesystems.com. 
How to select your communications preferences  
You may choose to receive or not receive marketing communications from us. To stop receiving  marketing communications, please click the “Unsubscribe” link in the email we sent you.  
You may choose which information we collect automatically from your device by controlling cookie  settings on your browser or by selecting your preferences through our Cookie policy.
Even if you opt-out of receiving marketing communications, we may still communicate with you in  connection with security and privacy issues, servicing your account, fulfilling your requests, or  administering any promotion or any program in which you may have elected to participate.  
9.0 Contact Information 
You may contact us to exercise any of your rights or ask for more information about your personal  information and our privacy practices by contacting us at privacy@cognitivesystems.com.
Appendix  
  
A.1 For individuals based in European Union (EU),  European Economic Area (EEA) and Switzerland. 
If you are based in one of these jurisdictions, Cognitive Systems Corp. is the controller of your  personal data collected in the following instances: 
• When you visit our Website www.cognitivesystems.com 
• When we process your personal data for sales and marketing purposes 
Cognitive Systems Corp. is a processor of all personal data processed on the Application, on behalf  of our Clients. We only process the personal data under their direction. Please contact the  organization that granted you access to the Application for details on their privacy practices. 
We only process personal data if we have a lawful basis for doing so. The lawful bases applicable to  our processing as controller are: 
• Consent - We will ask for your express and informed consent every time we collect your  personal data on this legal basis. 
• Contractual basis - We process the personal data as necessary to fulfill our contractual  terms with you or our Clients. 
• Legitimate interest - We process the names, contact details, job titles, companies of our  existing and prospective clients for our marketing purposes, including market research and  sales leads generation.  
You have the following rights under the GDPR: 
• Be informed about the collection and use of your personal data 
• Access your personal data 
• Correct errors in your personal data 
• Erase your personal data 
• Object to the processing of your personal data. 
o This right is also available to individuals whose personal data is processed by us for  direct marketing purposes. If you object to the processing of your personal data for  direct marketing purposes, we shall stop processing within 30 days of receipt of your  request.  
• Export your personal data
• Restrict our processing of your personal data for specific reasons, including any of the  purposes supported by the legitimate interest legal bases. (see the section above).  
We process personal data in Europe and share it with our service providers, located in Canada, USA  and other jurisdictions. We use standard contractual clauses as the data transfer mechanism of  transferring EU data to countries subject to data transfer requirements. See the table of our service  providers above.  
You may contact us at privacy@cognitivesystems.com or you may contact our EU Data  Representative at:  
bob.elhawary@cognitivesystems.com 
You may also lodge a complaint with your local supervisory authority, EU Data Protection Authorities  (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC). See their contact  details here National Data Protection Authorities.  
A.2 For individuals based in California 
This section provides additional specific information for consumers based in California as required by  the California Consumer Privacy Act of 2018 (“CCPA”). 
A.2.1 Collection and Use of Personal Information 
Cognitive Systems Corp. is a processor of all personal data processed on the Application, on behalf  of our Clients. We only process the personal data under their direction. Please contact the  organization that granted you access to the Application for details on their privacy practices.  
In the last 12 months, we have collected the following categories of personal information: 
• Identifiers, such as your name, mailing address, email address, zip code, telephone number,  or other similar identifiers. 
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password,  company name, job title, business email address, and department. 
• Internet/Network Information, such as your browsing history, log and analytics data,  information about the device(s) used to access the Services and information regarding your  interaction with our websites or Services and other usage data. 
• Geolocation Data, such as information about your location (at country and city level)  collected from your IP address. 
• Sensory Information where permitted by you and/or the law. 
• Profession/Employment Information that you include in your CV, cover letter and send to us  when applying for a position. 
• Other Personal Information, such as personal information you provide to us in relation to a  survey, comment, question, request, article download or inquiry and any other information  you upload to our Application.
We collect personal information directly from you, from your browser or device when you visit our  websites, from third parties that you permit to share your information or from third parties that share  public information about you and as stated above. 
See the section above, “How we use personal information,” to understand how we use the personal  information collected from California consumers. 
A.2.2 Recipients of Personal Information 
We may share personal information with third parties for business purposes. The categories of third  parties to whom we disclose your personal information may include: (i) our service providers and  advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics  providers; and (v) social networks.  
Please see the "How We Share Information" section of the Privacy Policy above for more information. 
A.2.3 California Privacy Rights 
As a California resident, you may be able to exercise the following rights in relation to the personal  information about you that we have collected (subject to certain limitations at law): 
• The Right to Know any or all of the following information relating to your personal  information we have collected and disclosed in the last 12 months, upon verification of your  identity: 
o The specific pieces of personal information we have collected about you; 
o The categories of personal information we have collected about you; 
o The categories of sources of the personal information; 
o The categories of personal information that we have disclosed to third parties for a  business purpose, and the categories of recipients to whom this information was  disclosed; 
o The categories of personal information we have sold and the categories of third  parties to whom the information was sold; and 
o The business or commercial purposes for collecting or selling the personal  information. 
• The Right to Request Deletion of personal information we have collected from you, subject  to certain exceptions. 
• The Right to Opt-Out of Personal Information sales to third parties now or in the future.  However, we do not sell your personal information. 
You also have the right to be free of discrimination for exercising these rights.  
Please note that if the exercise of these rights limits our ability to process personal information (such  as a deletion request), we may no longer be able to provide you with our products and services or  engage with you in the same manner.
A.2.4 How to Exercise Your California Consumer Rights 
To exercise your right to know and/or your right to deletion, please submit a request by contacting  us at privacy@cognitivesystems.com. 
We will need to verify your identity before processing your request.  
In order to verify your identity, we will generally require sufficient information from you so that we  can match it to the information we maintain about you in our systems. Sometimes we may need  additional personal information from you to be able to identify you. We will notify you.  
We may decline a request to exercise the right to know and/or right to deletion, particularly where  we are unable to verify your identity or locate your information in our systems or as permitted by  law. 
You may choose to designate an authorized agent to make a request under the CCPA on your  behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and  verified. Once a request has been submitted by an authorized agent, we may require additional  information (i.e. written authorization from you) to confirm the authorized agent's authority.  
If you are a third party (end user, auditor, business associate etc.), who was given access to the  Cognitive application by a Cognitive Client, please direct your requests and/or questions directly to  the Cognitive Client that gave you access. 
Minors Under Age 16 
Our application and services are intended for business use and we do not expect them to be of any  interest to minors. We do not intentionally collect any personal information of consumers below the  age of 16. We do not sell the personal information of California consumers.